Privacy Policy

18 July 2019

I. INTRODUCTION

Full Circle Craft Distillers Co., Inc. (Full Circle) upholds your privacy and recognizes the need for appropriate measures to protect and manage your personal data entrusted to us. Our Privacy Policy obeys, and is consistent with, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC), as well as other relevant laws of the Philippines.

Throughout this Privacy Policy, we use the term 'personal information' to refer to information relating to an identified or identifiable natural person, including information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. For example, your full name, date of birth, address, mobile telephone number, email address and credit card details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.

This Privacy Policy proclaims how Full Circle processes (how it collects, uses, shares, and keeps) and protects your personal data. It also provides the steps that you can take should you wish for any change in how we use your personal data, or if you want us to stop using your personal data.

II. PROCESSING OF PERSONAL DATA

A. Why we collect your personal data

To enable us to comply with our corporate policies in relation to data subjects as well as with the requirements under the Data Privacy Act, it is important that we collect, use, store and retain your personal data only as is reasonable and necessary for a declared and specific purpose stated in the pertinent consent forms.

In general, personal information that Full Circle collects will be used for the following primary purposes:

Special Offers, Marketing and Advertising

Managing our Relationship

Full Circle’s Website

In addition, from the general uses mentioned above, we may use your personal information depending on your transactions with us in any of the following means:

C. The type of personal data do we collect

We collect information to provide you with details and information regarding our product, services, and promotions. We process information also to respond to your enquiries or manage future interactive user function. The common type of data collected by Full Circle from you, generally includes the following:

D. How we collect, acquire or generate your data

We (or our subcontractors) collect and combine personal information in a number of was through the following channels

E. With whom we share your personal data

As a general rule, we are not allowed to share your data to third party except in limited circumstances as listed below.

By giving your consent, you authorize Full Circle to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:

However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

III. PRIVACY POLICY FOR USING WEB ANALYTICS

All our websites engage third-party service providers to analyze the web traffic data for us. This service does use cookies or web beacons.

As you interact and navigate through our site, such as clicking on the links, viewing pages and site content and other similar actions and statistics about your site interaction. We automatically capture certain information from your computer such as cookies and web beacons, which are also collected by our third party tracking for analytics and advertising purposes. We associate with third party ad networks and ad servicing providers that provides advertising campaigns on behalf of us. Advertisements includes those which might be appeal to you, and are tailored to your interest based on the information we have collected from you.

Cookies and web beacons are small files that our website puts on your personal computer (PC) to store information about your preferences. If you don't want our website to store cookies and web beacons on your PC, you can block it. We use this information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, measuring the effectiveness of advertising campaigns.

Use the options in your web browser if you do not wish to receive cookies or you wish to set your browser to notify you when you receive cookies. Click on the "Help" section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

IV. PRIVACY POLICY REGARDING FRAUDULENT AND MALICIOUS TRANSACTIONS

From time to time, we monitor constantly customers and transactional records to identify unauthorized transactions and fraudulent accounts and orders. We will request customers to submit necessary documents for identity verification and to proceed with their purchases.

Customer’s transaction will automatically be cancelled, should he/she fail to provide us with the necessary documents.

V. DATA PROTECTION

We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete, and up-to-date. We strictly enforce this Privacy Policy within Full Circle and we have implemented technological, organizational and physical security measures to protect your personal data from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

Be sure to sign-off when finished using a shared computer.

VI. DATA RETENTION

The personal data will be kept in our facilities located in the Philippines and the US and in accordance with the retention standard as listed below unless you request your personal data to be deleted in our systems, databases and hardcopies immediately. Once deleted, your personal data will no longer be searchable or included in anonymous searches and will be completely removed from all the storage location.

Full Circle reserves the right to retain your personal data in our files located in the Philippines and US under certain circumstances such as when your personal data may be necessary to resolve disputes, or if Full Circle is required to do so by law or in the good faith; provided that such action is necessary to comply with a legal obligation and/or protect and defend the rights or property of Full Circle or its affiliates. If Full Circle is required to retain any portion of your personal data for such purposes, it shall use reasonable efforts to limit such data to what is necessary to accomplish the particular purpose.

VII. CHANGES IN OUR PRIVACY POLICY

As necessary, this Privacy Policy may be updated from time to time. If we change our Privacy Policy, we will post the revised version in our website: http://www.fullcircledistillers.com/privacy-policy. Such updates will take effect immediately, so we suggest that you check our website periodically for the most up-to-date version of our Privacy Policy. Rest assured, that any changes will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless required by law.

VIII. YOUR DATA PRIVACY RIGHTS

Should you wish to exercise your rights as a data subject (which include the right to access, modify, erase, and object to the processing of your personal data) or should you have any inquiries and feedbacks on this Privacy Policy, and/or complaints to Full Circle, you may reach us through our “Contact Us” menu in our website, through a written letter or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:

Data Protection Officer Full Circle Craft Distillers Co., Inc. 8 San Juan River Drive Carmelray Industrial Park II – Special Economic Zone Calamba City, Laguna 4027 Philippines +63.918.8881107 privacy@fullcircledistillers.com

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph/mechanics-for-complaints.

Our decisions to provide such access or consider any request for correction, erasure and objection to process your personal data as it appears in our records are always subject to any exceptions under applicable and relevant laws and/or the DPA, its IRR and other issuances of NPC.

To cover for the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested, we may charge you reasonable fees based on administrative costs.