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

• Where you have provided your separate consent, to provide you with early access to new releases, exclusive events, special offers, newsletters, events and promotions either of Full Circle or its trusted partners, and to otherwise market to you (with direct marketing materials), via any medium including mail, telephone, commercial electronic messages (such as SMS, MMS, instant messaging, email, social media, mobile applications), or any other form of electronic, emerging, digital or conventional communications channel;
• To provide you with relevant advertising;

Managing our Relationship

• To carry out any purchases you make and otherwise manage our commercial and trading relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you our products and to address your expectations of us in respect of how we conduct our business;
• To ensure that your personal information remains up-to-date and complete;
• To provide you with information about your Full Circle account, customer account, transactions, content, services and products;
• To fulfill obligations in respect of any contract between you and Full Circle; to render services related to Full Circle and our customers (such as after sales services and enquiries); to facilitate payments from you;
• To contact you, including sending you any technical, administrative or legal notices relevant to Full Circle or our Full Circle websites; (viii) to otherwise maintain our relationship with you;

Full Circle’s Website

• To maintain the functionality of the Full Circle website, including the provision of information to you relating to the content available on the website; to improve the website and system administration; Improving our offerings
• To better understand and meet your needs and interests, to enable us to improve the nature of the goods and services we provide and to more accurately market our goods and services, and research our customers;
• To obtain opinions or comments about products and/or services and to conduct other research and development;
• To record statistical or de-identified data for analysis including marketing analysis;
• To conduct market research including identifying likeminded individuals; Miscellaneous
• To share personal information with our group companies and their related bodies corporate and agents, and other trusted third parties in the manner described in this Privacy Policy;
• For any further purposes stated in a particular collection channel;
• Where explicitly notified to you, to undertake recruitment for Full Circle;
• To manage your employment with Full Circle (if applicable);
• Any other purpose as may be deemed reasonably necessary by Full Circle in the circumstances;
• Perform processes related with security monitoring and CCTV Surveillance to ensure safety and security of all distillery guests, staff and other visitors.
• As needed to satisfy any law, regulation or legal request, to protect the rights or property of Full Circle, any member of the Full Circle group, or any member of the public, to protect the integrity of the Full Circle website, to fulfill your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

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:

• (i) When you make a purchase or attempt to make a purchase through the Site:
  • To address and respond to your product inquiries and complaints from our digital platform;
  • To fulfill your product orders with us;
  • To monitor your activities and purchases;
  • To serve as a reference and to process your billings;
  • To serve as a source for analysis in granting credit limits;
  • To serve as reference for our targeted advertising or marketing communications we believe may be of interest to you;
  • To monitor constantly customers and transactional records to identify unauthorized transactions and fraudulent accounts and orders;
  • To identify and trace any suspicious and high-risk transactions which includes determining if there is improper activity involved and verification of identity;
  • To conduct internal market research and measure the effectiveness of our advertising campaigns;
  • To perform any other action as may be necessary to implement the terms and conditions of our contract.
• (ii) When you want to become a part of our team:
  • To consider and evaluate your suitability for employment and, with a written or expressed consent, retain your personal information for a maximum of 10 years upon separation with the company;
  • When hired, to process your data necessary for your employment such as, but not limited to, payroll, benefits and loan application, allowances and refunds processing, tax processing, retirement benefits, and other purposes that demand processing of your personal data (e.g., to execute business transactions directly related and/or incidental to your job, business travels, anniversaries, social activities, emergencies, and so on);
  • Encode your data in our payroll software system;
  • While employed, for your performance evaluation and career development including seminars, trainings, workshops, and compliance monitoring;
  • To comply with our obligations under the law and as required by government organizations such as DOLE, BIR, SSS, HDMF and Phil Health; and,
  • Upon separation, to process your data for the exit interview and preparation of your final pay.

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:

• Personal information such as full name, provincial and billing/shipping addresses, e-mail address, telephone, other personal contact numbers, IP address and time zones;
• Sensitive personal information such as birth date, age, citizenship, civil status, gender, health, education and government issued identification document which includes, but not limited to government issued identity cards (ID), licenses, Credit card information;
• Employment record such as educational background, employment history, certifications, trainings attended, income information of your previous jobs, reason for leaving your previous job; and
• Biometric information such as fingerprints, full-face photographs, and any comparable images. You are responsible for ensuring that all data, whether personal information, sensitive personal information or privileged information, you submit to Full Circle is accurate, complete and up-to-date.

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

• Fill out physical or other ad-hoc channels in relation to events and our distillery;
• Fill out our forms such as: Information sheets, Performance evaluation forms and employee goal forms;
• Disclose your personal information through SMS, disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized representatives;
• Disclose your personal information through Kalibrr, Indeed or Jobstreet;
• Visit our website, we automatically collect certain information about your device such as cookies and IP address;
• Visit our social media pages, internal website, and any Full Circle mobile or tablet applications;
• Make a purchase or attempt to make a purchase through the Site, we collect your name, billing address, shipping address, and payment information and credit card numbers and valid IDs; and
• Any other means through which an individual provides personal information, including either physically or electronically.

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:

• As necessary for the proper execution of processes related to the purposes declared in this Privacy Policy.
• The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law). This means we might provide your personal data to the following:
  • Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
  • Law enforcement and government agencies;
  • All third parties with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

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:

• We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
• We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
• Any personal data that you provide on the website is initially processed and stored by Full Circle. Using a secured connection, only authorized Full Circle personnel can then access and download your personal data from the system.
• It is important for you to protect against unauthorized access to your password and to your computer.

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.