SOW Philippines Fulfillment Corporation (hereinafter referred to as “PAYO”, “we”, “our” or “us”) respects and values data privacy and employs reasonable measures to protect personal data in accordance with the Data Privacy Act of 2012 (‘DPA’), its Implementing Rules and Regulations, and related issuances from the National Privacy Commission (‘NPC’).
PAYO maintains a website and a technology solution to facilitate cash-on-delivery services and other business solutions (the “Services”).
- PERSONAL INFORMATION CONTROLLER
PAYO is the personal information controller of any personal data that you may disclose through the use of this website, which means that it determines the purposes for which your personal data is being collected and processed. It may also be that, with your consent, your personal data is disclosed to third parties pursuant to a data sharing agreement, in which case, such third parties are also the personal information controllers of your personal data.
- Keep track of services you have used,
- Record registration information,
- Record your user preferences,
- Keep you logged into the websites, and
- Track the pages you visit.
Cookies help us understand how the websites is being used and improve your user experience.
The following types of cookies may be used when you visit the websites:
- Advertising Cookies
Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the websites and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any other personal information about you.
- Analytics Cookies
Analytics cookies monitor how users reached the websites, and how they interact with and move around once on the websites. These cookies let us know what features on the websites are working the best and what features on the websites can be improved.
- First Party Cookies
First Party Cookies can either be permanent or temporary. These are necessary cookies, without which the websites will not work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the website.
- Personalization Cookies
Personalization cookies are used to recognize repeat visitors to the websites. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the websites.
- Security Cookies
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
- Websites Management Cookies
Websites management cookies are used to maintain your identity or session on the websites so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
- Third-Party Cookies
Third-party cookies may be place on your computer when you visit the websites by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.
- Other Tracking Technologies
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the websites to help customize the websites and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
- Control of Cookies
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the websites.
For more information on how to control cookies, please check your browser or device’s settings for how you can control or reject cookies, or visit the following links:
In addition, you may opt-out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool.
PERSONAL DATA COLLECTED AND PROCESSED
When you visit our website, the following data is transmitted to us or to our web space provider (so called server log files) by your internet browser:
- type and version of the browser you use
- operating system
- websites that linked you to our site (referrer URL)
- websites that you visit
- date and time of your visit
- your Internet Protocol (IP) address
This anonymous data is stored separately from any personal information you may have provided, thereby making it impossible to connect it to any particular person. The data is used for statistical purposes in order to improve our website and services.
We collect personal data from the merchants and consumers in accordance with the provisions of the DPA. Information is considered personal if it can be associated exclusively to a specific natural person.
For consumers, we collect the following categories of data:
- Email Address
- Goods Purchased
For merchants, we collect the following categories of data, depending on the transaction:
- Personal Details: Name, Organization Name, Username
- Government-Issued Identification:
- Device details: IP address, event logs, location, operating system version, configuration of devices when visiting the website, time and date of visit and usage and other related statistics and device identifying information etc.
- Transactional information: transactions made using the Service, communications related to the transactions
METHODS OF COLLECTION
- Consumer Information: Merchants provide PAYO with consumer information in order to manage the last mile service on behalf of the Merchant.
- Merchant Information: Merchant information is collected through the submission of personal data on the registration form upon signing up with PAYO’s services. We may also collect your personal data from any other documents or communications that you may have directly submitted to us, from publicly available information, or from third parties.
- Use of the Website. Server log files are collected through your use of the website.
- Contacting Us. On our website, we offer you the opportunity to contact us, either by email and/or by using a contact form. In this event, information provided by the user is stored for the purpose of facilitating communications with the user. No data is transferred to third parties. Nor is any of this information matched to any information that may be collected by other components of our website.
PURPOSES FOR COLLECTION AND USE
Personal data will be used for the following purposes
- Delivery of goods to consumers, whether through third-party logistics providers and other service providers or otherwise;
- Analysis of credit history;
- Fraud detection;
- Money collection;
- Order tracking;
- Pickup and delivery of goods to consumers;
- Money remittance;
- Process payments for Services delivered;
- To communicate with you through any communication channel regarding any questions, concerns, or complaints that you may have in relation to your use of the website, availment of our Services, and exercise of your data privacy rights;
- Improvement of our website and Services;
- To conduct market research and analysis, such as surveys;
- To conduct direct marketing activities, such as e-mail announcements, contests, and other promotional activities;
- To generate leads for direct marketing purposes;
- To comply with statutory and regulatory requirements, including directives, issuances by, or obligations of PAYO to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
- To enable PAYO to exercise sound corporate governance over its businesses, ensure that risks arising therefrom are duly identified, measured, managed and mitigated, and enhance risk assessment and prevent fraud;
- To conduct company audits or investigate a complaint or security threat;
- Other legitimate business purposes;
- Establish, exercise, or defend legal claims;
- Fulfill any other purposes directly related to the above-stated purposes.
PAYO will not process personal data in ways incompatible with the above-stated purposes.
You may inform us of the specific personal information you do not want to be processed beyond the requested purpose. We will respect your request in so far as it is feasible to fulfill the purposes for which the personal data was collected.
DISCLOSURE TO THIRD PARTIES
- Use of Twitter recommendation components
- Use of ClickFunnel
We use ClickFunnel with our marketing and sales process. ClickFunnel is a service provided by Etison, LLC. Our sales team uses ClickFunnel in the process of collecting leads for sales purpose. We will not compare the data collected during ClickFunnel registration with any other data that might be collected by other components of our platform.
- Use of YouTube components with enhanced data protection mode
On our website, we use components (videos) of YouTube, a company belonging to Google Inc., USA. To this end, we use the “ – enhanced data protection mode – ” option provided by YouTube. When you display a page that has an embedded video, a connection will be made to the YouTube server and the content will appear on the website via a communication to your browser. According to the information provided by YouTube, in “ – enhanced data protection mode -”, data is only transferred to the YouTube server, in particular which of our websites you have visited, if you watch the video. If you are logged onto YouTube at the same time, this information will be matched to your YouTube member account. You can prevent this from happening by logging out of your member account before visiting our website. Further information about data protection by YouTube is provided by Google under the following link: https://policies.google.com/privacy?hl=en/
- Use of MailChimp
Newsletter Consent. If you subscribe to our newsletter, you give your consent to data being processed by a service provider located in the United States. We use the newsletter to provide you with regular updates about our offers. To receive our newsletter, you will need a valid email address. We will then check the email address entered to ensure that you are actually its owner or if its owner has agreed to receive our newsletter. By registering for the newsletter, we will save your IP address and date and time of registration. This will be used in case a third party misuses your email address to subscribe to our newsletter without your knowledge. We will not compare the data collected during newsletter registration with any other data that might be collected by other components of our site.
Newsletter by MailChimp. We use MailChimp to send our newsletter to our subscribers. MailChimp is a service provided by The Rocket Science Group, USA. The data stored when you registered for the newsletter (email address, name, IP address, and time and date of registration) will be sent to a server operated by The Rocket Science Group in the United States and stored there in accordance with its Safe Harbour Agreement. Further information about the data protection offered by MailChimp can be found at: http://mailchimp.com/legal/privacy/
You may cancel your newsletter subscription and revoke your consent to the storage of this data at any time with future effect. For instructions to take this step, please refer to the confirmation email and each newsletter.
Newsletter Tracking. Our newsletter includes so-called web bugs that allow us to recognize if and when an email has been opened and which links in the email have been clicked by its recipient. This data is stored by us so that we can best align our newsletter to the wishes and interests of our subscribers. Accordingly, the data thus collected is used to send personalized newsletters to each recipient. If you subscribe to our newsletter, you agree that your data and your user responses will be stored electronically by newsletter tracking so that you can receive a personalized newsletter. By revoking the consent to receive the newsletter, the consent to the aforementioned tracking is revoked.
- Payment Partners
In order to process the payment of your requested products or services, it necessary for use to disclose your information to our payment partners.
Personal data of merchants and consumers is disclosed to couriers in order to facilitate the pick-up and delivery of goods.
- Law Enforcement, Regulatory Agencies, and other Legal Bodies
Your information may be disclosed where it is required to satisfy any applicable law, regulation, legal process or enforceable governmental request.
- Collaborations, Mergers, and Acquisitions
We reserve the right to transfer or assign the personal data we have collected from you in the event PAYO enters into product and service collaborations with third parties, is acquired by, or enters into a merger with, a third party, or in the event we undergo any other form of reorganization. In certain limited circumstances, our business partners may have a contractual right to obtain a copy of your contact information and to contact you if PAYO is unable to fulfill its contractual obligations to those parties.
- Other Disclosures
We may share your personal data when we believe in good faith that access, use, preservation or disclosure of such information is reasonably necessary to detect, prevent, or otherwise address fraud, security or technical issues, and/or protect against harm to the rights, property or safety of PAYO, its clients or the public as required or permitted by law.
- Data Outsourcing and Data Sharing Agreements
PAYO only shares your personal data with other entities or individuals outside of the company in limited circumstances. When information is disclosed to third parties or when the processing of personal data is outsourced by PAYO to a third party, the processing will be subject to written agreements between PAYO and the third parties processing the data, in accordance with the requirements of the DPA. These written agreements specify the rights and obligations of each party and will provide that the third party has adequate security measures in place and will only process personal data on the specific written instructions of PAYO.
We will not sell, rent, share, trade, or disclose any of your personal information to any other party without your prior written consent, with the exception of entities within our company and any third-party service provider which we have engaged whose services necessarily require the processing of your personal data.
DATA RETENTION AND DISPOSAL
We offer merchants the opportunity to sign up for PAYO’s services. The information entered when signing up, as shown in the registration form is collected and stored solely for use by our platform. We also store your IP address and the date and time you registered. This serves to protect us in the event a third party improperly and without your knowledge makes use of your data to sign up for our site. None of this information is transferred to third parties nor is any of this information matched to any information that may be collected by other components of our website.
When merchants provide PAYO with consumer details these are being stored in PAYO servers in order to manage the last mile service on behalf of the merchant. Merchant and Consumer details are transmitted to a selected courier company in order to ship the parcel to the Consumer. PAYO has no control over the data once it is sent to a courier. The merchant declares that he allows PAYO to send such data to the Courier in order to avail of Services provided by PAYO and the Courier.
We will retain your personal data for as long as you maintain an account on our website and as may be required by law. You may request for the deletion of your personal data by contacting us if you no longer wish to keep your account. We will promptly delete your personal data from our servers upon receipt of your request.
SECURITY AND CONFIDENTIALITY OF INFORMATION
RIGHTS OF THE DATA SUBJECT
Please be informed that you have the following rights under the Data Privacy Act of 2012:
- Access Personal Data
You may request access to any of your personal data held by the company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the PAYO Data Protection Officer.
- Make Corrections to Personal Data
It is your responsibility to inform us of any changes to the personal data that you have supplied during the course of your engagement.
- Object to the Processing of Personal Data
- Erasure or Blocking of Personal Data
You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our systems. Please note that depending on the type of personal information involved, you may be restricted from accessing any of our Services.
- Be Informed of the Existence of Processing of Personal Data
You have a right to be informed whether personal data pertaining to you shall be, are being or have been processed, including the existence of automated decision-making and profiling.
Upon presentation of a valid decision, you have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
You have the right to lodge a complaint before the National Privacy Commission.
PAYO DATA PROTECTION OFFICER
Address : 2232 Chino Roces Ave Makati, Manila Philippines
Telephone : 02-734-4831
You may also use the Contact Us facility on our website, which allows you to send us a message by email and/or by using a contact form.