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Privacy Policy

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Last updated: May 03, 2023

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Umpisa respects the privacy and confidentiality of your personal data and is committed to complying with the Data Privacy Act of 2012 (“DPA”) and its Implementing Rules and Regulations. We value data privacy rights and exert reasonable efforts to make sure that all personal data collected from our customers, vendors, partners, employees, associates, and other stakeholders are processed in accordance with the general principles of transparency, legitimate purpose, and proportionality.

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This Privacy Policy, hereafter referred to as “Policy”, explains how we collect, protect, use, and manage your personal data.

 

As used in this Policy, “personal data” includes personal information, sensitive personal information, and privileged information as these terms are defined under the DPA. To avoid doubt, personal information refers to information that can be used on its own or with other information to identify, contact, or locate an individual in context.

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PERSONAL DATA COLLECTED

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We collect personal data through various means and forms. Examples of personal data that we collect are as follows:

  • Personal data contained in property and other documents (e.g., contract to sell and deed of sale) that you submit to us. These personal include your name, gender, civil status, date of birth, address,  and proofs of identification;
  • Personal data provided to us in the course of our business relationship such as your telephone or mobile numbers, email address, associations due payment history, and bank account details

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Aside from the above, we also collect details about your visit and use of our website and digital platform, including but not limited to IP addresses, browsing behavior within and throughout our digital assets, and session lengths that are collected by our website analytics tools and cookies that we may place on your computer.

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HOW PERSONAL DATA ARE COLLECTED

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We may collect and store your personal data through the following:

  • Upon registration, maintenance, and use of our digital platforms, including this website;
  • When you avail of any of our services, promos, activities, and events;
  • When you interact with our property managers, operations, maintenance, and front desk personnel through this site, email, phone, or face-to-face meetings;
  • When you submit manual and online forms containing personal data, on this site and on our other digital assets;
  • When you provide personal data in relation to inquiries, requests, and complaints;
  • When you respond to surveys, promotions, and other marketing and sales initiatives;
  • When you submit personal data to us for any other reason.

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PERSONAL DATA OF THIRD PERSONS

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When you provide to us the personal data of another person (e.g., dependent, spouse, children, parents, and/or tenant), whether directly or through the documents that you submit to us, you warrant that you consent has been obtained from that person, (i) authorizing you to disclose and provide such personal data to us and (ii) authorizing  us to use, process, store, and share such personal data in accordance with this Policy. We reserve the right to require you to present proof of the abovementioned consent before, or at any time during the course of, our delivery of services to you.

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USE OF PERSONAL DATA

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GENERAL USES

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We use the personal data that you provide to us for the following purposes:

  • Providing you with services that you have requested;
  • Enhancing your customer experience by delivering services that match your needs and preferences;
  • Communication of relevant services, advisories, and responses to your queries, requests, and complaints;
  • Compliance with the requirements of the law and legal proceedings, such as court orders and legal obligations, prevention of imminent harm to the public, and ensuring public security, safety, and order;
  • Prevention, detection, and investigation of crime and analysis and management of other commercial risks;
  • Processing of personal data for statistical, analytical, and research purposes.

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OTHER USES, BY NATURE OF TRANSACTIONS

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Aside from the general uses mentioned above, we will use the personal data that you provided to us for the following purposes:

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UPON AVAILMENT OF THE UMPISA SERVICE

  • ‍‍Registering your inquiries and messages and addressing any follow-up calls;
  • Preparation of documentations, as may be requested;
  • Performing financial processes related to the service and other actions necessary in the implementation of our service;
  • Managing of unit and property activities;
  • Assessing of eligibility for certain rewards and programs, and informing you of products, services, events, promotions, and initiatives that may be of interest to you;
  • Providing you with personalized customer experience by maintaining your personal dashboard and by showing targeted advertisements that may match your preference and needs;
  • Communication of advisories and changes in relation to any services. You may unsubscribe from such notifications or offers by following the steps provided.

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UPON LEASE OF UNIT OR PROPERTIES LISTED IN THE UMPISA SYSTEM

  • Due diligence checks of sub-lessees for identification and verification;
  • Registering and documentation of unit or property lease;
  • Submission of lease documents or any other required documentations;
  • Financial transactions, such as the processing of rental payments, and other actions necessary in the implementation of the lease of your unit/property;
  • Communication of advisories and changes in relation to your lease contract.

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DISCLOSURE OF PERSONAL DATA

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BASED ON UMPISA SERVICES AND THE PURPOSE SET OUT IN THIS POLICY

  • Your personal data may be disclosed to the following parties:
  • Our employees and officers who need to know, or have access to, the personal data to perform their functions;
  • Professional advisers such as but not limited to lawyers and auditors;
  • Insurers and, upon your request, credit providers;
  • Upon your request, banks, credit card companies, and other financial institutions and their respective service providers;
  • Suppliers or subcontractors, third-party service providers, consultants that may have been contracted by  us to provide financial, technical, administrative, and support services;
  • At the moment, our sole payment service provider is PayPal, Inc. (PayPal). All personal and financial data that you enter on the PayPal browser are transmitted to PayPal and are not stored by us. For more information on PayPal’s privacy policy, you may visit https://www.paypal.com.ph/webapps/mpp/ua/privacy-full.
  • Members of our group of companies, our subsidiaries and affiliates, and our joint venture and alliance partners, with whom we have executed data sharing agreements.
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LEGAL AND STATUTORY COMPLIANCE

  • To the extent that we are required to do so by applicable laws, rules, and regulations;
  • In connection with any ongoing or prospective legal proceeding;
  • To the buyer or prospective buyer of our business, in the event of a contemplated sell;
  • To other users of our website, in case you decide to place advertisements containing any personal data;
  • To any person or entity, upon order of a court, regulatory body, or government agency of competent jurisdiction;
  • Any person or entity with which we share the personal data for the above purposes is contractually required to comply with confidentiality standards. to respect any individual’s right to privacy, and to comply with the Data Privacy Act. We also require that these organizations use the personal data only for purposes for which  they were shared and in the case of our service providers, follow our reasonable directions on the processing of the personal data.

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RETENTION AND DISPOSAL OF PERSONAL DATA

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All data that we collect are stored in the data centers of our hosting service provider, Google Cloud Platform. For more information on Google Cloud Platform’s privacy policy, you may visit https://cloud.google.com/security/privacy.

In accordance with the DPA, your personal data shall be retained to the extent:

  • That we are required to do so by law;
  • Necessary for us to deliver our services to you;
  • That these may be relevant to any ongoing or prospective legal proceedings in order to establish, exercise, and defend our legal rights (including providing personal data to others for the purposes of fraud prevention and reducing credit risk);
  • Required for legitimate business purposes.

Thereafter, the personal data shall be disposed of or discarded from our database so as to prevent further processing, unauthorized access, or disclosure by us to any other party or the public.

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UPDATING OF PERSONAL DATA

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You have the obligation to ensure that the personal data that you provide to us are updated, accurate, and complete.  If the personal data we hold about you needs to be corrected or updated, we will exert reasonable efforts to ensure that data collected is complete, current, updated, and accurate.

  • Necessary changes may be made via the Umpisa portal.
  • As part of our security measures, we will contact you to conduct the necessary verification measures to process your request. Once we have implemented the necessary adjustments, we will notify you that your request to update your personal data has been processed and completed.

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WITHDRAWAL OF CONSENT

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If you wish to withdraw the consent you’ve given for any or all purposes set out in this Policy, you may send your detailed request to your property manager via the in-app messaging service or through any other channel available to you. Depending on the nature of the withdrawal of consent, we may no longer be in a position to provide the necessary services to you.

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PERSONAL DATA PROTECTION

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PROTECTING PERSONAL DATA SUBMITTED ONLINE

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We take precautions to protect your personal data in our custody, both online and offline.

  • All our critical websites undergo security scanning and penetration testing to reduce their vulnerability to cyber attacks. While we employ all necessary precautions to safeguard your personal data, the internet is not 100% secure, so we cannot guarantee that the personal data that we collect or store will be protected from unauthorized access and used in a manner that is inconsistent with this Policy.

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MEASURES UNDERTAKEN TO PROTECT YOUR PERSONAL DATA

We maintain physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use, or modification. We also implement safeguards such as:

  • Limiting access to your personal data to those who are qualified and authorized to process them. All such persons, wherever they are located, are required to protect the confidentiality and privacy of your personal data in a manner consistent with this Policy.
  • Regular security vulnerability and penetration testing of our systems and infrastructure to ensure your personal data is properly protected.

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COOKIES

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A cookie is a small file which asks permission to be placed on your computer’s hard drive. If you allow the use of cookies, the file is added to your browser, helping us analyze and identify browsing behavior within our digital assets. Cookies allow web applications to respond to you as an individual. The web application can customize its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

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We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to properly respond to customer needs. We only use this for statistical analysis purposes, after which the data is removed from the system.

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Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

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You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies; however, doing so may prevent you from taking full advantage of the website.

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RIGHTS AS A DATA SUBJECT

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As a data subject, you have the following rights under the DPA. You may exercise these rights subject to the limits prescribed by the DPA and other relevant laws:

  • Be informed that your personal data will be, are being, or were collected and processed;
  • Have reasonable access to your personal data in our possession;
  • Object to the collection and processing of your personal data;
  • Dispute and correct any inaccuracies or errors in your personal data in our possession;
  • Suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our database or filing systems; and
  • Claim compensation if you suffered damages arising from our misconduct or gross negligence in handling your personal data.

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UPDATES TO THE POLICY

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As part of our efforts to safeguard and ensure the security and protection of your personal data, we may amend or change this Policy from time to time. We may also update this Policy to apply changes due to new laws and regulations affecting the DPA, as well as changes in our business operations and environment. You will be notified of any updates so that you are informed of the latest policy updates. You are deemed to have accepted the abovementioned amendments, changes, and updates if you continue to use our services after receipt of the notice of such abovementioned amendments, changes, and updates, as the case may be.