This serves as Clark Electric’s notice to all data subjects of its privacy procedures and practices which it ensures to be consistent with the data privacy principles of transparency, legitimate purpose and proportionality under the Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations. Clark Electric is committed to ensuring that data subject’s personal data is protected from collection to disposal. In this Policy, the term “We” or “Us” refers to Clark Electric, which is the Personal Information Controller (PIC) with respect to the personal data specified as follows.
WHAT WE COLLECT
We collect your personal data in the course of, or incidental to the conduct of, our business with you. These data include any other information you voluntarily provide for any legitimate purpose declared at point of collection as well as those we collect from publicly available sources, and from third parties and from other sources where the disclosure was subject of a separate consent or was otherwise lawfully permitted. The following are examples of these personal data.
From prospective and existing customers, including customers with terminated services:
- Information you provide to us when you apply for service, such as your name, address, phone number, email address, Tax Identification Number (TIN), evidence of authority to occupy (e.g., contract of lease, Board Resolution, Undertaking / Authorization from owner of the premises) and, if applicable, details of your authorized representative;
- Information you provide in relation to the conduct of our business such as regarding retail electricity supply or embedded generation;
- Billing and payment information used to process payment for your electric consumption and other liabilities, such as your banking information;
- Information to determine eligibility to participate in certain energy programs or services (e.g., net metering);
- Information you provide us when you visit or use our website or other communication channels, such as when you wish to contact us to lodge your concerns, to avail of our online application, outage notifications, and billing services, including information generated through such activities;
- Information you give us when you communicate with Clark Electric and/or any of our representatives (e.g., CRS Representatives, Relationship Managers, etc.), such as with respect to inquiries and complaint details on the quality and reliability of electric service;
- Responses you or your representative provide when you participate in our customer surveys;
- Information you provide for verification purposes (e.g., to facilitate refunds), such as photocopy of a valid / government-issued identification card.
From prospective, active and separated employees, as well as on-the-job trainees:
- Information you submit when you apply at CEDC for work or training, including what is contained in your resume or curriculum vitae and application form (e.g., work references);
- Information we collect during the processing of your application, such as testing results, employment offer, results of character investigation, and pre-employment medical assessment;
- Information we collect and maintain during your employment, such as your personal information, addresses, education records, professional licenses and permits; payroll information, including but not limited to government mandated and third party remittances like SSS, PhilHealth, and Pag-IBIG membership and contributions, taxes, bank account information; wages; entitlements and benefits; medical and dental care records; emergency contact information; training and certifications; performance evaluation; sanctions; and employment changes / work history;
- Information you provide about your dependents/beneficiaries for purposes of but not limited to administration of health maintenance plan, insurance claims, or profiling;
- Information we retain after your separation from service, such as but not limited to retirement benefits, bank account information, addresses, beneficiaries, and emergency contact information.
From vendors, suppliers or contractors, and consultants:
- Information you submit to CEDC in your application for accreditation, use of supply chain application system, and/or processing of payments, such as your name, tax identification number, address, contact details, educational attainment, work experience and banking information;
- Information we collect and maintain about you and your employees in relation to the preparation, execution, or fulfillment of your contract with us;
- Information that your employees submit to have access to, or perform your services or deliver your products within, the premises of the Company.
- Information you submit to us when you become a shareholder of or while being a shareholder of Clark Electric like your name, address, contact details, marital status, government issued identification, and if applicable, details of your authorized representative and heir/s;
- Information provided to us by your broker or by the Company’s stock transfer officer.
- Information we collect when you enter our premises such as your name, address, vehicle type and plate number or conduction sticker number, and identification card details;
- Information captured by our close circuit television (CCTV) installed in our premises including entrance and exit points.
From other pertinent third-parties:
- Information we collect from third parties by virtue of a legal claim or demand, such as claims filed by or against third parties, claims in relation to damage to company property;
- Information we collect from third parties in connection with our services, programs and events such as Corporate Social Responsibility Programs and other company events;
- Information provided to us by government agencies, regulators or public officers and employees in the performance of their lawfully mandated duties;
- In general, information collected or provided relating to our business, including those intended for market research and data analytics.
WHAT WE DO WITH THE INFORMATION WE GATHER
We store, process, and/or analyze the personal data collected for some legitimate purpose, related or incidental to the conduct of our business, including maintaining safety and security within the Company premises. Specifically, we may store, process, and/or analyze your personal data for the following and any other legitimate purposes:
For our customers:
To perform our contractual and legal obligations to you.
We process your personal data to evaluate your eligibility for electric and other related services, to provide you quality, reliable and regular supply of electricity, to continuously improve our business and operations as well as our products and services;
To enchance your customer experience.
We process your personal data to respond to your inquiry, concern, or complaint; to provide you information about our programs, service offerings, and any other programs or promos that may be of interest to you; to send you messages related to your services including outage notifications, updates, alerts, and other information that you request; to understand your needs and preferences by analyzing your use of our products and services, your participation in our surveys and research activities, and your browsing behavior in our mobile applications and websites, so we can serve you better.
To manage your account with us.
We process your data to administer and update your customer data, to compute your electric consumption and facilitate your payment or claims, including acceptance of bill payments according to your enrolled payment mode (e.g., automatic debit from your bank account), and to verify your identity when you access your account through the various customer engagement channels (e.g., e-mail, website, mobile application, via phone call, walk-in) and/or your eligibility to our programs, or entitlement to refunds and other claims.
For our applicants, active andseparated employees, as well as on-the-job-trainees:
To handle your application for employment or training.
We process your personal data to evaluate your eligibility for employment or training, including the verification of your qualifications, employment history, and character references (background checking);
To manage our employer-employee or training relationship.
We process your data to maintain your employment, on-the-job training and/or personal records, including your contact information, for operational or administrative efficiency. Specifically for employees, we collect, store, and process your data to administer your pay, statutory and salary deductions, entitlements, and benefits, and those of your dependents or beneficiaries, to conduct your performance reviews and grant rewards, to establish appropriate training and/or developmental interventions including your membership with professional or industry organizations, to monitor your work performance and use of company resources, and to conduct internal investigation and/or administer disciplinary action and sanction as necessary.
To address or enforce legal claims or obligations arising from employment contract or training relationship.
We process your data to comply with applicable statutory and regulatory requirements and submissions, including the processing of your work or labor-related claims (e.g. worker compensation, insurance claims, etc.). Your personal data may also be processed to enforce our claims or defend our rights in any proceeding arising from our relationship.
To maintain our post-employment relationship.
We process your data to administer your retirement benefits.
For our vendors, suppliers or contractors, and consultants:
To establish our business relationship or consultancy engagement.
We process your personal data to evaluate your application for accreditation or as basis for our engagement.
To conduct business with you.
We process your data to enforce our legal and contractual obligations including evaluating or auditing the provision of goods and/or services you provide, and facilitating the payment of your invoices in various payment methods (i.e., Fund Transfer, Corporate Check, Outsourced Check); informing you of our requirements, programs, or advisories; and responding to your questions, comments, and feedback by letter, e-mail, telephone, or other media for internal administrative purposes, such as auditing, data analysis, and database records management. Your data may also be processed to comply with statutory, legal, and regulatory requirements related to our business.
To maintain your account with us.
We maintain and update your vendor account information and establish details of your authorized contact persons for the goods and/or services you provide.
For our shareholders:
To manage investor relations.
We process your personal data to maintain your account and our relationship, to administer the shareholder register, to facilitate payment of your dividend or any other amounts related to your shareholdings, to coordinate with your broker or our stock transfer officer for your concerns, and to comply with legal or disclosure requirements.
To improve our stakeholder engagement.
We process your data to facilitate communications with you, including responding to your queries and requests, sending notices of general meetings, annual reports, and shareholder circulars to you, registering shareholders at general meetings and shareholders’ events including without limitation to verification of your identity and/or your proxy.
For our visitors/guest entering our Company premises or using our facilities or resources:
To monitor and/or control your entrance to, or exit from, and activities within, our premises.
We process your personal data to facilitate your ingress to and egress from our premises, offices, and facilities, including your vehicles or materials, such as verification of your identity and recording the purpose of your visit. We also monitor your location and activities inside the company premises, including ingress and egress of equipment, vehicle, and materials;
To enforce safety and security measures and procedures.
This includes conducting investigations and imposing sanctions in case of violations of Company policies and security and safety procedures or commission of crimes.
For other pertinent third-parties:
- To file and/or prosecute a legal claim or defend the Company, its officers, employees, and representatives against a demand;
- To pursue a potential or existing transaction;
- To comply with our legal, regulatory, or contractual obligations;
- To assist public authorities in their government programs and initiatives;
- In general, to facilitate the performance of our services, provide you information about our products, services, or programs that may be of interest to you, implement our programs or events like Corporate Social Responsibility Programs and other company events, or conduct our business operations.
We restrict the disclosure and processing of your personal data to our employees, trainees, authorized representatives, consultants, contractors, business partners, and government entities, on a need-to-know basis to carry out their responsibilities in relation to the conduct of our business.
Employees, Authorized Representatives, Trainees, and Consultants
We ensure that our employees and trainees commit to observe the privacy policies of the Company. We require our Authorized Representatives and Consultants to sign a Non-Disclosure Agreement (NDA), to ensure that they process your data confidentially in a manner consistent with the purpose of their employment or engagement.
Consultants, Contractors, and Business Partners, including Auditors
We require our contractors, subsidiaries, and business partners, through a Data Processing Outsourcing and/or Non-Disclosure Agreement (NDA), to secure and keep your data confidential. We take your privacy seriously so punitive or legal action will be initiated in case of proven misdeed. Moreover, we do not allow our contractors, subsidiaries, and business partners to disclose or share your data to others, or to use it for their own purposes, without your consent.
Your information may also be disclosed to government entities pursuant to and in compliance with applicable laws and regulations, subpoena or court order.
Unless you provide specific consent or except in instances allowed under the DPA, we will not:
- Share your personal data with our business partners and other third parties for their own commercial purpose or benefit;
- Use your personal data to enable third-party targeted advertisements which are not related to our business.
In case data sharing is allowed, we shall ensure the protection of your data through appropriate Data Sharing Agreements and commit to give you prior notice to any such transfer and processing of your data.
We are committed to ensure the integrity, confidentiality, availability, and security of your information. We implement reasonable organizational, physical, and technical security measures in collecting, processing, transmitting, storing, and disposing your personal data such as using secure servers, firewalls and security controls and ensuring regular conduct of audit and testing of our security protocols.
LINKS TO OTHER WEBSITES
PERSONAL DATA RETENTION AND DISPOSAL
We keep your personal data only for as long as necessary:
- for the fulfillment of the declared, specified, and legitimate purposes provided above, or when the processing relevant to the purpose has been completed or terminated;
- for the establishment, exercise, or defense of legal claims; or
- for other business purposes, that are consistent with standards established or approved by regulatory agencies governing CEDC.
Thereafter, your personal data shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.
CONTROLLING YOUR PERSONAL INFORMATION
You may request for a copy of your personal information in our possession, or have it corrected if you believe that it is inaccurate or incomplete.
If you wish to request for a copy of your personal data, or have it corrected or deleted, or to exercise your rights as data subjects, please reach out to us through the following contact information:
Email address: email@example.com
Tel. No.: 045 599 7091
Office: N2830 Bayanihan St., Clark Freeport Zone, Philippines
Please contact us through:
Atty. Francis Euston R. Acero
Data Protection Officer
Tel. No.: 045 599 3146
Office: N2830 Bayanihan St., Clark Freeport Zone, Philippines
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