LRT Manila Office | LRT Manila Office | Light Rail Manila Corporation

The LRMC is a joint venture company of the MPLRC,, AC Infra, and the MIHPL dedicated to developing, operating, and maintaining the country's light rail transit lines.

The Light Rail Manila transit is a joint project of the private sector and the LRMC.

If you ever find yourself on one of the Philippines' LRT lines, don't forget that it was made possible with the LRMC.

LRT1 takes you to Caloocan to Baclaran and 15 other stations with just one easy ticket.

Zip around with metro, fast and easy with LRMC's light rail transit in Manila!

If you have any concerns about the running operations of the LRT, please head on over to their LRT Makati office.
Zip around the metro fast and easy with rail lines built for the commuting public by the Light Rail Manila Corporation!

Privacy Policy

PRIVACY AND DATA PROTECTION POLICY

We, at Light Rail Manila Corporation (“LRMC”), are committed to protecting and respecting your data privacy rights.

We are committed to ensuring that our privacy management practices comply with the Applicable Privacy Laws as well as with our contractual commitments in the conduct of our business. LRMC staff are thus required to respect the confidentiality of all Personal Data and the privacy of individuals. In furtherance of this mission, we have directed our staff that Personal Data must be dealt with in accordance with this Privacy Policy.

1.       Definitions

For purposes of this Privacy Policy, the following definitions shall apply:

Applicable Privacy Laws means Republic Act No. 10173, also known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, other relevant laws and issuances by the National Privacy Commission, and any other laws protecting the fundamental rights and freedoms of individuals, and in particular, their right to privacy with respect to the collection and processing of Personal Data, as well as foreign laws and issuances protecting the right of individuals to privacy, if applicable.

DPArefers to Republic Act No. 10173 or the Philippine “Data Privacy Act of 2012”.

Personal Information”, “Sensitive Personal Information”, “Personal Data”, “Data Subject”, “Processing”, “Personal Information Controller”, and “Personal Information Processor, shall have the same meaning provided in the Implementing Rules and Regulations of the DPA.

Personal Data Breach” refers to a breach of security that requires notification to the NPC under the DPA and its implementing rules and regulations, including the relevant NPC issuances.

NPCmeans the National Privacy Commission.

2.       Scope and Application

This Privacy Policy outlines our responsibilities, including our employees’ and personnel’s, concerning the protection of Personal Data entrusted to us by passengers, customers, employees, contractors, or other individuals with whom we have been in contact with, including those Personal Data that may have come to our possession in the conduct of our business.

Our application of this Privacy Policy is subject to the requirements of the Applicable Privacy Laws. All LRMC employees, contractors and agents with access to Personal Data are required to comply with this Privacy Policy.

This Privacy Policy, together with the Privacy Statements set out in the Appendices that form part of it, explain what types of Personal Data we might collect, how we use, process, store, retain and secure Personal Data, when we disclose Personal Data to others, how you can access and seek to correct your Personal Data that we hold, and how you may make a complaint if you think that we have breached the Applicable Privacy Laws.

Our Privacy Policy and the Privacy Statements are available on our website, http://lrmc.ph/privacy.

3.       Policy Statement

LRMC is committed to complying with the Applicable Privacy Laws. For this purpose, we adhere to the general principles of Transparency, Legitimate Purpose, and Proportionality.

Transparency

We will inform our Data Subjects of the nature, purpose, and extent of the processing of Personal Data. To comply with this duty, we undertake to provide Data Subjects with information on the collection and processing of their Personal Data, including the identity and contact details of persons collecting, holding, or processing such Personal Data, scope and method of processing, the recipient or classes of recipients of their Personal Data, and the basis of processing of Personal Data when Data Subjects have not provided consent.

4.       Legitimate Purpose

We will process Personal Data only in cases when it is compatible with the declared and specified purpose which is not contrary to law, public morals, or public policy.

Proportionality

We will process Personal Data only when it is relevant, necessary, and compatible with the declared and specified purposes for its collection made known to the Data Subjects. We will retain Personal Data only for as long as necessary for the fulfillment of these purposes.

5.       Protection of Personal Data

We are also committed to upholding the rights of Data Subjects, as described in Annex A of this Privacy Policy. In this regard, LRMC implements appropriate systems to fairly and lawfully manage all Personal Data in a way that ensures its integrity, accuracy, relevance, and security. LRMC also protects Personal Data from misuse, loss, unauthorized access, modification or disclosure.

We will not disclose any Personal Data to third parties, except when the Data Subject consents to or the law mandates or allows the disclosure.

6.       Responsibility for Privacy and Data Protection

LRMC employees are responsible for complying with this Privacy Policy and will only access and process Personal Data in accordance with this Privacy Policy and Applicable Privacy Laws.

Relevant LRMC employees are responsible for ensuring that employees within their supervision or the contractors that they manage are aware of this Privacy Policy and are adequately trained in the processing of Personal Data within their control.

7.       Privacy Officer

Our Privacy Officer is responsible for managing any issues with Personal Data collected by LRMC. You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph

All LRMC employees are your partners in reporting actual or suspected Personal Data breaches to our Privacy Officer.

8.       Complaints

For any complaint on our compliance with Applicable Privacy Laws, you may contact us through our Privacy Officer at dataprivacy@lrmc.com.ph. You also have the right to lodge a complaint before the NPC in accordance with their relevant rules of procedure.

This Privacy Policy and Statements were last reviewed on December 3, 2018.

PRIVACY STATEMENT FOR PASSENGERS

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Statement, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. These are all available in our website http://lrmc.ph/privacy.

This Privacy Statement in particular applies to passengers of LRT-Line 1. There may be other Privacy Statements that may apply to specific concerns of passengers such as our use of surveillance cameras or CCTVs or the personal information we collect if you avail of your Wi-Fi services. These Privacy Statements are available on our website.

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any personal information which identifies or can identify an individual. Personal information does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

We collect and maintain different types of personal information on LRT-Line 1 passengers, including personal information (such as names, contact numbers, e-mails, residence and business address, etc.) contained in:

  • applications for senior citizen and other special stored value cards;
  • customer complaint or feedback forms;
  • other customer service forms;
  • Wi-Fi log-in portals;
  • surveillance cameras (CCTV);
  • records and forms for passenger accidents and incidents (including where the passenger may be the victim of or is alleged to be the perpetrator of a crime);
  • forms for reported lost property;
  • waivers; and
  • application and other forms relating to the availment of promotions and discounts. These include forms for the purchase of single journey tickets or stored value cards with a senior citizens, person-with-disability (PWD), and other discounts.

We will always obtain your express consent when we process special categories of personal information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, or sexual orientation. Your express consent may not be obtained when not required by law or the information is required for your protection in cases of emergency.

If you avail of a discount for our single journey or stored value Beep cards and the basis for the discount is a status of condition that may be considered sensitive or a special category of personal information (for example, PWD, senior citizens, or a discount given to members of a community on account of the anniversary or some other special celebration of that community), your availment or purchase of the Beep card will be deemed consent for the processing of that information for the availment and administration of the discount.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services. For example, as the Beep cards are issued by AF Payments, Inc. (“AFPI”), the information we collect in the discounted card application form is shared with AFPI to allow them to produce and issue the card. You can view AFPI’s privacy policy by following the link, https://www.beeptopay.com/privacy-policy.html.

Where we use the services of third parties or receive personal information collected by third parties, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

When permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

5.         Why Do We Collect Personal Data?

We sometimes need to collect your personal information so that we can provide you with the full range of our services, operate LRT-Line 1 effectively and safely, and carry out our functions and responsibilities in our operating franchise and concession with the government. These uses include:

  • safety and security purposes;
  • replying to or addressing customer complaints;
  • administering or processing passenger injury or incident claims;
  • administering the availment of senior citizen discounts and other legal benefits;
  • administering promotions and special benefits;
  • administering the lost-and-found office;
  • administration and availment of Wi-Fi services;
  • the production of metadata that allows us to analyse trends in passenger and consumer behaviour and satisfaction with our services; and
  • such other purposes as are reasonably required by LRMC.

As a company operating a public utility, we may sometimes need to process your personal information to pursue our legitimate interests, like prevention or detection of crimes.

6.         How Do We Use Your Personal Data

We may use your personal information

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes which we will tell you about and only do so if we get your consent, when your consent is required by law.

We may use your personal information without your knowledge or consent only when we are permitted or required by law or regulations to do so.

If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with details of such purpose and any other relevant information.

7.         When Do We Disclose Your Personal Data?

We will disclose your personal information to third parties only if we are legally obliged to do so or in compliance with our duties to you.

Further, your personal information may be disclosed:

  • when necessary to protect LRMC’s rights and property;
  • when necessary to protect your safety or other person’s safety during emergency situations;
  • when the personal information is publicly available; or
  • with your consent, when such consent is required by law.
8.         Notification and Consent

Privacy laws do not generally require us to obtain your consent before collecting, using or disclosing your personal information.

In addition, we may collect, use or disclose your personal information without your knowledge or consent when we are permitted or required by law or regulations to do so.

Unless you advise us otherwise and to the extent that your consent is required, we will obtain your consent for the collection, use, and disclosure of your personal information for the purposes stated above and any other purposes stated or reasonably implied at the time such personal information was collected from you.

Where your consent was required for our collection, use, or disclosure of your personal information, you may at any time withdraw your consent, subject to legal or contractual restrictions and reasonable notice. All communications as to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

9.        How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

10.        How Long is Your Personal Data Retained?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected (e.g., meeting any legal, accounting or other reporting requirements or obligations). Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

11.        Updating Your Personal Data

It is important that your personal information found in our records is both accurate and up-to-date. If your personal information happens to change, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

12.        Access to and Rectification of Your Personal Data

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

13.        Inquiries or Concerns?

If you have any questions about our Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

14.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
15.        Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

16.        Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

PRIVACY STATEMENT FOR EMPLOYEES

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Statement, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. These are all available in our website http://lrmc.ph/privacy.

This Privacy Statement in particular applies to all individuals who seek to be, are, or were, employed by LRMC (collectively, “employees”).

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any information which identifies or can identify an individual. Personal Data does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

We collect and maintain different types of personal information of our employees, including the personal information (such as names, contact numbers, e-mails, residence address, among others) contained in:

  • resumes, applications, and pre-employment checklists;
  • references and interview notes;
  • photographs, video, and surveillance cameras (CCTV);
  • employee ID cards;
  • background checks and authorizations;
  • letters of offer and acceptance of employment;
  • mandatory policy acknowledgement sign-off sheets;
  • information needed for payroll, benefits and expenses purposes;
  • forms for the request of tools and resources;
  • training and evaluation forms (including those for salary deduction authorizations);
  • wage and benefit information;
  • records of holiday, sickness, and other absence;
  • records related to your career history (such as training records, appraisals, and other performance measures);
  • disciplinary and grievance records;
  • meeting attendance sign-off sheets;
  • waivers for attendance in LRMC events;
  • exit interview forms;
  • correspondence with or about you (for example, letters to you about a pay rise or, at your request, a letter to your bank confirming your salary);
  • forms relating to the application for, or in respect of changes to, employee health, welfare and other benefits, including insurance, retirement benefits, car benefits, short and long term disability, medical and dental care, and availment of rail dependency passes; and
  • beneficiary and emergency contact information.

Necessarily, you will be referred to in many of LRMC’s documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of LRMC.

We may keep information relating to your health, which could include reasons for your absence and clinical reports and notes. This information will be used to comply with our health and safety and occupational health obligations. These obligations include considering how your health affects your ability to do your job and making appropriate adjustments to your job, if necessary. We will also need this personal information to administer and manage statutory and company sick pay, health insurance, or life insurance policies.

We will always obtain your express consent when we process special categories of personal information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, union membership, or sexual orientation. Your express consent may not be obtained when not required by law or the information is required for your protection in cases of emergency.

As a general rule, LRMC collects personal information directly from you. Some personal information, however, may come from other sources within LRMC, such as your manager; or in some cases, from sources outside LRMC, such as referees. In most cases where the personal information that we collect about you is held by a third party, we will obtain your consent before we seek out this information from such sources. Such consent may be given directly by you, or implied from your actions.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

When permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

5.         Why Do We Collect Personal Data?

As your employer, we need to keep and process your personal information for employment purposes. Personal information we hold and process will be used for management and administrative uses only. We will keep and use it to enable us to run our business and to lawfully and appropriately establish, manage, or terminate your employment relationship, during your recruitment, while you are working for us, at the time when your employment ends and after you have left. These uses include:

  • • determining eligibility for initial employment, including the verification of references and qualifications, and investigation of all data given in the employment application form and the employment contract itself;
  • administering pay and benefits (including employee requests for salary deductions);
  • processing employee work-related claims (g., worker compensation, insurance claims, and the like)
  • establishing training and/or development requirements;
  • conducting performance reviews and determining performance requirements;
  • assessing qualifications for a particular job or task;
  • gathering evidence for disciplinary action or termination;
  • establishing a contact point in the event of an emergency (such as next of kin);
  • complying with applicable labor or employment laws;
  • ensuring health and safety in the workplace;
  • compiling directories;
  • ensuring the security of company-held information; and
  • such other purposes as are reasonably required by LRMC.

As a company operating a public utility, we may sometimes need to process your personal information to pursue our legitimate interests, like prevention or detection of crimes.

6.         Monitoring

Your work output, as LRMC employee, whether in print, computer file, or any other storage format, belongs to LRMC, and such work output and the tools used to generate such work output, are subject to review and monitoring by LRMC at all times.

In the course of conducting our business, we may monitor your activities including our premises and properties. To illustrate, some of our locations — in and around the Depot, passenger stations, treasury rooms, and ticket booths — are equipped with surveillance cameras. These cameras are generally located in high risk areas. When in use, surveillance cameras are installed for the protection of employees, customers, and third parties, and against theft, vandalism of, and damage to LRMC’s goods and property.

Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to the police or other appropriate government agency or authority. Recorded images may also be used by LRMC in gathering evidence for disciplinary action, or termination, of any employee. Please read our Privacy Statement of CCTVs for more information.

Pursuant to our policies on acceptable computer and mobile phone use available on the intranet, we have the capability to monitor all your computer and e-mail use. Please read LRMC’s internet, e-mail and computer usage policies for more information.

We also keep records of your hours of work by way of our clocking on and off system.

This section, however, is not meant to suggest that all your actions will be subject to constant surveillance. This merely seeks to bring to your attention that such monitoring may occur and may result in the collection of your personal information (e.g., through the use of LRMC resources). When using LRMC equipment or resources, you do not have any expectation of privacy with respect to the use of such equipment or resources.

7.         How Do We Use Your Personal Data?

We may use your personal information

  • for the purposes described in this Privacy Statement; or
  • for any additional purposes which we will tell you about and only do so if we get your consent, when your consent is required by law.

We may use your personal information without your knowledge or consent only when we are permitted or required by law or regulations to do so.

If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with details of such purpose and any other relevant information.

8.         When Do We Disclose Your Personal Data?

We will disclose your personal information to third parties only if we are legally obliged to do so or in compliance with our duties to you. For instance, we may need to pass on some of your personal information to our external payroll provider, pension or health insurance schemes.

Further, your personal information may be disclosed:

  • when necessary to protect LRMC’s rights and property;
  • when necessary to protect your safety or other person’s safety during emergency situations;
  • when the personal information is publicly available; or
  • with your consent, when such consent is required by law.
9.         Notification and Consent

Privacy laws do not generally require us to obtain your consent before collecting, using, or disclosing your personal information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent, when we are permitted or required by law or regulations to do so.

Unless you advise us otherwise and to the extent that your consent is required, we will obtain your consent for the collection, use, and disclosure of your personal information for the purposes stated above and any other purposes stated or reasonably implied at the time such personal information was collected from you.

Where your consent was required for our collection, use, or disclosure of your personal information, you may at any time withdraw your consent, subject to legal or contractual restrictions and reasonable notice. All communications as to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

10.         How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

11.         How Long is Your Personal Data Retained?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected (e.g., meeting any legal, accounting or other reporting requirements or obligations). Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

Our Human Resources Department normally retains employee records for five years from the termination of your employment with LRMC; while information pertaining to your health are retained for ten years after employment. Our Finance Department also keeps records for ten years. Surveillance camera footages are kept for 90 days, after which it is erased, unless there is an ongoing investigation needing the footage.

12.         Updating Your Personal Data

It is important that your personal information found in our records is both accurate and up-to-date. If any of your personal information happens to change during the course of your employment with us, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

13.         Access to and Rectification of Your Personal Data

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

14.         Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

15.         Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
16.        Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

17.        Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

PRIVACY STATEMENT FOR SUPPLIERS AND CONTRACTORS

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. These are all available in our website http://lrmc.ph/privacy.

This Privacy Statement applies to you as a contractor and supplier of LRMC, including your owners, directors, partners, employees or any other individuals who may interact with LRMC.

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any information which identifies or can identify an individual. Personal Data does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

We collect and maintain different types of personal information in respect of our contractors and suppliers, including the personal information (such as names, contact numbers, e-mails, business address, etc.) contained in:

  • materials you provide us when you market or offer to supply us with certain products or services;
  • documents submitted to bid for goods and services (including proposals and curriculum vitae submitted as part of the bid or tender process);
  • registration forms filled out at the time you become a registered/accredited contractor or supplier of LRMC, including registering as a supplier or contractor;
  • work permit or delivery permit application forms and other applications with LRMC to enable you to perform the services and/or supply the goods to LRMC;
  • contracts, invoices, policies and other correspondences sent to LRMC;
  • e-mails sent to LRMC, business cards or information given during telephone calls or face to face discussions; and
  • security guard log books when you visit LRMC’s offices or surveillance cameras (CCTV).

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services (e.g., your details are passed on by other parties within the industry or clients as a potential supplier or contractor). Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect and process information about you without your knowledge or consent.

5.         Why Do We Collect Personal Data?

We sometimes need to collect your personal information so that we can establish, manage, administer and facilitate the provision of products and/or services by or to you LRMC. These uses include:

  • contacting you about potential supply or service agreements with you;
  • responding to any inquiries or feedback received from you;
  • performing our obligations to you under supply or service contracts, including processing of payments to you
  • taking legal or administrative action in relation to our supply or service contracts, including enforcing the terms of such contract or resolving any disputes;
  • undertaking financial management, planning and reporting within LRMC;
  • undertaking health and safety activities and checks;
  • keeping in touch with you for any future business opportunities; and
  • such other purposes as are reasonably required by LRMC.

As a company operating a public utility, we may sometimes need to process your personal information to pursue our legitimate interests, like protection of health, security or safety of individuals.

6.         How Do We Use Your Personal Data

We may use your personal information:

  • for the purposes described in this Privacy Statement; or
  • for any additional purposes which we will tell you about and only do so if we get your consent, when your consent is required by law.

We may use your personal information without your knowledge or consent only when we are permitted or required by law or regulations to do so.

If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with details of such purpose and any other relevant information.

7.         When Do We Disclose Your Personal Data?

We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our obligations to you. For instance, we may need to pass on certain information to our banks and other payment processing service providers who process our payments to you, our external consultants such as accountants, auditors, legal advisers and insurance brokers, and any technology service providers, including internet service providers, software suppliers, maintenance and support service providers.

Further, your personal information may be disclosed:

  • when necessary to protect LRMC’s rights and property;
  • when necessary to protect your safety or other person’s safety during emergency situations;
  • when the personal information is publicly available; or
  • with your consent, when such consent is required by law.
8.         Notification and Consent

Privacy laws do not generally require us to obtain your consent before collecting, using, or disclosing your personal information. In addition, we may collect, use or disclose your personal information without your knowledge or consent, when we are permitted or required by law or regulations to do so.

Unless you advise us otherwise and to the extent that your consent is required, we will obtain your consent for the collection, use, and disclosure of your personal information for the purposes stated above and any other purposes stated or reasonably implied at the time such personal information was collected from you.

Where your consent was required for our collection, use, or disclosure of your personal information, you may at any time withdraw your consent, subject to legal or contractual restrictions and reasonable notice. All communications as to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

9.        How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure

10.        How Long is Your Personal Data Retained?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected (e.g., meeting any legal, accounting or other reporting requirements or obligations). Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

Our Finance Department keeps records for ten years. Surveillance camera footage is kept for 90 days, after which it is erased, unless an investigation needing the footage is ongoing.

11.        Updating Your Personal Data

It is important that your personal information found in our records is both accurate and up-to-date. If any of your personal information happens to change during the course of your dealings with LRMC, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

12.         Access to and Rectification of Your Personal Data

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

13.         Inquiries or Concerns?

If you have any questions about this Privacy Statement or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

14.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
15.        Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

16.         Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

PRIVACY STATEMENT ON CCTV SYSTEM

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we use personal data collected via Closed Circuit Television (CCTV) camera systems in LRT Line-1.

1.         Camera Systems We Operate

Our CCTV system is used to capture and monitor images of events that take place in specific locations in real time. The images may also be recorded on a computer hard drive or magnetic tape depending on the type of camera. Cameras may be focused on a fixed location, set to scan a particular area, or operated remotely by specially trained operators.

2.         Why We Operate Cameras?

Under the Republic Act No. 10173 or the Data Privacy Act of 2012 (“DPA”), we are only allowed to use personal information if we have a “legitimate purpose” to do so. In the case of CCTV cameras, our concession agreement with the government requires us to have a CCTV camera system installed within the premises of LRT Line-1. We operate CCTV cameras to perform tasks in support of our operating franchise and this concession agreement – namely, the delivery of safe and efficient transport services through LRT Line-1.

We operate CCTV cameras for the following purposes:

  • To maintain the safety and security of our passengers, colleagues and stakeholders, members of the public, national security, detection and prevention of crime and transportation security;
  • To monitor passenger flow and demand throughout LRT Line-1 to maximize resources and optimize the passenger experience;
  • To support the effective management of LRT Line-1 operations and any incidents;
  • For investigative purposes or as evidence to support any investigation of incidents or formal follow-ups to such incidents;
  • To provide the Department of Transportation (“DOTr”) and Light Rail Transit Authority (“LRTA”) with evidence of our compliance with operating franchise and concession obligations; and
  • To enforce train operating and passenger management rules.
3.         Where are the CCTV Cameras Located?

We have CCTV cameras in and around LRT Line-1 passenger stations, depots, office buildings and areas (including station teller booths and treasury and safety deposit rooms), and power substations. We may eventually have CCTV cameras in trains.

4.         How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards to control access to, and use of, personal data associated with our CCTV systems. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

CCTV footages are retained in a secure environment and are only accessible to authorized personnel who have a legitimate reason to do so.

5.         When Do We Disclose Your Personal Data?

CCTV footage and imagery may be handled and used by the following recipients to maintain safe, secure, and efficient LRT Line-1 operations:

  • LRMC personnel;
  • police and other law enforcement agencies;
  • DOTr and LRTA representatives;
  • our retained security agency; and
  • other LRT-1 service providers.

On a case by case basis we may use and share CCTV images for research and analysis purposes. For example, these may be used to improve the management of health and safety incidents, or travel demand management.

In some circumstances, other disclosures of personal data (including CCTV images) to the police and other law enforcement agencies are permitted by law, if they relate to the prevention or detection of crime and/or the apprehension or prosecution of offenders. Before any such disclosure takes place, the police are required to demonstrate that the personal data concerned will assist them in this respect. Each police request addressed to us is dealt with on a strictly case-by-case basis to ensure that any such disclosure is lawful.

6.         How Long is Your Personal Data Retained?a

CCTV footages are kept for 90 days, after which it is erased. Footage required as evidence or in investigations may be retained for more than 90 calendar days and will be securely disposed upon completion and conclusion of the purpose for which it has been retained.

7.         What are Your Rights over Your Personal Data?

You may request copies of images or footage of yourself by making a request for such access. Please note that in most cases, CCTV footage is kept for a limited time, and any request should be made immediately.

In making your request, you will need to provide as much information as possible about when and where the images were captured (i.e., the specific date, time, and location). Along with your request, you will also need to submit a clear full length photograph of yourself so that we can identify you when searching for the relevant images.

When requesting access to CCTV footage, we may charge you a fee which you will be advised in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information or CCTV footage requested. In addition, CCTV footage may have been erased in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

8.         Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

9.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
10.        Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

11.         Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

 

WEBSITE AND SOCIAL MEDIA SITE PRIVACY STATEMENT

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. This Privacy Statement applies to persons who use any of our websites or social media sites.

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any information which identifies or can identify an individual. Personal Data does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

We collect and maintain different types of personal information (such as names, contact numbers, e-mails, business address, etc.) when you electronically submit to us your feedback, inquiries, requests or report an incident through our website or social media sites.

We will always obtain your express consent if we process special categories of personal information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, union membership, or sexual orientation. Your express consent may not be obtained when not required by law or the information is required for your protection in cases of emergency.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect and process information about you without your knowledge or consent.

5.         Why Do We Collect Personal Data?

We sometimes need to collect your personal information so that we can provide you with the full range of our services, operate LRT-Line 1 effectively and safely, and carry out our functions and responsibilities in our operating franchise and concession with the government. These uses include:

  • processing, documenting, and acting on requests, inquiries, complaints and incident reports to improve the quality of our service and your passenger experience;
  • safety and security purposes;
  • monitor website or social media site activity; and
  • such other purposes as are reasonably required by LRMC.

As a company operating a public utility, we may sometimes need to process your personal information to pursue our legitimate interests, like protection of health, security or safety of individuals.

6.         How Do We Use Your Personal Data

We may use your personal information

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes which we will tell you about and only do so if we get your consent, when your consent is required by law.

We may use your personal information without your knowledge or consent only when we are permitted or required by law or regulations to do so.

If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with details of such purpose and any other relevant information.

7.         When Do We Disclose Your Personal Data?

We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our obligations to you. For instance, we may need to pass on certain information to any technology service providers, including internet service providers, software suppliers, maintenance and support service providers.

Further, your personal information may be disclosed:

  • when necessary to protect LRMC’s rights and property;
  • when necessary to protect your safety or other person’s safety during emergency situations;
  • when the personal information is publicly available; or
  • with your consent, when such consent is required by law.
8.         Notification and Consent

Privacy laws do not generally require us to obtain your consent before collecting, using, or disclosing your personal information. In addition, we may collect, use or disclose your personal information without your knowledge or consent, when we are permitted or required by law or regulations to do so.

Unless you advise us otherwise and to the extent that your consent is required, we will obtain your consent for the collection, use, and disclosure of your personal information for the purposes stated above and any other purposes stated or reasonably implied at the time such personal information was collected from you.

Where your consent was required for our collection, use, or disclosure of your personal information, you may at any time withdraw your consent, subject to legal or contractual restrictions and reasonable notice. All communications as to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

9.         How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The internet, however, is not generally a secure medium of communication and we cannot guarantee the security of any information you input on our websites or social media sites.

10.         How Long is Your Personal Data Retained?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected.

Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

11.         Updating Your Personal Data

It is important that your personal information found in our records is both accurate and up-to-date. If any of your personal information happens to change during the course of your dealings with LRMC, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

12.         Access to and Rectification of Your Personal Data

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

13.         Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

14.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
15.         Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

16.        Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

PRIVACY STATEMENT ON WI-FI ACCESS

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy and series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. This Privacy Policy applies to persons who access our free or paid Wi-Fi service.

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any information which identifies or can identify an individual. Personal Data does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

Personal information (such your name, birthday and gender) is collected when you access our free or paid Wi-Fi service.

5.         How Do We Collect and Use Your Personal Data?

Personal information provided through accessing our Wi-Fi services is collected and processed by Phar Philippines, Inc., our ancillary revenue partner.

Your personal information may be used for the following purposes:

  • advertising and marketing purposes, including targeted advertising based on the information you provide;
  • profiling your usage and viewing;
  • personalizing your experience of the services based on your usage and viewing profile; and
  • improving and developing our services.

We may use your personal information to contact you with information about our products and services, special offers and rewards, as well as those of selected third parties. From time to time, we may contact you by mail, telephone, email, other electronic messaging services (such as text, voice, sound or image messages including using automated calling systems) or fax for these purposes.

We may share with third parties information about your use of the services in an aggregated form which will not personally identify you. This aggregated data may be used by those third parties for their marketing purposes (e.g., to improve their targeting of advertising based on user preferences).

6.         How is Your Personal Data Protected?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The internet, however, is not generally a secure medium of communication and we cannot guarantee the security of any information you input on the Wi-Fi portal.

7.         How Long is Your Personal Information Retained?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected.

Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

8.         Access to and Rectification of Your Personal Data

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

9.         Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

10.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
11.         Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

12.         Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

PRIVACY STATEMENT FOR GAME CONTESTANTS AND EVENT PARTICIPANTSS

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we ensure that your data privacy rights are respected and protected.

1.         Application

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. This Privacy Policy in particular applies to people who participate in events, contests or games organized by LRMC.

2.         Policy of Compliance

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         What is Personal Data?

Personal Data includes any personal information which identifies or can identify an individual. Personal information does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         What Personal Data Do We Collect?

From time to time, we may organize contests, games or events in which LRMC employees, LRT-1 passengers, and other individuals may participate. For you to join and for us to administer such events or contests, we may ask and collect from you different types of personal information (such as names, contact numbers, e-mails, residence and business address, and the like).

5.         Why Do We Collect Personal Data?

The personal information will be collected and used by us only in connection with the administration of the contest or event.

6.         How Long is Your Personal Data Retained?

Except as otherwise permitted or required by law or regulations, we only maintain personal information obtained in connection with events or contests for a period of up to six months.

Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

7.         Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

8.        Privacy Officer

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address: Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number: (02) 318-5762 loc. 5726
Email address: dataprivacy@lrmc.com.ph
9.         Revisions to this Privacy Policy

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

10.         Interpretation of this Privacy Policy

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.

ANNEX A: DATA PRIVACY RIGHTS OF DATA SUBJECTS

Under the DPA, you, as Data Subjects, have the right to be informed of your data privacy rights, including:

RIGHT TO BE INFORMED

You have the right to be informed of the reason and purpose why LRMC collects or uses your personal information.

Specifically, as Data Subjects, you are to be informed of (i) the fact that your information is being collected and will be processed; (ii) the information being collected and processed; (iii) the purpose for such collection and processing; (iv) if you have not given your consent, the basis for such collecting and processing; (v) the intended recipients of your personal information; (vi) the scope and method of processing your personal data and the methods for automated processing, if any; (vii) the identity and contact details of any person or entity who will process your personal information; (viii) the period during which the personal information will be retained; and (ix) your rights as set out in this Annex A.

RIGHT TO OBJECT

You have the right to refuse to the collection and processing of your personal information, including the processing of your personal information for direct marketing, automated processing, or profiling.

You also have the right to be informed and to object to further processing of your personal information in case of any change in the purpose, basis, scope, and method of processing of your personal information. In case you object, further processing of your personal information must cease and will no longer be allowed, except for certain instances provided under Applicable Privacy Laws.

RIGHT TO ACCESS

Upon request in writing, you have the right to reasonable access to your personal information subject of processing, the sources of such personal information, how your personal information is being processed, the identity of the recipients of your personal information, and the purposes for granting access to such recipients.

In addition, you have the right to be informed of the date when your personal data was last accessed or modified and the designation, identity, and address of the controller of such information, if other than LRMC.

RIGHT TO RECTIFICATION

You have the right to reasonably request us to correct any inaccuracy or error in your personal information. After the correction has been made, we shall inform the recipient, if any, of your personal information of any such inaccuracy and the subsequent rectification made.

RIGHT TO ERASURE OR BLOCKING

You may request LRMC to suspend, withdraw, or order the blocking, removal, or destruction of your personal information from its filing system (i) in case you withdraw your consent or object to the processing of your personal information, and there is no other legal ground or overriding legitimate interest for the processing of your personal information, or (ii) when there is substantial proof that personal data is incomplete, outdated, false, or has been unlawfully obtained.

LRMC will notify those who have previously received the processed personal information.

RIGHT TO DAMAGES

You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal information.

RIGHT TO DATA PORTABILITY

In case personal information was processed through electronic means and in a structured format, you have the right to obtain a copy of your personal data in such electronic or structured format. This right is subject to the guidelines of the NPC.

TRANSMISSIBILITY OF RIGHTS

Your lawful heirs and assigns may invoke your rights as a data subject in case of your death, incapacity, or incapability.

RIGHT TO LODGE COMPLAINT

You also have the right to lodge a complaint before the NPC in accordance with its relevant rules of procedure.