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.

“DPA” refers 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.

“NPC” means 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, https://lrmc.com.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) 5318-5762 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.