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) 5318-5762 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.