Frontier Tower Associates Philippines (the “Company”) is committed to protecting your right to privacy. In accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (“DPA”), the Company deems it essential to inform you, as the Data Subject, of how your personal data is collected, used, stored, processed, shared, safeguarded, and ultimately disposed of, as well as the entities with whom your personal data may be shared.
This Privacy Notice provides an overview of our data privacy practices:
Collection of Personal Data
The Company collects personal data through manual and automated means, which may include, but are not limited to, the following interactions:
When you visit or transact at any office, building, premises, or use the facilities owned or leased by the Company;
When you transact with employees or authorized representatives of the Company;
When you access the Company’s websites or applications (e.g., Vendor Portal);
When you submit application forms related to Company transactions;
When you file complaints, inquiries, or engage in any similar transactions.
Types of Personal Data Collected
Your name, contact information, identification details, email addresses, files and data uploaded to shared office folders, necessary information about family members, and cellphone numbers;
Audiovisual data such as video, images, and sound recordings obtained through surveillance systems including Closed-Circuit Television (CCTV) when entering premises owned or controlled by the Company, subject to applicable legal limitations;
Other relevant information arising from your engagement with the Company as an employee, third-party contractor, or subcontractor.
Sensitive Personal Information, where applicable, such as health information, government-issued identification numbers, or biometric data, only when required by law or for specific employment or contractual purposes.
Purpose of Collection
Personal data is necessary to manage employee records, payroll, benefits, contracts with clients, vendors, or contractors.
Data like video footage from CCTV or access logs help maintain safety and prevent unauthorized access to company premises.
Certain laws require companies to collect and retain personal data, such as for employment records and tax purposes.
To fulfill contractual obligations or process transactions requested by the data subject.
To comply with legal obligations and regulatory requirements.
For the Company’s legitimate interests, such as enhancing operational efficiency, monitoring compliance, and improving services, provided such interests do not override your fundamental rights and freedoms.
Data Collection and Protection Measures
The Company obtains your consent prior to the collection and processing of any personal information, except where such collection and processing are permitted or required by applicable laws;
The Company employs strict security measures and restricts access to personal data only to authorized personnel and employees;
Personal data is collected solely for specific, legitimate purposes and is not processed beyond those purposes.
Data Sharing and Recipients
The company may share your personal data with the following, when necessary and under appropriate safeguards:
Service providers or third-party vendors that support our operations, including payroll processors, IT service providers, auditors, and consultants;
Government agencies, regulatory bodies, or courts of law when required by applicable laws, rules, or legal orders;
Affiliates or parent companies, in connection with corporate policies or organizational purposes.
Individuals have rights such as:
Right to be informed – Know how your data is collected and processed.
Right to access – Request access to your personal data.
Right to Object – Refuse processing based on specific grounds
Right to Rectify – Correct inaccurate or outdated data.
Right to data portability – Obtain a copy of your data in a usable format
Right to have data erased or blocked – Request deletion or blocking of your data.
Right to Damages – Seek compensation for misuse of your data.
Right to File a Complaint – File complaints with the National Privacy Commission for any data privacy violations.
You can access, correct, delete, or object to the processing of your personal data. You can also file a complaint with the National Privacy Commission.
Data Retention Schedule and Data Disposal Procedures
The Company retains personal data only for as long as necessary and proportionate to fulfill the specific, legitimate purposes for which it was collected, or as required by the Data Privacy Act of 2012 and other applicable laws and regulations.
Once personal data is no longer needed for its intended purpose, the DPO shall, in turn, inform the concerned Data Subject in writing of the planned disposal.
If no objection is received from the Data Subject within seven (7) calendar days from the date of notification, all physical and electronic copies of the personal data are securely destroyed using appropriate methods, such as shredding, secure deletion, data wiping, or degaussing, depending on the data format.
Any unauthorized destruction of personal data are reported immediately to the DPO or the responsible Department Head to ensure proper documentation, investigation, and implementation of corrective actions.
Changes to the Privacy Notice
This Privacy Notice may be revised from time to time to reflect changes in legal or regulatory requirements, or operational needs. Updates will be posted on our website or communicated through appropriate channels.
Contact Us
For any questions, requests, or concerns regarding your personal data, you may contact our Data Protection Officer:
Name: Marceliano N. Molina III
Email: dpo@frontiertowersphilippines.com
