Last updated: October 2024

This “Privacy Policy” regulates the processing of your personal data by the controller: Plan International Pilipinas Foundation Inc, with registered office at 4F Bloomingdale Building, 205 Salcedo St., Legaspi Village, Makati City, 1229 Philippines (hereafter referred to as: “Plan International Pilipinas Office”).

Please read through this Privacy Policy carefully, since it contains your rights and duties vis-à-vis Plan International Pilipinas Office.

INTRODUCTION

This Privacy Notice applies to the web and mobile apps of Hope Town Hero, including all information and materials contained on it (“HTH”). HTH is managed by Plan International Pilipinas (“Plan Pilipinas”).

For all queries relating to your personal information, please contact the data controller at yesdigital.developer@plan-international.org.

OUR PRIVACY NOTICE

Plan Pilipinas is committed to ensuring the privacy of all users of HTH and that all personal data provided to us is handled in accordance with the relevant provisions of the Philippines Data Privacy Act of 2012. Personal data is any information that can be used to identify a living individual.

By using HTH, you consent to the terms of this Privacy Policy. Plan Pilipinas may change the terms of this Privacy Policy from time to time and, if such changes are made, we will notify you of those changes by contacting you if appropriate or publishing the updated Privacy Notice.

If you do not consent to the changes in the Privacy Policy then you should cease using HTH. Your continued use of HTH after being notified of such changes constitutes acceptance of the modified terms.

Plan Pilipinas may change the terms of this Privacy Notice from time to time and, if such changes are made, we will notify you of those changes by contacting you if appropriate or by publishing the updated Privacy Notice on our website. Your continued use of HTH will be on the terms of this Privacy Notice as amended from time to time.

DEFINITION OF TERMS

1. Data Subject refers who may be availing of the benefits of project, and, who has provided his or her information to the Parties, or any other individual whose personal, sensitive personal, or privileged information is processed.
2. Data sharing refers to the disclosure or transfer to a third party of Personal Data under the custody of the Company.
3. Personal Data refers to:
   1. Personal Information - any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual;
   2. Sensitive personal information:
      1. i. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
      2. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
      3. Issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
      4. Specifically established by an executive order or an act of Congress to be kept classified.
      Privileged Personal Information - any and all forms of data, which, under the Rules of Court and other pertinent laws constitute as privileged communication.

WHAT PERSONAL DATA WE COLLECT AND STORE

The type and amount of information about you that we collect and store depends on how you use HTH. Personal information that is collected and stored generally includes your first and last name, country, gender identity (for which you can select ‘prefer not to say’), birth month and year, and affiliation with Plan International. We will also be able to process any other information which you enter into HTH that is not required in order to access its services including (but not limited to): email address, education and work history, skills, awards, and job preferences.

WHY WE PROCESS YOUR PERSONAL DATA

Plan Pilipinas will only process your personal data to provide you access to HTH services and to aggregate and anonymize it so that the analytics we gather can be used for research carried out by Plan Ltd and its partner research organizations. Plan Pilipinas will also process your personal data in order to provide HTH users and our program participants with better services through HTH and our programs.

WHO YOUR PERSONAL DATA IS SHARED WITH

Your personal data will be shared internally within Plan Pilipinas and Plan Ltd so that we can fulfil the purpose for which you provided it. Where necessary, we will share your information with our service providers in order to allow them to deliver services to Plan Pilipinas, for example, if we contract with a service provider to host HTH.

If you are a program participant with Plan International, we will secure your consent before sharing your personal information with Plan International fundraising offices if they request information about user progress within HTH. Plan Pilipinas/They may contact you to invite you to support our/their activities. Otherwise, we shall only share your personal information if we are required to disclose it by law. Plan Pilipinas will never sell or rent out the personal data that you provide.

HTH uses Google Analytics and Amazon Web Services (AWS), thus your personal information will also be processed by these applications. For information on how these platforms may use or share your personal data please see each organization’s respective privacy policies.

Plan Pilipinas reserves the right to comply with valid legal requests, including the disclosure of user information to regulatory agencies, governmental bodies, or other authorities.

SENDING PERSONAL DATA OUTSIDE THE PHILIPPINES

Your personal data may be transferred outside the Philippines if, for example, Plan Pilipinas contracts with a third party service provider to perform functions on our behalf, (such as a company that hosts HTH) or if Plan Pilipinas transfers your personal data to one of the Plan International fundraising offices based in the country where you live.

Where your personal information is transferred to a service provider or Plan International office based outside of the Philippines, we will ensure that your personal data is protected to the same extent as in the Philippines through one of the following safeguards:

• Transfer to a country whose national privacy legislation ensures an adequate level of protection of personal data as determined by the Philippine government; or
• Put in place a contract with the service provider or Plan International fundraising office that means they must protect personal data to the same standards required in the Philippines.

HOW YOUR PERSONAL DATA IS PROTECTED

Plan Pilipinas takes the security of your personal data seriously. There are internal policies, procedures and controls in place to try and ensure that your personal data is not lost, accidentally destroyed, misused or disclosed, and is only accessed by its employees in the performance of their duties.

Where Plan Pilipinas engages third parties to process personal data on its behalf, they do so only the basis of written instructions, and under a duty of confidentiality. Third parties are also obliged to implement appropriate technical and organizational measures which are compliant with data protection legislation to ensure the security of personal data.

WHAT YOUR RIGHTS ARE

Under certain circumstances, by law, you have the right to:

• Request access to the personal information Plan Ltd holds about you. This is available through a Subject Access Request and must be made in writing to our data controller at yesdigital.developer@plan-international.org.
• Require Plan Pilipinas to change or rectify incorrect or incomplete personal data about you
• Request Plan Pilipinas to delete or stop processing your personal data, for example, where the personal data is no longer necessary for the purposes of processing

You are not required to pay any charge for exercising your rights (unless you are making a Subject Access Request and Plan Pilipinas reasonably concludes that it is manifestly unfounded or excessive).

If you make a request, Plan Pilipinas has one month to respond to you. If you would like to exercise any of these rights please contact our data controller at yesdigital.developer@plan-international.org or in writing to Plan International Philippines, 4F Bloomingdale Building, 205 Salcedo St., Legaspi Village, Makati City, 1229 Philippines.

COMPLAINT RESOLUTION

Plan Pilipinas will strive to resolve any complaints relating to its processing of personal data promptly and fairly. Plan Pilipinas will cooperate with data protection authorities and other regulators, agencies, and tribunals involved in resolving such complaints. In the first instance, please raise your concerns to data.privacy@plan-international.org.

If you are unhappy with how we have dealt with your personal data or your request / complaint, please note that you can make a formal complaint to the supervisory authority in the country where you live or work. If you believe there has been an infringement of your rights under the Philippine Data Privacy Act of 2012, please contact the supervisory authority in the Philippines.

OUR COOKIE NOTICE

A cookie is a text-only piece of information that a website transfers to your web browser so that the website can remember who you are. A cookie will normally contain the name of the Internet domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

Plan Pilipinas uses cookies and analysis software for the purpose of enhancing your user experience. This information is not used to develop a personal profile of you.

By using HTH, you agree that we can place these types of cookies on your device.

Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. To prevent the download of cookies, or otherwise control how cookies are used on your computer, please read the help information supplied with your Internet browser software, go to www.allaboutcookies.org, or read further instructions below.

OUR USE OF COOKIES

GOOGLE ANALYTICS

HTH uses Google Analytics to help analyze how users use the app. This analytical tool uses 'cookies', which are text files placed on your device, to collect standard internet log information and visitor behavior information in an anonymous form.

The information generated by the cookie about your use of HTH (including your IP address) is transmitted to Google. This information is then used to evaluate visitors' use of HTH and to compile statistical reports on website activity for Plan Ltd.

Plan Ltd will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our app. We will not associate any data gathered from HTH with any personally identifying information from any source as part of our use of the Google statistical analytics tool.

Google will not associate your IP address with any other data held by Google. Neither Plan Ltd nor Google will link, or seek to link, an IP address with the identity of a device user.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. See Google's Analytics overview for further information.

DISABLING AND ENABLING COOKIES

You have the ability to accept or decline cookies by modifying the settings on your browser.

Please be aware that restricting cookies may impact on the functionality of this Website.

To disable cookies if you are using Microsoft Windows Explorer: Click on 'Tools' in the top menu, then on Internet Options, then on the tab marked 'Privacy'; Move the slider to the position corresponding to the level of cookie acceptance/denial acceptable to you.

To remove existing cookies if you are using Microsoft Windows Explorer: Click on 'Tools' in the top menu, then on Internet Options; In the section marked 'Browsing History', click on 'Delete...'; In the section marked 'Cookies' click on 'Delete cookies'; Click on 'Yes' or hit the 'Enter' key.

To disable cookies in other browsers see the links below:

• Firefox cookie management
• Chrome cookie management

Other browsers have similar cookie management abilities in their settings, please refer to your browser's 'Help' facility.

Find more detailed information on disabling cookies here: www.aboutcookies.org.