Effective Date: August 1, 2022
Welcome to the Privacy Statement of Ayala Land, Inc., where the terms “we”, “us”, and “our” are references to Ayala Land, Inc. and all its subsidiary companies doing business under the Ayala Land, Inc. name. The term “you” and its derivatives refer to customers, vendors, partners, employees, associates, and other stakeholders of Ayala Land, Inc.
This Privacy Statement describes our privacy practices and our general approach to protecting the Personal Data that you share with us. This complements the Privacy Notice, available at specific data collection points, which provides more specific details about the categories of Personal Data we collect, the purpose and extent of their processing, and the safeguards in place to ensure their protection.
The Principles that Guide Our Privacy Practices
Ayala Land, Inc. and its subsidiaries respect the confidentiality of Personal Data, value your data privacy rights, and are in compliance with the Philippine Data Privacy Act of 2012.
We strive to ensure that all Personal Data collected from customers, vendors, partners, employees, associates, and other stakeholders are processed in accordance with the following general data privacy principles:
Transparency is key to building trust with you. As such:
We shall provide you with clear and accessible information through a Privacy Notice that describes
- your Personal Data that are collected and processed,
- the purposes and lawful bases for processing,
- how your Personal Data are protected,
- your rights and choices, and
- the contact information for privacy-related matters.
You will be given the choice to allow us to process your Personal Data; except when the law requires us to do so.
When your consent is needed to lawfully process Personal Data, you will be asked to read the Privacy Notice and provide your consent before we can collect and process your data.
We will only process your Personal Data for purposes that are not contrary to law, morals or public policy. In addition, your Personal Data will only be processed when one or more of the following bases of lawful processing is present:
- Your freely-given and informed consent
- Processing is needed to fulfill our contract with you, or when you ask us to prepare the contract
- Processing is needed for us to comply with a legal obligation
- Processing is needed to protect your vital interests
- Processing is needed to comply with the requirements of public order and safety
- Processing is needed to pursue our legitimate business interests
We will only process your Personal Data in proportion to the specific, explicit, and legitimate purpose.
- We will collect your data only in ways adequate and not excessive to the purposes for which the data was collected.
- We will limit the use, sharing, and retention of your Personal Data to what is necessary to fulfill the purposes.
- Once the purposes have been completed, your Personal Data will be securely disposed of, unless we are required to retain them for legal purposes.
- We will limit access to your Personal Data to authorized personnel. This access is limited to what is necessary to fulfill the purposes.
We respect your rights as a data subject, which the DPA lists as follows:
- You have the right to access information we hold about you, subject to providing us with appropriate evidence of your identity. We may withhold personal data that you request to the extent permitted by law.
- You can object to us using your data for profiling you or making automated decisions about you.
- You have the right to port your data in a mutually acceptable format.
- You have the right for your data to be erased by asking us to suspend, withdraw, remove or destroy your personal data, if it is no longer necessary for us to hold the data for the stated purposes (including for appropriate legal purposes).
- You have the right to lodge a complaint regarding our use of your data; but please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the National Privacy Commission.
- You have the right to damages arising from inaccurate, incomplete, false, unlawfully obtained or unauthorized use of your personal data
We shall be accountable for adequately protecting your Personal Data to prevent its misuse and consequent harm.
- Following our internal risk management framework, we assess the risks of systems that process your Personal Data, and use appropriate operational, physical and technical controls to protect them.
- When we outsource, subcontract or share your Personal Data with any entity in fulfillment of the stated purposes, we
- limit their processing to what is necessary full said purposes;
- require that they provide an equivalent level of privacy protection; and
- monitor their compliance in providing these protection measures.
- When a data breach happens, we will immediately deploy measures to prevent further harm, and notify you about the situation accordingly.
Personal Data refers to data that can be used on its own, or with other information to identify, contact, or locate a single person or an individual in context.
What types of Personal Data we collect from you
Depending on your dealings with us (e.g., customer, shareholder, business partner, employee, etc.), whether online or offline, we may collect and process your Personal Data as summarized below.
Personal Data you provide us directly:
Device Information IP address, hardware model, IMEI number and other unique device identifiers, and operating system version
Your location (derived from your IP address, Bluetooth beacons or identifiers, or other location-based products or features technologies) that may be collected when you enable location-based features
Information about your visit and use of our websites, digital platforms, and mobile apps
Time, duration, manner of use of our products and services, or products and services connected to ours
Social media behavior
Tagging, mentioning, or posting photographs of any development project of Ayala Land and its subsidiaries on any social media platform (i.e., Facebook, Twitter, Instagram, LinkedIn, etc.)
Information we may collect from other sources
To the extent permitted by applicable laws, in addition to our websites, applications and other digital channels, we may also obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms and other third parties.
Information we may aggregate from different sources to your profile
If you have indicated to us that you wish to receive personalized direct marketing communications, we might aggregate data from different sources (both internally and externally) to have a better understanding of your preference and interests, and be able to serve you with more relevant communications. You can always object to these activities by opposing this. In particular, you can always opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email.
We may collect and store your Personal Data in a variety of ways:
- When you purchase or avail any of our products, services, promos, activities, and events;
- When you interact with our sales or customer care agents, reservation officers and specialists through email, phone, chat services, or face-to-face meetings;
- When you submit information through manual forms, and online forms on our digital assets (i.e., websites, apps), or contact us through any of our social media accounts (i.e., Facebook, Twitter, Instagram, LinkedIn, etc.);
- When you register, maintain, or use our digital platforms, including our mobile apps;
- When you visit our premises with CCTV surveillance camera that are used for safety and security of our shoppers, guests, employees, and other visitors of our malls, offices, hotels, and resorts;
- When you provide Personal Data in relation to inquiries, requests, and complaints;
- When you respond to surveys, promotions, and other marketing and sales initiatives;
- When you submit a job application;
- When you are referred to us by third parties or business partners; and
- When you submit your Personal Data to us for any other reason.
When you disclose to us Personal Data of another person (e.g., your dependent, spouse, children, and/or parents), you attest that consent has been obtained from that person to disclose and process his/her Personal Data in accordance with this policy.
If the Personal Data was provided by a minor or one who is not legally capable of entering into contractual transactions without parental or guardian consent, the parent or legal guardian shall be responsible in providing the consent as required under this Data Privacy Statement, and in correcting any information given or informing us that the information should be disregarded or deleted.
General uses of your Personal Data
We may use your Personal Data for different legitimate reasons and business purposes. Among the general uses are:
- Providing you with product and services that you have requested, including customer support;
- Enhancing your customer experience by delivering product services that match your preference and needs;
- Communicating relevant products and services, advisories, and responses to your queries, requests, and complaints;
- Complying with the requirements of the law and legal proceedings, such as court orders, and legal obligations; preventing imminent harm to the public; and ensuring public security, safety, and order;
- Preventing, detecting, and investigating a crime (including fraud and money-laundering)
- Analyzing and managing other commercial risks; and
- Processing of information for statistical, analytical, and research purposes.
Other uses by nature our dealings
Aside from the general uses mentioned above, depending on your dealings with us, we may use your Personal Data to serve the following purposes:
When you inquire about or purchase property from us
- Conducting appropriate due diligence checks;
- Registering your inquiry and addressing any follow-up calls;
- Preparing necessary sales documentation and any other documentation as may be requested;
- Performing financial processes related to the sale, such as the set-up of down payment, amortization, and financing, and performing other actions necessary or desirable in the implementation of our contract;
- Managing unit turn-over activities; and
- Communicating advisories and changes in relation to the sale.
When you apply to become a merchant or tenant in any of our properties for lease
- Conducting appropriate due diligence checks for identification and verification;
- Registering and processing your application;
- Preparing lease documents and any other document as may be required;
- Processing of financial transactions (e.g., rental payments), and other actions necessary or desirable in the implementation of our contract; and
- Communicating advisories and changes in the terms and conditions related to your lease contract.
When you are a guest or resident in our hotels and resorts
- Providing the services that you request such as to facilitate reservations, conduct identity verification, send confirmations, assist you with meetings, events or celebrations, and confirm details of your accommodation;
- Fulfilling our contractual obligations to you or anyone involved in the process of booking your travel arrangements;
- Strengthening our relationship with you before, during, and after your stay through segmentation analysis for statistical, analytics, marketing, and communication purposes;
- Personalizing your entire hotel and resort experience with tailor-fit products, services, and offers, including those performed by third parties such as courier and transportation services;
- Providing you with value-added services such as processing for your seamless arrival and departure, resident cards, babysitting, and spa and fitness requirements, and performing all financial processes related to the transaction; and
- Facilitating your application to our partner reward and membership clubs, including contacting you by mail, fax, telephone, or email for marketing purposes.
When you are a guest or shopper in our malls
- Monitoring security, crime, and emergency incidents and situations within mall premises through camera recording and surveillance;
- Determining whether you can avail of any discount or privilege;
- Determining whether you are eligible to participate in any offer, service, event, or activity in our malls;
- Generating data insights from customer feedback and/or mall traffic
- Addressing your queries, requests, and complaints, and conducting any follow-up as may be necessary.
When you use any of our digital platforms, including mobile apps
- Registering, verifying, and maintaining your account, as applicable;
- Giving our third-party service providers the necessary information to implement our rewards programs and access to any advanced features of our digital platforms, as applicable;
- Assessing your eligibility for certain rewards and programs, and informing you of products, services, events, promotions, and initiatives that may be of interest to you;
- Providing you with personalized customer experience by maintaining your personal profile/dashboard and by showing targeted advertisements that may match your preference and needs; and
- Addressing your queries, requests, feedback, changes to our terms of service, and matters relating to the operation of your account, as applicable.
You may unsubscribe from our offers or marketing materials at any time by clicking the unsubscribe link in the promotional emails or by following the steps provided in the promotional text messages.
When you are a vendor, prospective vendor, or contractor
- Conducting appropriate due diligence checks;
- Evaluating of your proposal and conduct of corresponding background checks;
- Assessing your viability as a vendor and processing your accreditation;
- Communicating to you matters related to our required products and services;
- Performing other actions necessary or desirable in the implementation of our contract.
When you apply for employment or become our employee
- Conducting appropriate background investigation, reference checks, pre-employment medical examination and interviews;
- Communicating the status of your candidacy;
- Processing of your compensation, allowances, expense reimbursement and monitoring your attendance and leaves;
- Enrolling in our benefit programs which may include health insurance, medical insurance, retirement plan and social security;
- Assisting you in your professional development through performance management, career development, seminars, workshops, and training;
- Making you part of our employee engagement activities and programs, such as events, employee surveys, and incentives and discounts offered subject to approval of management;
- Complying with our obligations under the law as required by government organizations and local government units; and
- Facilitating, upon separation with the company, your exit interview, clearances, and other procedures necessary to process your final pay.
When you are our shareholder
- Managing the administration of the relationship (e.g., identification, verification, including identity of your nominated proxy);
- Communicating the company’s performance including products and services as well as changes in polices, terms and conditions through various applicable channels.
Fulfillment of Legitimate and Business Purposes
In fulfillment of the stated purpose/s that you consented to, we may disclose your Personal Data to the following parties:
- Our employees and officers;
- Professional advisers such as lawyers and auditors;
- Insurers and credit providers;
- Banks, credit card companies and their respective service providers;
- Suppliers or subcontractors; third-party service providers; consultants that have been contracted by us to provide financial, technical, architectural, administrative, and support services such as information technology, payroll, accounting, sales administration, procurement, training, background investigation, loyalty engine or rewards program, and other services, such as but not limited to allowing users to have access to and enjoy other features of our digital platforms;
- Any third-party business offering goods and services or sponsor contest or other marketing and promotional programs, where you have provided your consent;
- Members of our group of companies or our subsidiaries and affiliates;
- Our holding company Ayala Corporation and all its subsidiaries and affiliates; and
- Our joint venture and alliance partners.
Legal and statutory compliance
To the extent that we are required to do so by applicable laws, rules, and regulations, we may share your Personal Data:
- In connection with any ongoing or prospective legal proceeding;
- To the buyer or prospective buyer of any business or asset that we are contemplating to sell;
- To clients and customers availing of our products and services;
- To any person whom we reasonably believe may apply to a court or other competent authority for disclosure of such Personal Data where, in our reasonable opinion, such court or authority would reasonably and be likely to order the disclosure of such Personal Data;
Any company/entity with which we share information about you for the above purposes is contractually required to comply with confidentiality standards, undertake to respect any individual’s right to privacy, and comply with the Data Privacy Act. We also require that these organizations use this information only for our purposes, and follow our reasonable directions with respect to the use and protection of this information. This includes organizations which handle or obtain Personal Data as service providers for us.
Information that we collect may be stored, processed, and transferred between any of the countries which host the cloud services that we utilize (e.g., Microsoft Office 365, Amazon Web Services, Salesforce). All cloud service providers have been evaluated for their ability to meet the minimum requirements of the Data Privacy Act of 2012. Their performance in fulfilling these requirements is part of the Vendor Performance Evaluation.
Personal Data that you publish or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by parties other than those mentioned in the section above (“Disclosure of Personal Data with Other Parties”).
We will retain documents (including electronic documents) containing your Personal Data:
- To the extent that we are required to do so by law;
- To the extent required by or pursuant to our contract; and
- If we believe that the documents may be relevant to any ongoing or prospective legal proceedings in order to establish, exercise, and defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
Thereafter, your Personal Data shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.
The specific details about the retention and disposal of your personal data will be stated in the Privacy Notices of the individual subsidiary company’s website or application that you have accessed.
Accessing your Personal Data
You may instruct us to provide you with any Personal Data we hold about you, subject to providing us with appropriate evidence of your identity.
- We may withhold Personal Data that you request to the extent permitted by law.
- You may instruct us at any time not to process your Personal Data , unless these are required to fulfill our contractual obligations or to comply with the lawfor
- • You will be asked to expressly agree in advance to our use of your Personal Data for marketing purposes, or we will provide you with an opportunity to opt out of the use of your Personal Data for the same purpose.
Updating your Personal Data
If the Personal Data that we hold about you needs to be corrected or updated, Ayala Land shall make all reasonable efforts to ensure that data collected is current, complete and accurate.
- If you need to access, correct, and update your Personal Data, you may send a request to firstname.lastname@example.org or get in touch with the customer support team of the product or services that you availed of.
- As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary corrections, we shall then notify you that your request has been processed and completed.
Withdrawal of consent
If you wish to withdraw the consent that you’ve given for any or all purposes set out in this policy, you may send your detailed request to email@example.com . Depending on the nature of the withdrawal of consent, Ayala Land may no longer be in a position to provide products and services to you.
We take precautions to protect your information. When you submit sensitive information via any of our official websites, such information is protected both online and offline.
Protecting information that you submit online
- Wherever we collect sensitive information (e.g., credit card data), such information goes through our payment gateway, which encrypts and transmits the data to us in a secure way.
- All our critical websites undergo security scanning and penetration testing to reduce their vulnerability to cyber-attacks. While we employ all necessary precautions to safeguard your information, the internet is not 100% secure, so we cannot guarantee that information we collect or store will be protected from unauthorized access and used in a manner that is inconsistent with this Privacy Statement.
We maintain physical, technical, and organizational safeguards to protect your Personal Data against loss, theft, and unauthorized access, disclosure, copying, use, or modification.
How we safeguard your Personal Data
We also implement safeguards such as:
- The use of secured servers behind advanced threat protection appliances, firewalls, encryption, and other security tools;
- Limiting access of your Personal Data to those who are qualified and authorized to process them. All such persons, wherever they are located, are required to protect the confidentiality and privacy of your Personal Data in a manner consistent with our privacy policies and practices; and
- Regular security vulnerability and penetration testing of our information systems and infrastructure to ensure that your Personal Data is properly protected.
Our websites contain hyperlinks and details of third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.
What is a Cookie?
Why are these cookies used?
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to properly respond to customer needs. We only use this information for statistical analysis purposes, after which the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. We may use your browsing behavior to develop promotional offers, products, and services that we feel are beneficial to you.
What are your options?
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies; however, doing so may prevent you from taking full advantage of the website.
Ayala Land Management is committed to ensure that its Privacy Management Program is constantly reviewed, monitored, and enhanced.
To that end, a Data Protection Officer for Ayala Land and corresponding Compliance Officers of Privacy for our subsidiaries have been appointed to manage and safeguard the handling of your Personal Data in compliance with the Philippine Data Privacy Act of 2012 (R.A. 10173) and this Policy.
Ayala Land regards Personal Data breaches very seriously, and has procedures in place to deal with these.
Ayala Land and its subsidiaries use a CCTV system in capturing images and videos of employees, mall goers, hotel and resort guests, and visitors to monitor security, crime and emergency incidents or situations within our premises. The CCTV data is stored in secure locations, accessed only by authorized Ayala Land and subsidiary personnel for legitimate purposes, and may be shared with appropriate authority for investigatory purposes.
Individuals identified on the CCTV system have the right to ask for access to footage subject to confirmation and approval of Ayala Land/subsidiary’s management.
As part of our efforts to safeguard and ensure the security and protection of your Personal Data, Ayala Land amends this Privacy Statement from time to time. Ayala Land may also update this Privacy Statement to apply changes due to new laws and regulations affecting the Data Privacy Act, as well as changes in our business operations and environment. Any update will be posted on the Ayala Land, Inc. corporate website with a date stamp so that you are informed of the latest update.
For comments, questions, or requests relating to this Privacy Statement, or complaints in relation to your rights under this Privacy Statement, you may get in touch with the Ayala Land Data Protection Officer by filling up the Ayala Land Group Data Privacy Form.