Emperador Privacy Policy on Protection of Personal Data

INTRODUCTION

Emperador Inc. (“EMP”) is currently a holding company which operates an integrated business of manufacturing, bottling and distributing distilled spirits and other alcoholic beverages from the Philippines and Europe, through its subsidiaries. Its wholly-owned direct subsidiary, Emperador Distillers, Inc. (“EDI”) is the Philippines’ largest liquor company and the world’s largest brandy producer.

We, EMP, EDI and its subsidiaries (”Emperador”, whether acting individually or together), respect your privacy and recognize your need for appropriate protection and management of your personal data that you have directly and voluntarily entrusted us. We have developed this Privacy Policy in order to protect your personal data in accordance with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (“NPC”) and other relevant laws of the Philippines.

Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to “any information, whether recorded in a material from 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”.

This Privacy Policy tells you how we process (meaning, how we collect, use, share, and retain) and protect your personal data. It also tells you what steps you can take if you want us to change how we use your personal data, or if you want us to stop using your personal data.

Why do we collect your personal data?

To enable us to comply with our corporate policies with respect to our customers, as well as with regulatory requirements being observed by Emperador, it is important that Emperador collects, uses, stores and retains your personal data when it is reasonable and necessary for a declared and specific purpose.

In general, we are using your data for any of the following purposes:

To provide information about our products and services which may be of interest to you;
To perform functions necessary to deliver the services, goods and other products offered by Emperador;
To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction;
To respond to specific complaints, enquiries, requests or manage future interactive user function it may be necessary to ask for personal information;
To provide customer care activities, monitor our quality and security, and provide services timely and efficiently;
To generate statistical insights;
To comply with legal and regulatory requirements or obligations; and,
To perform such other processing or disclosure that may be required under law or regulations.

Other uses by nature of our transactions

In addition to the general uses mentioned above, we may use your personal information to process your transactions with us, in any of the following situations:

When you want to become a part of Emperador:
- To document the commencement of your employment with Emperador;
- To comply with our obligations under law and as required by Government Agencies such as DOLE, BIR, HDMF, PhilHealth, and SSS;
- To inform and consider you for future job opportunities that may be of interest to you;
- To provide services to clients for which you are involved or endorsed as team member/practitioner;
- To engage independent contractors for the company;
- For information processing such as payroll, benefits application, and tax processing of the company’s Finance and Accounting;
- For enlistment of stockholder
- For performance evaluation and career development of the employees including training and compliance monitoring;
- For demographics and data analytics; and,
- For marketing and sales initiatives such as Emperador publications, events, and business programs and projects.
When you are a vendor, a potential vendor, or a contractor:
- To conduct due diligence check prior to accreditation of suppliers;
- To evaluate feasibility of your proposal whether it is congruent with Emperador;
- To serve as a reference for crediting accounts of accredited suppliers; and,
- To perform any other action as may be necessary to implement the terms and conditions of our contract.
When you are a distributor, or customer:
- To evaluate and reward customers that meet the qualifications for accreditation;
- To monitor the activities of the customers in order to maintain accredited status with Emperador;
- To serve as a reference and to process billings of customers;
- To serve as a source for analysis in granting credit limit; and,
- To perform any other action as may be necessary to implement the terms and conditions of our contract.
When you are a participant in the marketing initiatives of Emperador:
- To notify and update you (through call, text or email) about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications;
- During events, such as product launching, sponsorships and activations, we may obtain your personal information or take a picture of attendees which may be used for documentation and reporting for internal purposes. Also, we may use these pictures for our promotional activities and advertisements in social media pages and websites. We assure you that we treat all of our customers’ information confidential and we will prevent any unauthorized disclosure of it by our employees or any third party; and,
- To implement various marketing initiatives to promote our products and to provide incentives to our loyal customers.
When you become an investor of Emperador:
- To generate stockholders information in the preparation of financial reports as mandated by Security and Exchange Commission; and
- For computation of payout of company’s profit to stockholder during dividend declaration.

What type of personal data we collect?

The common type of data collected by Emperador from you, generally includes the following:

Basic personal information such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
Sensitive personal information such as age, nationality, marital status, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number;
Employment record such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs; and
Financial details such as credit history, bank account, credit card, and debit card information you have provided as a result of our transaction.

Please note that you are responsible for ensuring that all such personal data you submit to Emperador is accurate, complete and up-to-date.

How we collect, acquire or generate your data?

We collect data when you:

Submit a job application;
Submit a proposal and related business documents;
Fill-out our forms and submit necessary documents;
Submit information through any form on our digital platforms or contact us through any of our social media accounts;
Purchase or avail of any of our products and promos;
Respond to surveys, promotions, and other marketing and sales initiatives;
Provide personal information in relation to inquiries, requests, and complaints
Subscribe to our newsletter by indicating your email address;
Disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized representatives; and,
When you transact with an investment broker and/or with our accredited stock transfer agent.

Is emperadorbrandy.com using web analytics?

Our website does not use cookies. Thus, we do not retain any information based from your visits on our website.

What about the links to third-party websites?

We do not provide any personal data to third party websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. Emperador’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. Emperador has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

Who we share your personal data with?

As a general rule, we do not share your data to third party except in limited circumstances as noted below:

By giving your consent, you authorize Emperador to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:

As necessary for the proper execution of processes related to the declared purposes in this Privacy Policy.
The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).

This means we might provide your personal data to the following:

Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
Law enforcement and government agencies;
All third parties with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

What is our Privacy Policy regarding children?

As an alcoholic beverage company, we do not transact with children. Emperador would never collect personal data from children.

We urge parents to be vigilant in regularly monitoring and supervising their children's on-line activities.

How we protect your personal data?

We take reasonable steps to make sure that your personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce our Privacy Policy within Emperador and we have implemented technological, organizational and physical security measures to protect your personal data that we hold, from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
Any personal data that you provide on the http://www.emperadorbrandy.com/ is initially processed and stored by Emperador. Using a secured connection, only authorized Emperador personnel can then access and download your personal data from the system.
We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign-off when finished using a shared computer.

Where and how long do we keep your personal data?

In general, the data will be kept in accordance with the following retention standards:

If the data subject has an existing contract and transaction with Emperador, information will be retained all throughout the contract period and 10 years after its completion.
If the data subject has no existing contract but has existing transaction with Emperador, information will be retained during the transaction and 10 years after its fulfillment.
If the data subject has no existing contract and transaction with Emperador, information will be retained for a retention period of 6 years.

Data collected will be retained in accordance with retention limit set by Emperador standards, industry standards and laws and regulations, unless you request your data to be deleted in our database immediately. Once deleted, the data will be completely removed from all the storage location.

What if there are changes in our Privacy Policy?

From time to time, it may be necessary for Emperador to change this Privacy Policy. If we change our Privacy Policy, we will post the revised version here and it will take effect immediately, so we suggest that you check here periodically for the most up-to-date version of our Privacy Policy. Rest assured, however, that any changes will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless required by law.

How you can access, correct and update the personal data we have about you?

To exercise your rights which include right to access, modify, erase and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or complaints to Emperador, you may reach us through our “CONTACT US” menu in this website: http://www.emperadorbrandy.com/ through a written letter or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:

Data Protection Officer
7F 1880 Building
Eastwood City Cyberpark
E. Rodriguez Jr. Avenue
Bagumbayan, Quezon City
Metro Manila Philippines 1110
Office: (02) 709 2222
Mobile Number: 0956 791 5457
Email: edi.dpo@emperadordistillers.com

For concerns regarding Emperador Inc. please contact our DPO through the following contact details:

For other concerns regarding the full exercise of your rights, you may contact NPC through its website: www.privacy.gov.ph

Our decisions to provide such access or consider any request for correction, erasure and objection to process your personal data as it appears in our records are always subject to any exceptions under applicable and relevant laws and/or the DPA, its IRR and other issuances of NPC.

This Privacy Policy was last amended on April 5, 2018.