PRIVACY POLICY

 

This Privacy Policy (“Privacy Policy”) by Acquisition Apps, Inc. (the “Corporation”, “Tangere”, “we”, or “us”) applies to persons (collectively “Users”) using Tangere’s Marketing Survey: Prize Polls Mobile Application (the “App”) in: (1) participating in market research by answering survey questions and (2) earning points for raffle draws as may be designated by the Corporation to potentially early raffle prizes awarded at random by the Corporation (collectively “Services”). Users shall be collectively referred to herein as “you”.

This Privacy Policy was last updated on April 25, 2020.

If you do not agree to be bound by all the terms of this Privacy Policy, please exit the Site immediately and do not use the App and our Services. We may, at any time and at our sole discretion, amend and update this Privacy Policy. 

You are responsible for regularly reviewing this Privacy Policy. Any such amendments, modifications and/or updates will be effective immediately upon posting on the App and the Site. Your continued access or use of the App or the Site after the posting such amendments, modifications and/or updates confirms your acceptance and consent to be bound by the Privacy Policy, as amended.

I. COLLECTION OF PERSONAL INFORMATION

Under this Privacy Policy, your Personal Information (“Personal Information”) which we collect shall include, but is not limited to: your name; address; mobile phone number; age; gender; birth date; marital status; religion; email address; mobile number; profile picture; or any other information necessary which we may request from time to time, subject to your consent, to create and/or maintain your account and to allow you to use the App and access the Site. It may also refer to any other information whether recorded in a material form or not, from which your identity is apparent or can be reasonably and directly ascertained by us, or when put together with other information would directly and certainly identify you. Personal Information shall include both Personal Information and Sensitive Personal Information as defined under Republic Act No. 10173 or the Data Privacy Act of 2012 (the “DPA”).

Tangere collects Personal Information from or about you in the following manner: 

  • i. When you download the Tangere App;
  • ii. When you create an account in the Tangere App directly or through other services (i.e., social media accounts); and
  • iii. When you participate in our Services; specifically, by participating in market research by answering survey questions in the Tangere App.

Tangere processes Personal Information to fulfill our contractual obligations to you, comply with legal obligations and regulatory requirements, or as may be reasonably necessary to conduct our business. In all cases where we process Personal Information, we will uphold your rights under the DPA, including its Implementing Rules and Regulations (“IRR”) as well as other issuances of the National Privacy Commission (“NPC”) (collectively, the “Law”). 

We also recognize that the personal data of European Union residents and/or jurisdiction(s) are protected by the General Data Protection Regulation (“GDPR“) and that the GDPR covers the processing activities involving the personal information of the aforementioned individuals. In this regard, we state that our policy commitment is to adopt all standards and regulations prescribed by the Law as well as by the GDPR, as may be applicable to you.

In using the Tangere App, we may permit you from time to time to submit, upload, publish or otherwise make available to us, through the Tangere App, textual, audio, and/or visual content and information, including commentary and feedback related to the Tangere App, initiation of support requests, and submission of entries for competitions and promotions (“User Content”).

Tangere may also collect transaction details related to your use of the Tangere App, including choices made on the survey forms, number of points generated, and other related transaction details.

Tangere may also receive, combine, and associate collected information from other sources if you choose to link, create, or log in to your account in Tangere App using a social media service (e.g. Facebook) or if you also interact with us through our customer service representatives.

In the course of using our website and electronic platforms, we may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. We can track your location upon use of the Tangere App. We may likewise use web analytics tools – including those of third parties –that use cookies to collect anonymous information and data generated in connection with your activities when you visit the pages in our website.

Tangere may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives, agents and service providers.

By accepting this Privacy Policy and submitting the required Personal Information or User Content to us, you consent to such collection, disclosure, processing and retention thereof. You hereby expressly waive and release us from any and all liability, claims, causes of action or damages arising from our legitimate use of the submitted information, Personal Information or User Content.

II. USE OF PERSONAL INFORMATION

Subject to this Privacy Policy, the Terms of Service, and applicable terms and conditions of third-party applications, all data transmitted through the App is owned by Tangere. To the extent that Tangere is precluded from owning data transmitted through the Tangere App, you grant Tangere a perpetual, worldwide, royalty-free license to use such data to the extent necessary to enable your use of the Tangere App and Services.

Tangere may use and process your Personal Information consistent with this Privacy Policy, the Terms of Service, applicable terms and conditions of third-party applications, and the Law, for the following purposes:

  1. 1. For the purposes of contracting with or providing you access to the App, the Site, and/or our services;
  2. 2. For purposes of enabling you to use our App and Site to participate in our Prize Polls Surveys.
  3. 3. For purposes of COLLECTING YOUR RESPONSES TO OUR market and/or political surveys/POLLS UPON YOUR USE OF OUR APP AND ITS SERVICES and, THEREBY, TO ALLOW US TO CONDUCT, ANALYZE, GENERATE, AND/OR AGGREGATE MARKET and/or political research AND/OR ANALYTICS BASED ON YOUR RESPONSES TO OUR SURVEYS/POLLS IN OUR APP.
  4. 4. To respond to questions, comments, and feedback from you;
  5. 5. To communicate with you for any of the purposes listed in this Privacy Policy and our Terms of Use;
  6. 6. To enhance or develop the App, the Site, and our features, and services; 
  7. 7. To conduct studies and researches for the purpose of reviewing, developing and improving the App, the Site, and our services;
  8. 8. To perform profile analysis, behavioral modeling, and analytics to understand needs, preferences, and market trends to be able to improve and recommend suitable products and services;
  9. 9. To perform certain protective safeguards against improper use or abuse of the App, the Site, our products and services including fraud prevention;
  10. 10. To comply with our operational, audit, and administrative processes, policies and procedures, the terms and conditions governing the App and our products and services, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities, or courts of competent jurisdiction, as the same may be amended or supplemented from time to time;
  11. 11. To comply with legal and regulatory requirements and respond to court orders and other instructions and requests from any local authorities including regulatory, governmental, tax and law enforcement authorities or other similar authorities, as may be applicable; and
  12. 12. To perform other such activities permitted by law or with your consent.

III. STORAGE OF PERSONAL INFORMATION

All information provided to us may be stored, processed, and/or accessed by us, for business purposes, including for marketing, service development and improvement, industry and market, research, and such other lawful purposes consistent with this Privacy Policy, the Terms of Service, applicable terms and conditions of third-party applications, and the Law.

Your personal information shall be retained for as long as you remain as a User of the App, consistent with this Privacy Policy, and until such time as you choose to deactivate your account with us, unless otherwise a longer period is required by Law. We undertake to delete your personal information from the time that the information is no longer necessary pursuant to the above conditions.

IV. DISCLOSURE OF PERSONAL INFORMATION

​Subject to any limitation and consistent with the guidelines set under the Laws, you consent that we may provide any information collected from you and available to us about you and in connection with your use of the App and the Site to third parties which include the following – 

  1. 1. With the staff and employees of Tangere;
  2. 2. With third parties listed in Annex “A” of this Privacy Policy with whom you choose to let us share your Personal Information;
  3. 3. With our subsidiaries and affiliated entities and their employees that provide services or conduct data processing, data centralization and / or logistics purposes on our behalf;
  4. 4. With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf, such as work related but not limited to:
    • a. compliance with legal requirements;
    • b. enforcing our Terms of Use or such other applicable policies with respect to the services that we provide;
    • c. addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property or security of our customers or third parties; or
    • d. carrying out all other purposes set out above;
    • 5. With regulators, law enforcement officials, government authorities, or any competent authority in response to a request for information if we believe that disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process, or not inconsistent with our Tangere App and Terms of Service available at https://www.tangereapp.com/terms-of-service/, including the following instances – 
    • a. there is a complaint, dispute, or conflict relating the App or any proceedings in defense of claims or enforcement of rights and/or upon any compulsory order by a court of competent jurisdiction or any other ground/s allowed under applicable law;
    • b. it is necessary to enforce the Terms of Services;
    • c. it is required by applicable law, regulation, ordinance, license, or operating agreement; or
    • d. it is necessary to protect our safety, rights, property, or security or that of any third party; to detect, prevent, stop or otherwise address fraud, security, technical issues or any activity which we, in our sole discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable;
    • 6. With any other entity in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

The data shall be provided in a manner and form as specified in a separate contract or agreement. Tangere and third parties shall take reasonable measures to protect the data from breach of the agreement or any part thereof or from unauthorized and unlawful disclosure to other parties. 

The following shall be observed in sharing data:

  • The amount of information that shall be collected and processed are defined.
  • The information shall be provided only to the authorized recipients of date.
  • Tangere may withhold or order to cease processing or sharing of data at any time if it deems that such processing or disclosure is contrary to Law or adversarial to Tangere’s interests.
  • Tangere may share anonymized or aggregated information internally and with third parties for any purposes. Such information will not identify you individually.

V. PROTECTION OF YOUR PERSONAL INFORMATION

Tangere fully recognizes the value of your Personal Information. Appropriately, we strive to maintain the confidentiality, integrity and availability of your personal information by employing physical, technological and organizational safeguards. We are committed to implement physical, technological and organizational safeguards to protect Personal Information against loss, misuse, damage and unauthorized processing, access, disclosures or modifications of Personal Information. We train our employees to properly handle your information. Whenever we engage other companies to provide services for us, we require them to protect your Personal Information aligned with our own security standards. We continuously review and enhance our security policies and security measures to consistently maintain a high level of security.

VI. USE OF COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

When you use or access the App or the Site or engage with our email communications, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons. 

We use and collect only essential data which are absolutely necessary for running the App, the Site, and to provide our products and services. We do not collect cookies related to analytics without your permission.

If you do not wish for your Personal Information to be collected via cookies on our website, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

VII. Unsolicited Idea Submission Policy

Unsolicited idea (“Unsolicited Idea”) refers to any suggestions including, but not limited to, ideas for new or improved services or technologies, service enhancements, processes, materials, marketing plans or new service names, artworks, new advertising campaigns, and new promotions. Tangere or any of its employees do not accept or consider Unsolicited Ideas or suggestions from you at all times. 

We strongly request you not to submit any of your original creative work or suggestion in any form available to improve and enhance our services to us or any of our employees. 

The sole purpose of this policy is to avoid potential misunderstandings or disputes when our services or marketing strategies might seem similar to the unsolicited ideas or suggestions submitted to us. If, despite our request that you not send us any of your ideas or suggestions, you still do so, then regardless of what you expect from us in view of your submission, you are deemed to have agreed upon the following terms and conditions:

  • i. Tangere will automatically own your submission(s) and their contents as its property, without any compensation or recognition to you; 
  • ii. Tangere may use, sell or redistribute the submission(s) and their contents for any purpose and in any way as it deems fit;
  • iii. Tangere does not have any obligation to review any submission(s); and 
  • iv. Tangere does not have any obligation for to keep any submission(s) confidential.

VIII. DATA PRIVACY RIGHTS

Under the Law, you are entitled to the following data privacy rights:

  • i. the right to be informed whether your Personal Information shall be, are being, or have been processed;
  • ii. the right to object to the processing of your Personal Information;
  • iii. the right to reasonably access your Personal Information;
  • iv. the right to dispute the inaccuracy or error in your Personal Information and have us correct it immediately and accordingly;
  • v. the right to suspend, withdraw, or order the blocking, removal or destruction of your Personal Information from our records; 
  • vi. the right to file a complaint with the NPC for any violation of your data privacy rights;
  • vii. the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your Personal Information not in accordance with this Statement; and
  • viii. the right to data portability of your Personal Information. 

In respecting your data privacy rights, you may opt to tell us:

  • i. not to send you marketing materials via email;
  • ii. not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the services that you have availed with us;
  • iii. to provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the Philippines by certain laws and regulations;
  • iv. to update your information; and
  • v. about your other concerns relating to how we collect, use, share, protect or dispose your information.

Tangere may charge a fee for processing your request/s for access and/or update. Such fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you prior to making the request.

In respect of your right to access and/or correct your Personal Information, Tangere has the right to refuse your requests to access and/or make any correction to your Personal Information for the reasons permitted under the law, for example where the expenses of providing access to you is disproportionate to the risks to your or to another person’s privacy.

IX. FEEDBACK

Tangere welcomes any feedback from you regarding any area of our existing services or marketing strategies as you use the Tangere App. You may send your specific feedback through [email protected]. Any feedback you provide at our website shall be deemed to be non-confidential. We shall be free to use such information on an unrestricted basis.

In sending your feedback, please do not include any Unsolicited Ideas that are contrary to law, morals, customs, public policy, public order or any of our company’s existing policies. Your feedback is highly appreciated as it serves as a way for us to improve our services and best satisfy your needs. 

For any queries, clarifications or requests on any aspect of this Privacy Policy, the exercise of your rights pertaining to your Personal Information or to provide any comment about our processing of personal information, please get in touch with us – 

Martin Xavier Penaflor

Data Protection Officer

Acquisition Apps, Inc.

Lot 20 Block 14, Bahayang Pag-asa Subdivision

Pasong Buaya, Imus City, Cavite

+63-920-959-0619

[email protected]

X. ACKNOWLEDGMENT AND CONSENT

By communicating with us using the Tangere App and Site and our Services or by virtue of your engagement with Acquisition, you acknowledge that you have read and understood this Privacy Policy and agree and consent to the use, processing and/or transfer of your Personal Information by us as described in this Privacy Policy.

From time to time we may modify, update or amend the terms of this Privacy Policy by placing the updated Privacy Policy on our website. The effective date of such modifications, updates or amendments will be noted at the end of the Privacy Policy. You should therefore review it periodically so that you are up to date on our most current policies and practices. If we make material changes to our practices regarding the processing and/or use of your Personal Information, your Personal Information will continue to be governed by the version of the Privacy Policy to which such Personal Information was subject (prior to those changes), unless you have been provided notice of, and have not objected to, the changes. By continuing to communicate with Tangere, by continuing to use our Services or by your continued engagement with Tangere following the modifications, updates or amendments to this Privacy Policy, such actions shall signify your acceptance of such modifications, updates or amendments.

By submitting the required Personal Information to us, you consent to such collection, disclosure and use thereof. You hereby expressly waive and release us from any and all liability, claims, causes of action or damages arising from our legitimate use of the submitted Personal Information.

Copyright © 2023 Tangere Apps. Acquisition Apps. Inc. All Rights Reserved.