We at Concepcion value your privacy and take the protection and security of your personal data with utmost importance and commitment. This Privacy Notice will help you understand how your personal data is collected, stored, used, disclosed, and disposed by Concepcion affiliates, which includes Concepcion Industrial Corporation, Concepcion Carrier Airconditioning Company, Concepcion Durables, Inc, Concepcion Midea, Inc., Concepcion Otis Philippines, Inc., Concepcion Business Services, Inc., Cortex Technologies Corporation, Tenex Services Inc., and Teko Asia Solutions, Inc. (collectively, “Concepcion”, “We”, “Our” or “Us”). It also informs you how you can access and update your personal data and make certain choices on how your personal data are used.

This Notice covers our online and offline data collection activities through various channels such as Our websites, web-based and mobile-based applications, third party networks, points of sale, contact centers, retail outlets, promotions, and events (“Concepcion touchpoints”).

We collect personal data (full name, home address, email address, contact numbers) from your interactions with Concepcion touchpoints and other legal sources, as follows:

• Customer Registration: Upon your sign-up to our e-commerce platforms, contact centers and mobile applications, we collect your personal data through the Personal Information Sheet.
• Product Registration: To enable seamless processing of product support and warranty services.
• Order Fulfillment: To process and fulfill your order, We collect and use certain personal information. This information is necessary to ensure that your purchases are accurately processed, prepared, and delivered to your specified address.
• Contact Us: We value your inquiries and concerns. When you contact Us through Our authorized representatives and contact centers, email, mobile applications or services, and other online platforms, We collect some information to effectively address your needs.
• Partnering With Us: When you are interested in becoming a vendor in Our platform, We collect your information to facilitate your onboarding with Us.
• Publicly Available Sources: We may collect information about you from public records and from other available sources authorized to disclose such information.

When our Customers provide us with Personal Data by which they can be reasonably identified, they can be assured that their Personal Data will be used only in accordance with our Privacy Policy and the relevant Terms and Conditions governing their relationship with us.

We collect Customers’ Personal Data from the following sources: (1) Personal Information Sheet; (2) information we collect about Customers when they contact us through our authorized representatives and contact centers, email, mobile applications or services, and other online and mobile platforms; and (3) information we collect about our Customers from public records and from other available sources authorized to disclose such information.

The following describes the various purposes for which Concepcion collects and uses your personal data, and the legal basis for its use:

If you have any comments or questions or if you wish to access, correct, update or ask for a copy of personal information we hold about you, or if you have questions about Condura’s privacy practices in general, please email dpo@cic.ph.

Purpose

Customer services to administer and perform our services, including responding to your inquiries and carrying out Our obligations arising from any agreements between you and Concepcion.

Marketing, business development, and other promotions To understand your preferences, and when allowed by law, market to you personally; provide you information about products and services, promotions and events; develop and implement marketing strategies

Personalization

We use your personal data to:

• Analyze your preferences and habits
• Anticipate your needs based on our analysis of your profile
• Improve and personalize your experience on our Websites and apps
• Ensure that content from our Websites / apps is optimized for you and for your computer or device
• Provide you with targeted advertising and content
• Allow you to participate in interactive features, when you choose to do so

Other general business purposes (eg. market research, analysis, IT security)

• We use your personal data for maintaining your account, conducting internal or market research and measuring the effectiveness of advertising campaigns
• Corresponding with you
• Managing your appointments with us or with someone supporting our products or services (for example, regarding a new product, or after-sales service)
• Enhancing your experiences; fraud prevention (for example in the context of our promotions, competitions and surveys, to ensure that they are not taken more than once by the same person, or in the context of e-commerce to protect cardholder information)

Legal Basis

Consent
Contractual obligations
Legal Obligations
Legitimate interests

Consent
Legitimate interests

Consent
Legitimate interests

Consent
Legitimate interests

Legitimate interest

• Improving and developing new products and services
• Providing sales related or product warranty and support services
• Improving efficiency
• Identifying which of our products and services may interest you and telling you about them
• Defining new types of consumers for products and services
• Marketing our products
• Operating Concepcion touchpoints
• Identifying which of our products and services may interest you and telling you about them
• Defining new types of consumers for products and services
• Customizing your experiences in using Concepcion touchpoints
• Improving and developing new products and services
• Customizing Concepcion touchpoints
• Improving operational efficiency
• Protect our systems, networks and staf

We may disclose your personal data to:

Third party service providers that perform business operations on Our behalf

• Partners who collaborate with Us to provide services to our customers
• Business partners that provide joint communications that We hope our customers find of interest through processing of the following:
  •  Our customers’ Internet Protocol address
  • Search terms used
  • Pages and internal links accessed on Our sites
  • Date and time of visit to the sites
  • Geolocation
  • Referring site or platform (if any) through which Our customers clicked through to this site
  • Operating system
  • Web browser type
  • Type of device used.

We implement appropriate technical and organizational measures to protect personal data that We hold from unauthorized disclosure, use, alteration or destruction. These include using secured IT infrastructure to collect and store personal data, and locked storage rooms for files. Where appropriate, We use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements. We store your personal data for as long as necessary to fulfill the legitimate purposes described in this Privacy Notice unless a longer retention period is required or permitted by law. We generally retain your data for a maximum period of 10 years from your last transaction with us. Once your personal data is no longer needed for the listed purposes, or upon your request (subject to legal requirements), we will securely dispose of it. This may involve physically shredding of documents or permanently deleting electronic data from our systems.

As data subjects, it is important that you are aware of your rights and how to exercise them:

• Right to be informed: You have the right to be notified and furnished with information before processing your personal data.
• Right to access: You have the right to request access to the personal data We hold about you. This allows you to verify the lawfulness of processing and to understand how your information is being used and you may limit the use or transfer of the personal data We hold about you.
• Right to rectification: If you believe that any personal data, We hold about you is inaccurate or incomplete, you have the right to request corrections or updates.
• Deletion of your personal data including deletion of your registered account.
• Right to object: As a data subject, you have the right to object to the processing of your personal data when such processing is based on consent or legitimate interest. You may also withdraw consent for receiving direct marketing communications.

Additionally, you have the option to close your account or request deletion of your personal data. In such cases, We will make reasonable efforts to delete or de-identify your personal data, as permitted by applicable law. Please note that if you choose to withdraw consent entirely or request deletion of your data, We may not be able to continue providing services to you. This action may also lead to the termination of any agreements with Us

• Right to portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
• Right to file a complaint: If you feel your personal data has been misused, maliciously disclosed, improperly disposed, or that any of your data privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission.
• Right to damages: You have the right to receive compensation for any damages you have sustained due to inaccurate, false, and unlawfully obtained or unauthorized use of your personal data. If you wish to exercise any of the rights described above, please email dpo@cic.ph. We aim to respond to your requests within one (1) month.

As Concepcion expands and improves its websites and its applications, or as legal requirements change, We may need to update this Privacy Notice. This Privacy Notice may be modified from time to time without prior notice. We encourage you to review this Privacy Notice on a regular basis for any changes. Rest assured, any changes will not be retroactively applied to personal data already collected, unless required by law.

If you have any comments or questions or if you wish to access, correct, update or ask for a copy of personal information we hold about you, or if you have questions about Concepcion’s privacy practices in general, please email dpo@cic.ph