PEER LEARNING INC. PRIVACY POLICY
Introduction
This Privacy Notice describes how PEER collects and processes your personal information through the PEER websites and applications that reference this Privacy Notice. PEER refers to an ecosystem comprising PEER websites (whose domain names include but are not limited to www.peerprc.com), mobile applications, clients, applets and other applications that are developed to offer Peer Services, and includes independently-operated platforms, websites and clients within the ecosystem (e.g., PEER LET Reviewer App, PEER Maritime Reviewer App, PEER Engineer Reviewer App, et al.).
This Privacy Policy applies to all platforms, websites, and departments of PEER. By using PEER Services, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy Policy.
PEER LEARNING INC., a company registered at 09W1,01-209E WEWORK 36TH STREET UPTOWN BONIFACIO TOWER III FORT BONIFACIO, BGC, TAGUIG CITY is the data controller for personal information collected in connection with provision of PEER services.
1. What Personal Information does PEER collect and process? Why does PEER process my personal information ? What are the legal basis for our use of personal information?
| What personal information does PEER collect and process? | Why does PEER process my personal information? | Legal Basis for our use of personal information (Data Privacy Act Philippines 2012) |
| - email address; - name; - gender; - date of birth; - home address; - phone number; - school or company information; - device ID; - a video recording of you; - transactional information; |
- Transaction services. We use your personal information to process your orders, and to communicate with you about orders and services; - Communicate with you. We use your personal information to communicate with you in relation to Peer Services; - We collect and process identity information and Sensitive Personal Data (as detailed in section 1) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations; |
Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. |
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- the Internet protocol (IP) address used to connect your computer to the Internet; - login, e-mail address, password and location of your device or computer; - PEER Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences); - version and time zone settings; - transaction history; - Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus; |
- Provide, troubleshoot, and improve PEER Services. We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of PEER Services.
-Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, PEER Services and others. We may also use scoring methods to assess and manage credit risks. |
Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others; |
| - Information about your behavior: we may process information about you on your behavior and your activity for marketing and advertising purposes. |
- Improve our services. We process personal information to improve our services and for you to have a better user experience; - Recommendations and personalization. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalize your experience with PEER Services; |
Our legitimate interest to improve our services; Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose. |
2. Does PEER Share My Personal Information?
Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. PEER shares users' personal information only as described below and with the subsidiaries or affiliates of PEER that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.
Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that PEER or substantially all its assets are acquired, user information will be one of the transferred assets.
Protection of PEER and others: We release account and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of PEER, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
3. What About Cookies and Other Identifiers?
We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements.
The cookie banner on your browser will tell you how to accept or refuse cookies.
4. Transfers of personal data
PEER may transfer your data domestically or internationally. PEER puts in place suitable technical, organizational, and contractual safeguards (including Standard Contractual Clauses and designated individuals within PEER), to ensure that such transfer is carried out in compliance with applicable data protection rules.
5. How Secure is My Information
We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software.
We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account password. We recommend using a unique password for your PEER account that is not utilized for other online accounts and to sign off when you finish using a shared device.
6. What About Advertising?
For us to provide you the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising. You may opt-out of sharing personal information with our marketing partners unless we have a legitimate interest to do so.
7. What Information Can I access?
You can access your information, including your name, address, payment options, profile information, and transaction history in the "Your Account" section of the application.
8. What Rights Do I Have?
If you have any questions or objection as to how we collect and process your personal information, please contact [email protected].
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time.
In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances, by contacting [email protected].
As data subject, you are entitled to:
(a) Be informed whether personal information pertaining to him or her shall be, are being or have been processed;
(b) Be furnished the information indicated hereunder before the entry of his or her personal information into the processing system of the personal information controller, or at the next practical opportunity:
(1) Description of the personal information to be entered into the system;
(2) Purposes for which they are being or are to be processed;
(3) Scope and method of the personal information processing;
(4) The recipients or classes of recipients to whom they are or may be disclosed;
(5) Methods utilized for automated access, if the same is allowed by the data subject, and the extent to which such access is authorized;
(6) The identity and contact details of the personal information controller or its representative;
(7) The period for which the information will be stored; and
(8) The existence of their rights, i.e., to access, correction, as well as the right to lodge a complaint before the Commission.
Any information supplied or declaration made to the data subject on these matters shall not be amended without prior notification of data subject: Provided, That the notification under subsection (b) shall not apply should the personal information be needed pursuant to a subpoena or when the collection and processing are for obvious purposes, including when it is necessary for the performance of or in relation to a contract or service or when necessary or desirable in the context of an employer-employee relationship, between the collector and the data subject, or when the information is being collected and processed as a result of legal obligation;
(c) Reasonable access to, upon demand, the following:
(1) Contents of his or her personal information that were processed;
(2) Sources from which personal information were obtained;
(3) Names and addresses of recipients of the personal information;
(4) Manner by which such data were processed;
(5) Reasons for the disclosure of the personal information to recipients;
(6) Information on automated processes where the data will or likely to be made as the sole basis for any decision significantly affecting or will affect the data subject;
(7) Date when his or her personal information concerning the data subject were last accessed and modified; and
(8) The designation, or name or identity and address of the personal information controller;
(d) Dispute the inaccuracy or error in the personal information and have the personal information controller correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the personal information have been corrected, the personal information controller shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by recipients thereof: Provided, That the third parties who have previously received such processed personal information shall he informed of its inaccuracy and its rectification upon reasonable request of the data subject;
(e) Suspend, withdraw or order the blocking, removal or destruction of his or her personal information from the personal information controller’s filing system upon discovery and substantial proof that the personal information are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected. In this case, the personal information controller may notify third parties who have previously received such processed personal information; and
(f) Be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information.
SEC. 17. Transmissibility of Rights of the Data Subject. – The lawful heirs and assigns of the data subject may invoke the rights of the data subject for, which he or she is an heir or assignee at any time after the death of the data subject or when the data subject is incapacitated or incapable of exercising the rights as enumerated in the immediately preceding section.
SEC. 18. Right to Data Portability. – The data subject shall have the right, where personal information is processed by electronic means and in a structured and commonly used format, to obtain from the personal information controller a copy of data undergoing processing in an electronic or structured format, which is commonly used and allows for further use by the data subject. The Commission may specify the electronic format referred to above, as well as the technical standards, modalities and procedures for their transfer.
SEC. 19. Non-Applicability. – The immediately preceding sections are not applicable if the processed personal information are used only for the needs of scientific and statistical research and, on the basis of such, no activities are carried out and no decisions are taken regarding the data subject: Provided, That the personal information shall be held under strict confidentiality and shall be used only for the declared purpose. Likewise, the immediately preceding sections are not applicable to processing of personal information gathered for the purpose of investigations in relation to any criminal, administrative or tax liabilities of a data subject.
9. How Long Does PEER Keep My Personal Information?
We keep your personal information to enable your continued use of PEER Services, for as long as it is required to fulfil the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you.
10. Contact Information
Our data protection officer can be contacted at [email protected] and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.
11. Conditions of Use, Notices and Revisions
If you choose to use PEER Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at PEER, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
Our business changes constantly, and our Privacy Notice will change also. You should check our website frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing PEER immediately. When an updated version of the Privacy Policy is released, your continued access to PEER means that you agree to the updated content and agree to abide by the updated Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.