This Policy sets out the commitment of Refocus E-Learning Philippines Corp. ("Refocus") to collect and process personal information and sensitive personal information (collectively, "personal data") in accordance with the applicable laws and regulations on data privacy, including the Philippine Data Privacy Act of 2012 ("DPA") and its implementing rules and regulations ("DPA IRR"). It explains how Refocus implements that commitment, and the terms and conditions under which we collect and process personal data. In processing personal data, we seek to adhere to the general privacy principles of transparency, legitimate purpose, and proportionality, and such other relevant principles in the collection, processing, and retention of personal data as required by applicable law. This Notice, and any updates, amendments or supplements thereto, is available at https://refocus.me/.
WHAT WE DORefocus provides interactive video course with 24/7 feedback, teaching its clients how to effectively:
Create marketing campaigns from scratch;
Test existing creatives (images, videos, etc.) to improve customer response;
Analyze marketing data;
Budget marketing expenditures;
Manage digital marketing channels (Facebook, Google, Snapchat, TikTok, Instagram); and
Work with marketing partners (in-house team and marketing agents).
SOURCES OF PERSONAL DATAThis Notice applies to Personal Data that Refocus collects from or about you from the following sources:
Our website. Client-directed websites operated by or for Refocus, including sites that Refocus operates under our own domains/URLs and mini-sites that Refocus runs on third party social networks such as Facebook (“Websites”).
Mobile sites/apps. Client-directed mobile sites or applications operated by or for Refocus, such as smartphone apps.
E-mail, text and other electronic messages. Interactions with electronic communications between you and Refocus.
Offline registration forms. Printed or digital registration and similar forms that Refocus collects via, for example, postal mail, in-store demos, contests, sampling activities, and other promotions, or events.
Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third party website, we may receive information about that interaction).
Data created by Refocus. In the course of our interactions with you, we may create Personal Data about you (e.g. records of your transactions with Refocus and affiliated websites).
Data from other sources. Third party social networks (e.g. such as Facebook, Google), market research (if feedback not provided on an anonymous basis), third party data aggregators, promotional partners, public sources and data received when we acquire other companies.
INFORMATION WE COLLECT, GATHER OR GENERATERefocus collects, gathers and generates the following personal data:
last name, first name, middle name and applicable suffixes;
email address;
contact phone number;
links to profiles (pages) on social networks or websites;
photos and / or avatars;
age, gender, and date of birth;
technical means (devices): the IP address of the host, the type of operating system, browser type, geographical location, Internet service provider, data obtained because of access to the camera, microphone, etc. of devices;
information about the visited pages of the website;
information that is automatically received when accessing the website using bookmarks (cookies).
WHY WE COLLECT, GATHER OR GENERATE INFORMATIONRefocus collects, gathers or generates your personal information for the purpose of concluding and executing contracts between Refocus and clients.
Refocus does not verify the accuracy of the information received (collected) from the clients, except in cases when such verification is necessary for the purpose of fulfilling the provisions of the applicable legislation in force and/or obligations to the client.
Refocus collects and stores only those Personal Data that are necessary for:
- execution of the provisions of Contracts with the User;
- distribution of informational materials.
Refocus considers the processing of your personal data for these purposes to be necessary for the performance of our contractual obligations to you, for our compliance with a legal obligation, to protect your vitally important interests, for the performance of tasks we carry out in the public interest, or for the pursuit of the legitimate interests of Refocus or a third party. Refocus understands that the DPA imposes stricter rules for the processing of sensitive personal information and privileged information, and we are fully committed to abiding by those rules.
If we require your consent for any specific use of your personal data, we will collect it at the appropriate time.
Please note further that we will not subject your personal data to any automated decision-making process without your prior consent.
Our Use of CookiesThis website makes use of cookies, which may be set by our webserver or provided by a third party. These are small text files that are automatically downloaded to your browser upon visiting this site. These then collect your browsing data in order to help the site better interact with you and other visitors. In other instances, cookies are also relevant for authentication, session management, and performance analytics.
DISCLOSURE OF YOUR PERSONAL DATAIn addition to Refocus, we also share your Personal Data with the following types of third party organizations:
Service providers. These are external companies that Refocus uses to help it run its business (including but not limited to order fulfilment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, advertising providers, website development, data analysis, CRC, etc.). Service providers, and their selected staff, are only allowed to access and use your Personal Data on behalf of Refocus for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition. We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger.
RETENTION OF YOUR PERSONAL DATAIn accordance with applicable laws, Refocus will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements. Personal data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.
DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATAPeople who can access your Personal Data. Your Personal Data will be processed by our authorized staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected.
Measures taken in operating environments. Refocus stores your Personal Data in operating environments that use reasonable security measures to prevent unauthorized access. Refocus follows reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although Refocus will do its best to protect your Personal Data, it cannot guarantee the security of the data during transmission through our Websites/apps.
Measures to be taken by the Clients. It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls Refocus provides you in our Website/app.
Transfer of your Personal Data. Because of the international nature of its business, Refocus may need to transfer your personal data to affiliated companies, and to third parties as noted above, in connection with the purposes set out in this Privacy Notice. For this reason, Refocus may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Security MeasuresRefocus has taken appropriate security measures to protect your personal data against unauthorized access or unauthorized alteration, disclosure, or destruction. These measures include internal reviews of our data collection, storage, and processing practices, as well as physical security measures to protect your information against unauthorized access. As part of our efforts to ensure your information is protected, Refocus restricts access to personal data to personnel who would need that information to perform their functions.
YOUR RIGHTS UNDER THE DPAUnder the DPA, data subjects have the following rights:
Right to object. As a data subject, you have the right to indicate your refusal to the collection and processing of your personal data, including processing for direct marketing, automated processing, or profiling. You also have the right to be informed and to withhold your consent to further processing in case there are any changes or amendment to information given to you. Once you have notified us of the withholding of your consent, further processing of your personal data will no longer be allowed, unless:
(i) The processing is required pursuant to a subpoena, lawful order, or as required by law; or
(ii) The collection and processing is undertaken pursuant to any lawful basis or criteria AS may be allowed under the DPA.
Right to access. Upon your request, you may be given access to your personal data that we collect and process. You also have the right to request access to the circumstances relating to the processing and collection of your personal data, insofar as allowed by law.
Right to rectification. You have the right to dispute any inaccuracy or error in your personal data and may request us to immediately correct it. Upon your request, and after correction has been made, we will inform any recipient of your personal data of its inaccuracy and the subsequent rectification that was made.
Right to erasure or blocking. In the absence of any other legal ground or overriding legitimate interest for the lawful processing of your personal data, or when there is substantial proof that your personal data is incomplete, outdated, false, or has been unlawfully obtained, you may request us to suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our filing system. We may also notify those who have previously received your processed personal data.
Right to damages. You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, taking into account any violation of your rights and freedoms as a data subject, as provided by law.
Right to data portability. In case your personal data was processed through electronic means and in a structured and commonly used format, you have the right to obtain a copy of your personal data in such electronic or structured format for your further use, subject to the guidelines of the National Privacy Commission with regard to the exercise of such right.
Transmissibility of rights of the data subject. Upon the passing of a data subject, or in case of a data subject’s incapacity or incapability to exercise legal rights, the data subject’s lawful heirs and assigns may invoke the data subject’s rights in place of the data subject.
Limitation on rights; manner of exercising. The rights mentioned above are not applicable if personal data are processed only for scientific and statistical research purposes, and without being used as basis for carrying out any activity or taking any decision regarding you as the data subject. Your rights as a data subject are also subject to other limitations provided by law.
The law requires you to exercise your rights as described in this Notice in a reasonable and non-arbitrary manner, and with regard to rights of other parties.
Data breachesRefocus will comply with the relevant provisions of rules and circulars on handling personal data security breaches, including notification to you or to the National Privacy Commission, where an unauthorized acquisition of sensitive personal information or information that may be used to enable identity fraud has been acquired by an unauthorized person, and is likely to give rise to a real risk of serious harm to the affected data subject. Please note that under applicable law, not all personal data breaches are notifiable.
Amendments and supplementsRefocus may, from time to time, make changes to this Notice. On such occasions, we will let you know through our website and, when permissible, other means of communication. Any modification is effective immediately upon posting on the website
HOW TO REACH USIf you wish to exercise any of your rights, or should you have any concern or question regarding them, this Notice, or any matter involving Refocus and data privacy, you may contact our Data Protection Office (DPO) at:
Email:
[email protected]Office address:
F27 The Enterprise Center Tower 2, Ayala Ave. cor. Paseo de Roxas Ave., Makati 1226Mobile:
+63 (285) 409-669Website: refocus.me