SK LinkUp (“the App”), owned by Direct Agent 5 or DA5 (“we”, “us”), is a social media mobile application that is designed to allow users to have conversations and share information within the app. It aims to provide an exclusive community platform for citizens of Sultan Kudarat.  

Likewise, the App aims to implement the policies, rules and regulations for data protection and privacy. In relation thereto, the App respects and values the data privacy rights of the data subject enunciated under Republic Act No. 10173 otherwise known as the Data Privacy Act of 2012 including its Implementing Rules and Regulations (IRR), and ensure that the processing of the data collected from the personal information of the data subject conforms to the general principles of transparency, legitimate purpose and proportionality. Furthermore, we only collect and process information that is necessary to fulfill the purpose of our platform. 

In accordance with this, this privacy policy will detail any necessary information about how the App will collect, process, and store your personal data. This includes the retention of your information, all your privacy rights in relation to that data, and the people/organizations with whom we may share it with, when necessary. 

The compliance for data privacy is managed through the continuous review, evaluation and agreement between the Board of Directors and the Management of the SK LinkUp app. The authority to oversee the implementation of the data privacy policies of the App is vested to its Management. The content of this Privacy Policy may be updated or amended from time to time to align with any future platform configurations, and to comply with the new amendments relative to the implementation of data privacy laws and policies. Should these changes require your consent, we will immediately notify you and request for your consent before we proceed in updating or amending your data based on the newly implemented platform conforming to the changes or amendments of the law as previously mentioned. Otherwise, changes will be rendered effective immediately upon posting.

DEFINITION OF TERMS

Personal Information – refers to any information, whether recorded in a material form 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; 

Data Subject / User – refers to an individual who’s Personal is processed; 

Consent of the Data Subject – refers to any freely given, specific, informed indication of will, whereby the Data Subject agrees to the processing of his or her personal, sensitive personal, or privileged information. It may also be given on behalf of a Data Subject by a lawful representative or agent specifically authorized by the Data Subject to do so; 

Processing – refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of data. Processing may be performed through automated means, or manual processing, if the Personal Information are contained or are intended to be contained in a filing system; 

Outsourcing – refers to the disclosure or transfer of personal information by SK Link Up App Tech Team to Personal Information Processor/s (PIP/s), if any, for the Processing of Personal Information obtained or shared under this Agreement; 

Personal data breach – refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

YOUR RIGHTS AS A DATA SUBJECT

SK LinkUp recognizes all the rights of the data subject enumerated under the Republic Act. No. 10173, otherwise known as the Data Privacy Act of 2012, including its Implementing Rules and Regulations (IRR). The following are the rights of the data subject that will be observed by the company while providing the mobile application services to the client, to wit:

  1. Right to be Informed.
  2. Right to Object.
  3. Right to Access.
  4. Right to Rectification.
  5. Right to Erasure or Blocking.
  6. Right to Damages.

WHAT WE COLLECT

No personal information from data subjects will be collected until the user has given their consent for its collection. In order to register and create an account under SK LinkUp, we only require the user to login with their mobile number. Once the account has been created and if the user would like further access to various functions in the app, other information will be required to validate the identity of the registered user. Information required to access the full functions of the app are as follows:

  1. Personal information
    1. Mobile Number 
    2. Email 
    3. Full name 
    4. Birthdate 
    5. Sex 
    6. Address 
    7. Citizenship 
    8. Biometrics (selfie) 
    9. Permanent Address 
    10. Proof of Billing 
    11. Valid ID 
    12. Profile Picture 
    13. Nickname 
  2. Financial Information
    1. E-wallet Transactions 
    2. Credit Card information (Full account number and CVV are not retained by SK LinkUp) 
  3. User Generated Content
  4. Device Information 

In any instance wherein personal data is requested for a specific reason that is not covered in this privacy policy, we will state the purpose of why we need such information, as well as the legitimate purpose for collecting it. Correspondingly, if there is any instance that we will process your data for any purpose other than for which it was originally collected, we shall provide clear explanation and description of said purpose, along with any other relevant information pertinent to the processing.

PURPOSE OF COLLECTION / HOW WE USE YOUR DATA

We may use your personal information for various purposes, including the following, and any other future purpose not mentioned herein shall be disclosed:

  1. Personal information is used for Account management, customer support, Know-Your-Customer examination/investigation or client identification related activities as required by law, and dissemination of App-related updates and notifications. 
  2. User generated content is collected for displaying user-generated content within the App and to enhance our service offerings. 
  3. Financial information is used to facilitate transactions, process payments, and administer your e-wallet account. 
  4. Device Information is used to analyze App utilization, address technical anomalies, and ensure account security. 
  5. Responding to any customer inquiries, requests, concerns or complaints 
  6. Detection, prevention, investigation, and prosecution of fraud or crime 
  7. Performance of activities, such as receiving marketing and promotion announcements, that you have consented to 
  8. Performing of other activities permitted by law 

Third-Party entities. In cases where sharing of information to third parties is necessary to carry out the business, SK LinkUp/DA5 will inform its stakeholders as to the extent of information that will be transferred to third parties. These entities shall have access to your information solely for the purpose of executing tasks on our behalf and are contractually obligated not to disclose or utilize it for any other intent. Moreover, no information shall be given to third parties that will defeat the purpose of this Agreement 

Legal Requirement. We may disclose your information if mandated by law or in response to a valid legal request.

HOW WE PROTECT YOUR INFORMATION

We implement reasonable and appropriate physical, technical, and organizational security measures to prevent the loss, destruction, misuse, or alteration of your information. We keep and protect your information using a secured server behind a firewall, encryption, and security controls to ensure our clients that we are committed to protecting their information from personal data breaches.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be periodically revised, and the most recent version will be posted on this page along with the updated date.

CONTACT US

All complaints in relation to the implementation for the use of the personal information of the client shall be forwarded to the Data Protection Officer (DPO) of Sultan Kudarat App. Moreover, personal issue(s) not in connection to the implementation of the used personal information of the client shall not be entertained. Should you have any concerns regarding this Policy or the processing of your information, you may contact us through our DPO at [email protected].