All capitalized terms in this Data Privacy Policy shall have the same meanings ascribed to such terms in the Agreement.

1. Privacy Policy

This Privacy Policy outlines the policy of Innove Communications, Inc. (“We”) in relation to the collection, use, and protection of your personal information (collectively, the "Customer Data"). From time to time, we may update our Data Privacy Policy to reflect current changes. When we do so, we will notify you by posting it in the Site for your information and reference, and shall obtain your consent prior to the updates becoming effective.

2. Collection of Customer Data

As part of our continuing relationship with you, we collect your Customer Data, as may be applicable. Customer Data are either Personal Information or Non-Personal Information: 

(i) Personal Information is any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address and proof of identification. 

It also includes information about: 
(a) the services provided to you, such as, call/SMS details, location information, and certain information about your service plans and features, as required by law; 
(b) the location of your device whenever it is switched on, if you subscribe to location-based services, subject to coverage limitations; and 
(c) your use of our network, network performance experience, diagnostics, such as, signal strength, dropped calls, data failures, and other network performance issues to help us improve our network and quality of products and services, determine tailored content, and for other legitimate business purposes. 

(ii) Non-Personal Information is any information that does not identify you individually, and includes statistical and analytical data, and anonymous and aggregate reports. 

We may also request you to update your Personal Information from time to time. Should you be unable to supply us with the required Personal Information, we may be unable to provide you with your requested products and services, updates on our latest offerings, and you may be unable to participate in our events, promotions or other activities. 

When you use our Site and electronically communicate with us, depending on your settings, we may use cookies, web beacons, small data text files or similar technologies to identify your device and record your preferences, with your consent.

3. Use of Customer Data

We use your Customer Data to: 

(i) Enable you to register with and subscribe to our services; 
(ii) Provide you with your other subscribed products and services, including customer support; 
(iii) Enhance your customer experience and determine tailored content to meet your preferences and needs; 
(iv) Communicate relevant services and/or advisories to you; 
(v) Abide by any safety, security, public service or legal requirements and processes; and 
(vi) Process information for statistical, analytical, research and other related purposes. 

We use your Personal Information to the extent necessary to comply with the requirements of the law and legal process, such as a court order; to comply with a legal obligation; or to prevent imminent harm to public security, safety or order. 

We use your Non-Personal Information for statistical, analytical, and research purposes to create anonymous and aggregate reports. 

We may also use your Customer Data, or permit any member of our group of companies, which shall include our parent company and its subsidiaries to use your Customer Data, to develop and provide you with information about their products and services, which may be of interest to you. Please note, however, that we will not permit our parent company and its subsidiaries to contact you by electronic means (email or SMS) unless you have expressly consented to receiving such communications. You can change your preferences for receiving these communications at any time by calling our Customer Hotline at 09778269507. When required by our Data Privacy Policy and the law and before we use or process your Customer Data for any other purpose, we will ask for your consent. 

You may avail of our broadcast messages relevant to you through written correspondence, text messaging, internet, or other similar means of communication. You may also change your mind anytime and stop receiving them. 

We outsource or contract the processing of Customer Data to third parties, such as but not limited to, vendors, service providers, partners or other telecommunications operators, to fulfill any of the above purposes. They are only authorized to use Customer Data for such contracted purposes. They may have access to Customer Data for a limited time under reasonable contractual and technical safeguards to limit their use of such information. We require them to protect Customer Data consistent with our Data Privacy Policy.

4. Protection of Customer Data

We respect your privacy. We take paramount care in protecting your Customer Data. As such, we secure and protect your Customer Data with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the law. 

As communications over the internet may not be secure, we make reasonable and appropriate security arrangements and measures that use a variety of physical, electronic, and procedural safeguards to protect Customer Data. For example, we protect and keep your information submitted through our Site safe using a secured server behind a firewall, encryption, and other appropriate security controls. When you enter your information through our Site, we encrypt that information using Secure Sockets Layer (SSL) technology so that it cannot be read as the information travels over the internet. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our system and unauthorized alteration, disclosure, or destruction of information we hold. 

We only permit your Customer Data to be accessed or processed by our authorized personnel, contractors and contractors who hold such information under strict confidentiality. We restrict access to information to our employees, contractors, and agents who need to know such information in order to process it for us, who are subject to strict contractual and technical safeguards and are accountable if they fail to meet these obligations. 

Furthermore, we only give you or your authorized representative access to your Personal Information. We do not sell your Personal Information to anyone for any purpose. We also do not use or share your Personal Information with content and/or information providers without your prior request or consent. Personal Information will only be disclosed to third parties in accordance with this Privacy Policy. 

We keep our records as accurate as possible. If your Personal Information is wrong, we give you ways to update it. Once you have registered as our customer, you may access your account details and correct your Personal Information by contacting our Customer Service Representative. 

We keep your Personal Information in our records, as may be applicable, while you are a customer, or as long as it is necessary to fulfill the purpose for which it was collected, or while it is needed by us for business, tax, or legal purposes. When disposing of your Personal Information, we take reasonable measures to ensure that it is done properly and is not accessible to the public. 

We are not responsible for information, content, application, product or service that we do not provide. But because we care for you and protect you, we take measures to fight spam, fraud or any unauthorized messages that traverse our network. 

Photo or video voyeurism, including the publication or broadcast or transmission through our network of any sexual act or any similar activity without the consent of the person involved and under circumstances in which the person has a reasonable expectation of privacy, is prohibited and unlawful with corresponding penalties under the law. 

Child pornography is also prohibited and punishable by law and our network shall not be used in any manner for the storage, transmission, or dissemination of materials containing child pornography. We will report any instances of such activity that we become aware of to the proper authorities as required by law.

5. High-Level Privacy Principles

Purpose and Use 
We will limit the access, collection, sharing, disclosure, and further use of your Personal Information to meeting legitimate business purposes as outlined in this Data Privacy Policy or to otherwise meet legal obligations. 

Data Minimization 
We will collect, access, and use only the Personal Information necessary to meet legitimate business purposes as outlined in this Data Privacy Policy. 

Respect User Rights 
You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Information. 

Security 
Personal Information will be protected, using reasonable safeguards appropriate to the sensitivity of the information. 

Accountability and Enforcement 
All responsible persons will be accountable for ensuring that these principles are met. You have the right to lodge a complaint before the relevant government agencies, including the National Privacy Commission of the Philippines.

6. Contact Us

For any questions or concerns, you may contact our Privacy Officer as follows: 

Anton Bonifacio 
Email Address: datamanager@innove.com.ph 
Mobile Number: +63 917 818 0026