This Privacy Policy explains how MARUBENI PHILIPPINES CORPORATION (“Company“, “we“, “our“, or “us“) shall handle and process personal data that we collect online, through our websites and applications, and through our offline interactions with you (collectively, the “Company Services”).
This Privacy Policy applies whenever personal data is collected, held or processed by the Company, at a time when the data subject or individual is a citizen or resident of the Philippines, the collection and processing is being done in the Philippines, or the collecting or holding entity has ‘links to the Philippines’ within the meaning of Republic Act No. 10173, otherwise known as the Philippine Data Privacy Act of 2012 (“DPA”).
Our Business
The Company services clients with its extensive global network of human, financial and technological resources. Its operations encompass domestic, import, export and offshore trade, turn-key project management, risk management, finance, logistics, Build-Operate-Transfer projects, joint ventures and investments in various industries such as telecommunications, information technology, power, agriculture, transportation, construction, metals, and other similar services.
Data Controller and Processor
When processing personal data of data subjects who are Philippine citizens or are in the Philippines or in connection with the Company’s Services, the Company will act either as personal information controller (“PIC”) or personal information processor (“PIP”). When the Company determines the purpose and the manner of processing of your personal data, the Company is deemed to be a PIC. The Company will apply a similar approach to protecting your data whether acting as a PIP or a PIC.
Processing of personal data
We will collect, use or disclose your personal information where you have provided us with express consent, and/or for the purposes permitted under applicable laws, for instance, to comply with legal or regulatory obligations. We will process, store, collect and/or disclose your sensitive personal information when you have given your express consent, when it is expressly authorized by Philippine laws and regulations, or if the same is otherwise allowed under the DPA, which includes the Implementing Rules and Regulations of the DPA and the issuances of the National Privacy Commission (“NPC”).
Categories of personal data which we may collect
We may collect and process your personal information and data, including your sensitive personal information, depending on what product and service you use, which information shall include, but not be limited to, the following:
- Contact information (name, contact information such as email address, mailing address, and phone number)
- Biographical and demographic information (such as date of birth, age, gender, marital status, ethnicity, residence, nationality, disabilities)
- Employment or work history, educational attainment, and salary information (including information that may be indicated in your CV, resume or business card)
- Government-issued identification
- Payment-related information (payment method and details, financial information, payment history and correspondence, account information)
- Traffic data (IP addresses, cookie data, device identifiers, and similar device related information)
- Statistical and analytical data, demographic and information and feedback voluntarily submitted in surveys
- Health and medical information
- Criminal background check information
Purposes of processing of personal data
How the Company uses your personal data depends on how you interact with or avail of the Company Services. Generally, The Company may use your information for the following purposes:
- For HR management and administration (job recruitment, job application management, administration and payroll, etc.), and for IT and communications purposes (provision of IT and information processing support, data storage, HR and payroll administration, etc.)
- To operate the “Marubeni Hotline”, or for processing, analyzing, recognizing, resolving and/or otherwise addressing any issues or circumstances identified in reports made to or through the hotline, or for human resources planning, management and processing.
- For managing customers’ accounts, taking payments, monitoring usage, marketing and public relations, marking and improving recommendations, communications with customers and customer services, providing services to customers, compliance with legal and regulatory requirements, and compliance with shareholder requirements.
- For administration of vendors, facilitating communications with vendors, service providers, and business partners, business operations, and compliance (complying with applicable legal and regulatory requirements).
- For Personal Information Processors” (PIP) which the Company engages to perform and provide certain functions or services for your benefit; specifically, the following: (1) Payroll Service Provider; (2) Annual Physical Examination Service Provider (Medical Clinic); (3) Group Health & Life Insurance Provider; and (4) Retirement Fund Trustee Bank and Independent Actuary.
The Company may also use your personal data for other purposes disclosed to you from time to time.
Cookies Policy for our websites
Definition of Cookie
A cookie is a small text file that a web server places on the computer or device of a user or website visitor. Cookies are typically used to improve the navigation of a user or visitor through a website but may also be used to identify the user, track the path of the user or visitor through the website, identify repeat visits to the site by the same user or visitor or device of that same user or visitor, or analyze user behavior.
How and why we use Cookies
The Company uses cookies for a better understanding of how users or visitors interact with our website and applications for the improvement of the Company Services, for advertising, and for analytics purposes.
The Cookies we use
Our website uses first party cookies, which are cookies that are only set by our website only. Our website also uses third party Cookies, which are cookies set by third parties and may be used for advertisement and analytics purposes by such third parties.
Disclosure of your personal data
We will share your personal data to third parties or other affiliated companies, such as Marubeni Corporation, for the purposes mentioned in this Policy, and only with your express consent, including in the following cases:
- If the third party or affiliate receiving your personal data will act as a PIC, or will otherwise have control over, or will be able to determine the purpose and the manner of, the processing of your personal data; or
- If we will share your personal data to advertising and remarketing networks, or to third parties or affiliated companies who will otherwise be engaged in direct marketing operations, or to third party vendors or service providers who will provide services or assistance to the Company.
Cross-border transfers
It is likely that personal data about you will be collected, held and processed in countries outside the Philippines. It may also be disclosed to persons in other countries in the circumstances described in this Policy.
Security Measures
We maintain reasonable and appropriate technical, physical, and organizational security measures to protect the security of your personal data against loss, misuse, unauthorized access, disclosure, or alteration.
Data Protection Officer
The Company has designated the General Manager assigned to the Office of the President as the Company’s Data Protection Officer (“DPO”) for the Philippines. For any data privacy-related concerns, you may contact the Company’s DPO, whose contact details are as follows:
| Title or designation | General Manager, President’s Office |
| Address | 8th and 9th Floors, L.V. Locsin Building, Ayala Corner Makati Avenues, Makati |
| Telephone number | +632-88190211 |
| Email address | dee-j@marubeni.com |
Your rights
You have rights as a data subject in accordance with applicable law. If you would like to exercise any of these rights, please contact our DPO at the contact details indicated above. For your information, you have the following rights in relation to your personal data:
- Right to access. You have the right to request access to the personal data we hold about you and to check that we are lawfully processing it.
- Right to correction. You have the right to request the correction of any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide to us.
- Right to object. You have the right to object to the processing of your personal data where we are relying on your consent or a legitimate interest and you object to the processing of your personal data on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object in case of any significant change to this Policy, or where we are processing your personal data for direct marketing purposes.
- Right to erasure or blocking. You have the right to request for the erasure, blocking or withdrawal of your personal data, where you believe that your personal data or our processing thereof (a) is incomplete, outdated, false or unlawfully obtained, (b) used for unauthorized purposes, (c) no longer necessary for the purposes set out in this Policy or for other purpose(s) disclosed to you, or (d) is prejudicial to you.
- Right to data portability. You have the right, in certain cases, to request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
- 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., We encourage you to reach out to us through our contact information indicated in this Policy in the event that you feel that any of your rights as a data subject under applicable law has been violated.
Please note that we may, in accordance with applicable law, charge you a reasonable fee to process your request. If so, we will inform you of the fee before processing your request. We will comply with your request within 30 days after receipt of your request and upon submission of the necessary supporting or additional documentation. In case, however, that your request is complex or numerous, this period may be extended for another 15 days provided that we will notify you of the reason for such extension.
Data retention
Your personal data will not be held for longer than is necessary for the purposes described above or as disclosed to you from time to time, except to the extent this is required by applicable legal requirements. In any event, personal data will never be retained for longer than is allowed by applicable law.