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THE RED WHISTLE DATA PRIVACY POLICY

The Red Whistle (TRW ORG. INC.) respects an individual’s right to privacy. Following Philippine data privacy laws, this Privacy Policy sets out and explains TRW’s policy in processing your personal information and sensitive personal information (Personal Data). In this regard, the term “processing” shall include, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of personal data. Processing may be performed through automated means, or manual processing, if the Personal Data are contained or are intended to be contained in a filing system.


 

1. What does this Policy Cover?

 

This policy:

• sets out the principles that TRW follows when processing Personal Data; and

• describes other important topics relating to an individual’s right to privacy.

 

TRW collects personal data, as needed in its activities, as needed and in compliance with the reportorial and management requirements of its funders. TRW informs you of the collection of such and explain the use and storage of such information every single time, and preserve them in the prescribed forms.

 

By communicating with TRW through email, by telephone or mobile device, in writing or by using any of TRW’s other services, including TRW’s website and social media accounts, or by providing Personal Data to TRW, Philippine law allows the limited processing of personal information, to be done in the manner described herein. You also expressly give your consent to the limited processing of your sensitive personal information, also to be done in the manner described herein.

 

The Personal Data which you provide to TRW now or from time to time or which you have provided to TRW previously will be processed, and/or continued to be processed by TRW, in accordance with this Privacy Policy. Any amendments, variations, or revisions, from time to time, will be brought to your attention.


 

2. Collection Use and Retention of Personal Data

 

(a) What TRW collects

 

The types of Personal Data that TRW may collect from individuals will depend upon the particular activity. The Personal Data collected by TRW may include but is not limited to the following:

 

  • personal information such as name, title, membership in organizations, field of work, sexual orientation, gender identity, and expression;

  • contact information such as residential address, phone numbers and email address;

  • such other information such as it may deem reasonably necessary in order to accomplish the above mentioned purpose;

  • camera or video footage of activities that may identify individuals as part of TRW’s documentation and reporting;

  • Sensitive Personal Information (SPI) - SPI refers to any personal information prescribed under the law as sensitive personal information which may include but is not limited to information pertaining to physical or mental health or condition, the proceedings for the commission or of any offense, opinions and other beliefs of similar nature. Your SPI shall only be collected by TRW upon your express consent and under such circumstances as authorized by law. With respect to any Personal Data about a third party, such as your spouse, sibling, relative and/or children, provided by you to TRW, you confirm that you have obtained the required consents to enable TRW to process such Personal Data for the purposes stated in this Privacy Policy.



 

(b) Collection, Purpose of Collection and Processing of Personal Data

 

Personal Data will, generally, only be collected and used for the primary purposes of:

 

  • communicating with clients, funders, stake holders or any other individuals relevant to the project;

  • processing, servicing or enforcing transactions and sending related communications;

  • identifying and verifying individuals that have been supplied with any TRW services;

  • administering or managing projects;

  • responding to an individual’s queries;

  • administering contests or surveys conducted by TRW or on TRW’s behalf

  • marketing (such as providing individuals with information about TRW’s services and promotional notices and offers)

  • processing any donation, purchase, application, inquiry or request;

  • ensuring activity security;

  • compliance with applicable laws and regulations of regulatory authorities and enforcement agencies;

  • administrative purposes such as billing, payment and debt collection;

  • responding to any claim and/or legal process;

  • improving TRW’s website.

 

(c) Retention of Personal Data

 

TRW shall retain and secure the Personal Data you provided for the period and manner defined in the project or operation or as prescribed by applicable law, whichever is longer.


 

3. Disclosure

 

We may disclose and share the Personal Data, subject to compliance with applicable laws and regulations, on a need to know basis, and in all cases only for legitimate conduct of project or operation purposes, as follows:

 

  • for the primary purpose for which it was collected; or

  • for purposes that a reasonable person will consider appropriate in the circumstances; or

  • where the individual has consented;

  • where permitted by the Data Privacy Act of 2012 or other applicable law or if required by law;

  • to TRW’s stake holders, funder, related, affiliate and/or associate organizations;

  • in any court of law or any relevant party in connection with any claim or legal proceedings, legal firms and/or advisors;

  • regulatory authorities and enforcement agencies; and

  • third party service providers, consultants, insurers, underwriters, auditors and advisors as well as their respective agents and/or contractors on a need to know basis;

 

TRW does not disclose your Personal Data for any secondary purposes unless your consent has been previously given, pursuant to the Data Privacy Act of 2012 or other applicable law.

 

TRW will not sell or license any Personal Data that it collects from an individual.

 

In situations where TRW processes Personal Data outside reasonable expectations, TRW will require your consent prior to processing.

 

4. Consent and Limiting the Use and Process of your Personal Data

 

You may choose whether or not to provide your Personal Data, and, if already provided, may choose to exercise your right to object, block, or remove such Personal Data as provided for under the Data Privacy Act of 2012.

 

If you would like to exercise your right to object, block, or remove your consent, kindly write to TRW at its registered address or email at contact@theredwhistle.com. In this respect, TRW may not be able to provide you with the services requested by yourself beyond the performance of contracts between you and TRW.

 

When you object, block or remove your consent, TRW shall no longer process your Personal Data, unless:

 

  • the Personal Data is needed pursuant to a subpoena;

  • the Processing is for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which you are a party; or

  • the Personal Data is being collected and processed to comply with a legal obligation.


 

5. Access, Rectification or Updating your Personal Data

 

You are entitled to certain rights in relation to the Personal Data, including the right to be informed of the processing of your Personal Data, to object to such processing, to access and correct your Personal Data, to request deletion thereof, and to lodge a complaint before the National Privacy Commission in case of violation of your rights as data subject.

 

You may send us in writing at TRW’s registered address or email at contact@theredwhistle.com to request access to, correct and/or delete any Personal Data that you have provided to us. Please be advised, however, that TRW cannot delete your Personal Data without restricting or removing our ability to effectively execute your transactions with, and relevant services, and products offered by and through TRW. TRW may not accommodate a request to correct and/or delete Personal Data if TRW believes the same would violate any law or legal requirement or cause the Personal Data to be incorrect.


 

6. Anonymity when dealing with TRW

 

TRW gives individuals the option not to identify themselves when dealing with it, where practicable.


 

7. Data Privacy Policy for Partners

 

Data Privacy is guaranteed and safeguarded as a matter of policy by TRW. This is in strict compliance with the provisions of the Data Privacy Act of 2012 or other applicable law. Data privacy should be strictly complied with. 

TRW enjoins its collaborators and partners to exercise the same confidentiality and the same level of care and compliance in handling any and all Personal Data in the course of collaboration or partnership with TRW.


 

8. Security of Personal Data

 

TRW have implemented technical, organizational, and physical measures designed to protect confidentiality, integrity, and availability of your Personal Data and secure such from unauthorized destruction, access, alteration, disclosure, fraudulent use and/or any other unlawful processing, as well as other natural and human dangers.



 

9. Other Important Information

 

TRW reserves the right to modify this Privacy Policy at any time will be communicated to you and those TRW are engage with on a collaborative or partnership project at the soonest possible and practicable opportunity. Your continued engagement after notification of any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

 

Any changes to this Privacy Policy in compliance with any governmental issuances and legal orders shall be accordingly reflected and deemed included in this Privacy Policy.

 

If we make any material changes to this Privacy Policy, we will notify you through the contact information provided or any other form of communication channels you have provided us with.


 

10. Further Information

 

If you have any queries or concerns about TRW’s privacy policy, please contact us.

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