Last updated: October 04, 2019
Philippine Digital Asset Exchange (“PDAX” or the “Company”) is committed to secure its clients’ privacy and to ensure that personal information is handled in accordance to the requirements sent by law. This statement shall explain how the Company will collect, use, and share the personal information that its clients disclosed with PDAX during transacting with the company or while using its webpage.
Who we are
PDAX shall refer to Fyntegrate Inc., a corporation duly registered and organized under Philippine laws, its directors, officers, employees, representatives, legal advisers, subsidiaries, affiliates, and other related entities, and their directors, officers, employees, representatives, legal advisers.
What Personal Information is Collected and Processed
Personal information is any information, whether recorded in a material form or otherwise, 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.
This includes sensitive personal information which is personal information about one’s:
- Individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
- Health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
- Information issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
- Specifically established by an executive order or an act of Congress to be kept classified.
PDAX collects personal information that is material and relevant to your account application, necessary to conduct business, and to provide better products and services.
Specifically, PDAX collects the following information:
- Personal Details
- Employment Background
- Name of company
- Address of company
- Contact details of company
- Title or designation of position held
- Electronic Data
- IP Address
- Operating System, and
- Other machine identifiers
- Customer Service Feedback
During the use of this website and other electronic platform, PDAX may collect other personal information provided by your device such as, but not limited to, IP address, operating system. and other machine identifiers
PDAX may likewise utilize web analytics tools such as cookies and also collect, utilize, and retain comments made known via customer service feedback or through any other engagements you have with the Company, its employees, and authorized representatives.
Utilization of Personal Information
- The implementation and handling of PDAX account, customer profiling, risk assessment,
- Compliance with Anti-Money Laundering Act, its implementing Rules and Regulations, and pertinent circulars released by Bangko Sentral ng Pilipinas,
- Compliance with other laws, rules and regulations that may be enforced, and data sharing with authorized third party service providers.
In addition to the abovementioned purposes, the information collected shall likewise be processed for the following purposes:
- To meet the lawful objectives of the business of the Company;
- To facilitate registrations with the Company’s platform and its services;
- To manage and operate the Company’s platform;
- To provide better products and services;
- To establish, exercise, or defend legal claims; and
- To fulfill any other purposes directly related to the above-stated purposes.
Personal Information Disclosure
During your transaction with PDAX or the use of this website, PDAX may disclose your personal information to the following
Third persons and entities engaged by the Company to facilitate account administration and/or implementation;
PDAX‘s parent company, subsidiaries, affiliates, or such other related companies, to assist in the collection, recording, organization, storage, modification, retrieval, use, consolidation, blocking, erasure, destruction of data, administration, implementation, and servicing of accounts, other products, and facilities;
Philippine or foreign government regulatory and/or enforcement agencies for reports relating to your account history including, but not limited to, your past dues, limit breaches, covered and suspicious transaclions, and other reports ordered by such regulatory/enforcement agencies;
Third parties or entities engaged by PDAX, its parent company, subsidiaries, affiliates, or such other related companies, under the duty of confidentiality, to offer other products and services;
Third-party service providers or the like entities engaged by the PDAX to assist in the administration and/or maintenance of its products, facilities, and services;
Government bodies or agencies having regulatory supervision over PDAX; and
Such other persons or entities that PDAX may deem to have authority or right to receive disclosure of information such as, but not limited to, the following:
- Payment channels;
- Banks and/or remittance companies; and
- Outsourcing agents for the completion of the KYC Policy and other functions which may be outsourced such as, but not limited to, printing, processing, and distribution of statement of accounts. When the processing of your personal data is outsourced by the PDAX to a third party, the processing will be subject to written agreements between the Company and the third parties processing the data. These written agreements specify the rights and obligations of each party and will provide that the third party has adequate security measures in place and will only process your personal information on the specific written instructions of the Company.
The Company may also transfer your personal information to third parties as required by law or legal instrument, to protect the Company’s rights or assets, to facilitate acquisition or disposition of the Company’s businesses, and in emergencies where the health or safety of a person is endangered.
The Company will not sell, rent, share, trade, or disclose any of your personal data to any other party without your prior written consent, with the exception of entities within the Company and any third-party service providers which the Company has engaged, whose services necessarily require the processing of your personal data.
Retention Period for Personal Information
The Company shall retain or store the information collected and/or processed for as long as the purposes for which they are being processed have not been satisfied. Upon termination of your account, the Company shall retain personal information collected seven (7) years from such termination.
The Company will retain and use your Personal Information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements:
- Hard copies of lhe forms you submitted, as well as all records that are relevant to the maintenance of your account, may be stored in the Company premises in a secure cabinel or in an off-site warehouse managed by a third-party service provider.
- Forms and documents which contain your personal information will be digitized and stored on the Company’s information management system hosted by the Company on-site or in the premises of an authorized third- party service provider.
- The Company shall ensure, using contractual and other reasonable means, that the third-party service provider implements proper safeguards to ensure the confidentiality, integrity, and availability of the personal data processed, prevent its use for unauthorized purposes, and comply with the requirements of the DPA, its Implementing Rules and Regulations, and other applicable laws for processing of personal data, and other issuances of the NPC.
PDAX has put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use the Information we collect and process in the correct and proper manner. These safeguards vary based on the sensitivity of the Information that we collect, store, and process.
Personal Information of Other Individuals
You understand, agree and warrant that any personal information regarding other individuals disclosed with PDAX is obtained with appropriate consent, and was obtained for the use, storage, and processing of their information for compliance with regulatory requirements, and for the application and administration of your account.
You further undertake to furnish PDAX with proof of your authority to give the said consent of other data subjects with respect to disclosure and processing of their personal information for the legitimate purposes of PDAX.
Rights of a Data Subject
Under the Data Privacy Act, data subjects have the right to:
- Be informed that your personal information will be collected and processed;
- Be furnished information in relation to the processing of your personal information;
- Reasonable access to your personal information held by PDAX;
- Dispute any error in your personal information and have it corrected,
- The erasure or blocking of your personal information from PDAX’s system if said information is incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or no longer necessary for the purposes for which they were collected,
- Object to the processing of your personal information,
- Lodge a complaint before the National Privacy Commission; and
- Damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal information.
Data Privacy Officer
Any questions regarding Data Privacy may be coursed through PDAX‘s Data Protection officer.
For more information regarding Data Privacy Act, you may visit privacy.gov.ph