Purposes and Uses of Personal Data 

14. We may collect and use your personal data for any or all of the following purposes, which in any event shall not extend beyond what is reasonable for us to provide you with our Services: 

1. 1. to perform our obligations in the course of or in connection with the provision of our Services as requested by you; 
   2. to register you as a Registered User; 
   3. to verify your identity; 
   4. to send you emails in relation to our Services; 
   5. to enable you to engage with Client Organisations, and vice versa, through our Services; 
   6. to facilitate engagement events involving Registered Users and Client Organisations; 
   7. to obtain, respond to, handle, and process queries, requests, applications, complaints, and feedback from you; 
   8. to manage your relationship with us (including notifying you about changes to our Policy or Terms of Service); 
   9. to administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data); 
   10. to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority; 
   11. for any other purposes for which you have provided the information; 
   12. for any other incidental business purposes related to or in connection with the above; and 
   13. to transmit to any unaffiliated third parties including our Third Party Service Providers and agents, or relevant governmental and/or regulatory authorities, whether in the Philippines or abroad, for the aforementioned purposes.

15. The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you). 

16. Aggregated data
    We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. For example, we may use such aggregated data for data analytics purposes to improve our Website, Services, marketing, customer and User relationships and experiences. 

Such aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. In the event such aggregated data is combined with or connected to your personal data such that it can directly or indirectly identify you, we will treat such combined data as personal data, which will be used in accordance with this Policy.

Disclosure of Personal Data 

17. We may disclose your personal data: 

1. 1. where such disclosure is required for performing our obligations in the course of or in connection with the provision of our Services as requested by you; 
   2. to Client Organisations, where such disclosure is in relation to the provision of our Services; 
   3. to Third Party Service Providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 14 above for us; 
   4. to other Registered Users participating in common engagement events, or 
   5. to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 

18. Disclosure to Client Organisations
    By default, your Talent Profile is open, meaning that the data within will be disclosed to Client Organisations. You may request to hide your Talent Profile so Client Organisations can only view limited information about you. 

Client Organisations may be able to see or search Registered Users by name, contact information, country, job title, function, preferences, year of graduation, and such other search criteria as we may reasonably introduce. 

19. Disclosure to Third Party Service Providers
    Our Website and certain Services we provide require the services/products of Third Party Service Providers, who may require you to disclose your personal data to them through our Website. 

As we use an external mailing service provided by Third Party Service Provider(s) to deliver you our emails, we may disclose your name and email address to the said Third Party Service Provider(s). We will, however, insofar as it is commercially reasonable, contractually ensure that your data and/or information is protected by such Third Party Service Provider(s) in accordance with the PDPA or any other legislation.

By using our Services, you expressly acknowledge and consent to the disclosure of your personal data to the Third Party Service Providers for the purposes listed above in Clause 14. 

20. Disclosure upon Sale of Business
    If the Company’s business is sold, transferred or merged with another business, your personal data or information may be disclosed to our advisers and any prospective purchasers and their advisers, and the new owners may collect, use or disclose your personal data in the same way as set out in this Policy. 
21. We will not use any of the content you create within our Website and/or during the course of using our Services for external marketing purposes unless your prior consent has been obtained. 

Transfer of Personal Data Overseas 

22. In order to provide you with our Services, we and/or our Third Party Service Providers may need to transfer your personal data to countries outside of the Philippines. For example, if you join a chat on our Website while you are out of the Philippines, your data will need to be transferred to servers outside the Philippines. By visiting our Website, registering as a Registered User, or using our Services, you consent to the transfer of your personal data to countries outside of the Philippines. In the event such transfers are necessary, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable law(s) and regulation(s). 

Protection of your Personal Data 

23. To safeguard your personal data from unauthorised access, collection, use, disclosure, Processing, copying, modification, disposal, accidental loss, or similar risks, we have put in place appropriate security, administrative, physical and technical measures, such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us. 
24. We also limit the disclosure of personal data both internally and to our agents, contractors, Third Party Service Providers and other third parties to a need-to-know basis. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and in accordance with their own privacy policies. 
25. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 
26. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. 

Retention of your Personal Data 

27. We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws, including satisfying any legal, accounting, or reporting requirements. 
28. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. 

Access and Correction [and Deletion] of your Personal Data 

29. Subject to the exceptions referred to in section 21 of the PDPA, you have the right to request access to a copy of your personal data which we hold about you or information about the ways in which we use or disclose your personal data. 
30. You also have the right to request for the correction or update of any personal data of yours which we hold. We generally rely on personal data provided by you. We want to ensure that your personal data is current, complete and accurate. Please update us if there are changes to your personal data. 
31. If you are a User from the EU, you may also have the following rights under the GDPR, within and subject to the conditions provided in the GDPR: 

1. 1. to request that we erase your personal data; 
   2. to request that we restrict the processing of your personal data; 
   3. to object to our processing of your personal data; 
   4. to request that we transfer the data that we have collected from you to another organisation, or directly to you; 
   5. to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you. 

32. If you wish to make (a) an access request; (b) a correction request; or (c) deletion request, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. 
33. We will respond to your request as soon as reasonably possible or practicable. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of receiving your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). 
34. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also need to verify the accuracy of any new data you provide us. 
35. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if (a) your request unreasonably interferes with our operations due to its repetitious or systematic nature; (b) the burden or expense of providing access would be unreasonable to us or disproportionate to your interests; (c) the information is does not exist, cannot be found, or is trivial; or (d) your request is otherwise frivolous or vexatious. Alternatively, we may refuse your request in these circumstances.

Contact Us 

36. You may contact our Data Protection Officer if you have any enquiries or feedback on this Policy, our personal data protection policies and procedures, or if you wish to make any request, in the following manner: 

• SeeMeSOL Inc
• 4th Floor, Keyland Building  
• 114 Valero Street
• Salcedo Village, Bel-Air, Makati City 
• dpo@seemesol.com