Last Updated: June 2020
Introduction and Overview
Information We Collect About You and How We Collect It
How We Use Your Information
How We Share Your Information
Cookies and Similar Technologies
How We Protect Your Information
Retention and Disposal of Your Information
Your Communications Preferences
Your California Privacy Rights
Additional Disclosures for Data Subjects in the EEA, the U.K., and Switzerland
Integration of Third-Party Platforms and Services
1. Introduction and Overview
Please note that when we are processing or interacting with your personal information on behalf of our customers, all questions and requests in relation to your personal information should be directed to the customer under whose direction we are providing our business services.
3. Information We Collect About You and How We Collect It
The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site, and information from third parties.
a) Information You Voluntarily Provide Us. The personal information that we collect from you may include:
Account Registration: information relating to the creation of an account on one of our Site, such as first and last name, email address, postal address, telephone number and/or a unique individual password;
Form Submissions: information that you provide by filling in forms that we make available on the Site, including contact information, company, title, and country in order to request white papers, register for events, or to request information for assistance;
Mailing List Sign-Ups: information relating to our newsletter sign-up page, including your email address;
Technical Support and Customer Service: information you provide when you report a problem with the Site or otherwise communicate with us by email, via our Site, by telephone, in writing, or through other means, including any records and copies of your correspondence that you provide;
Third-Party Contact Information: the name and email address of individuals to whom you send information via our Site; and
Job Applications: your name, email address, phone numbers, and any attachments you upload as part of applying for open positions posted on our Careers webpage or elsewhere.
b. Information We Collect Automatically. As you navigate through our Site or otherwise interact with Infocom, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Information About Your Use of the Services: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.
Device Information: if you access the Site through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
c. Information We Collect from Third Parties. When you interact with our Site or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.
4. Why We Collect Your Information
Infocom uses your information for business and commercial purposes, including to provide the customer experience, automation, and strategic services offerings that you request; to perform customer service functions; for security and fraud prevention; for marketing and promotional purposes; and to perform website analytics.
We may use the information we collect about you in the follow ways:
a. To Provide You Our Services: providing any services or products that you request or purchase in connection with the Site, such as to process your application, fulfill our contracted for services, and for billing and collection;
b. To Provide You with Service-Related Communications: contacting you regarding the administration of any features or functions of the Site you have registered to use, and notifying you about changes to our Site and services, our policies, terms or any products or services we offer or provide though our Site;
c. To Provide Customer Support or to Respond to You: providing you with notices about your account, including expiration and renewal notices, and responding to your questions or other requests;
d. To Send You Marketing and Promotional Emails: contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the services that you already use or the offerings that you have already purchased or inquired about, unless you have opted not to receive such information;
e. For Internal Use and Services Improvement: accumulating and reporting aggregate, statistical information in connection with the Site and user activity, including determining which features and services users like best to help us operate, enhance and improve our Site;
g. To Maintain Legal and Regulatory Compliance: processing personal information to pay our taxes, fulfill our business obligations, ensure compliance with employment and recruitment laws, or as necessary to manage risk under applicable law;
h. For Customization: saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Site); tracking your return visits to and use of our services; and/or otherwise customizing what you see when you visit and use the Site;
i. For Research Purposes: for research purposes and to provide reporting for external clients and business partners that does not contain personal information;
j. With Your Consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related products requested, with your permission or upon your direction; and
k. For Employment Purposes: processing job applications, including to communicate with you and to conduct applicant and employment-related statistical evaluation and record-keeping.
5. How We Share Your Information
a. Within Our Corporate Organization. We may share information between and among Infocom subsidiaries and affiliated companies for purposes of management and analysis, decision making, and other business purposes, such as processing orders and expanding service offerings;
b. When We Work with Service Providers. We may share your information with service providers that provide us with support services, such as website hosting, email and postal delivery, service delivery, analytics, and conducting academic research; [For SEO and analytics purposes]
c. Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. By engaging with Infocom or using our Site, you understand and agree to our assignment or transfer of rights to your personal information;
d. As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Infocom or our customers;
e. With Advertising and Marketing Partners. We may disclose your information, including non-directly identifiable cookie IDs and other device identifiers, with advertising and marketing partners, in order to advertise our services and to assess, develop, and provide you with promotions and special offers that may interest you; [We don’t do retargeting/remarketing campaigns]
f. With Your Consent. We may disclose your personal information for any purpose with your consent; and
g. When the Information Does Not Identify You. We may share your information in a way that does not directly identify you. For example, we may share information about your use of our Site in a manner that does not identify you, or we may combine information about the nature or frequency of your transactions with similar information about other people and share the aggregated information for statistical analysis and other business purposes.
6. Cookies and Similar Technologies
We and business partners we allow on our Site may use a variety of technologies to collect information about your device and use of our Site, including cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.
to understand and save users’ preferences for future visits;
to keep track of advertisements; and
to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You may be able to reject cookies, web beacons, entity tags and HTML5 local storage by adjusting the appropriate settings in your browser.
a. Browser Settings. Each browser is different, but many browsers have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.
Please note that if you turn cookies off, some features of the Site will be disabled, will not run as efficiently, or may not function properly.
b. Google Analytics. For more information, click here on how to opt-out of tracking technology from Google Analytics.
c. Interest-Based Advertising Opt-Outs. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain website where people can opt out of interest-based advertising from their members for a particular web browser. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal here or visit the NAI’s opt-out portal here. Residents of the European Union may opt-out of online behavioural advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting Your Online Choices website.
d. “Do Not Track” Technology. Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the website you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser “Do Not Track” signals, as there is no standard for how online services should respond to such signals.
7. How We Protect Your Information
Infocom protects your information using administrative, technical, and physical security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. For example, our Site are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. In addition, we use regular malware scanning, secure networks, and strive to ensure that information is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
We have also invested in the people, processes, and technology (e.g., tools and systems) to become ISO 27001 certified, having undergone independent, expert audits of whether our organization’s personal information is sufficiently protected, meeting ISO’s management system standards.
However, no system can be guaranteed to be 100% secure, and due to the inherent nature of the Internet, we cannot guarantee that data, including personal information, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices at all times.
8. Retention and Disposal of Your Information
When personal information is no longer needed, or in any event, after legal authority to retain it has expired, personal information will be destroyed, in accordance with local law and pursuant to procedures established in relation to the relevant Infocom system or process.
9. Your Communications Preferences and Account Management
In order to provide service to you, we may send you communications related to your transactions, security, or the administration of the Site. From time to time, we may also send you other messages or updates about Infocom, our Site, and our service offerings or other activities. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section below. Please note that if you opt out of receiving communications from us, we may still send you service communications such as emails about your account or the status of your application.
10. Notice to California Residents
This section applies solely to individuals who reside in the State of California. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information (as defined in California Civil Code Section 1798.140(o)), about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act, as amended (“CCPA”). Your “right to know” about personal information collected, used, and disclosed by Infocom includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you provide us.
In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:
Personal information categories listed in the CCPA
Internet or similar electronic network activity
Professional or employment-related information
a. How We Sell Your Information. In the preceding twelve months we have not sold personal information as that term is generally
understood. We do not sell personal information, but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” In the preceding 12 months, through our Site, we made available identifiers and inferences about you in such a way that, under the CCPA, may be defined as selling.
In addition to the “Cookies and Similar Technologies” section above’s description for opting out of interest-based advertising and controlling browser settings, California consumers may also use the Digital Advertising Alliance’s tool to send requests under the CCPA for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool in this link, or by downloading the DAA’s AppChoices mobile application opt-out in this link.
Infocom has no actual knowledge that it sells the personal information of minors under 16 years of age.
b. Your Rights.
Access to Specific Information and Data Portability Rights – Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:
The categories of personal information we have collected about you;
The categories of sources for the personal information we have collected about you;
Our business or commercial purpose for the information collection;
The categories of third parties with whom we share that personal information; and
The specific pieces of personal information we collected about you.
Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
Opting Out. As described in “How We Sell Your Information” above, California residents have the right to opt-out of having their personal information sold.
Non-Discrimination. We recognize and respect that you have the right to not receive discriminatory treatment by our business for exercising any of your CCPA rights.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to using the information listed in the “Contact Us” section below. Please note that in order to verify your request, we may require you to verify personal information that we already have on file for you or to provide additional information.
Use of an Authorized Agent to Submit a Request. Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.
c. Direct Marketing. If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes, if any. To request a notice, please submit your request as described in the “Contact Us” section below.
11. International Transfers
When you access or use our Site, your personal information may be processed in the United States or any other country in which Infocom, its affiliates, or its service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Site. For more information about the transfer of personal information from the European Economic Area, the United Kingdom, or Switzerland, please see Section 13 below.
12. Additional Disclosures for Data Subjects in the EEA, the U.K., and Switzerland
This section applies solely to individuals using or accessing our Site while located in the European Economic Area (EEA), the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time the individual’s personal information was collected.
We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country.
a. Our Relationship to You. Infocom is a data controller with regard to any personal information collected from individual accessing or using our Site, as may be the case with individuals requesting information about our offerings, viewing blogs and similar content, registering customer accounts, or applying for jobs with us. A “data controller” is an entity that determines the purposes and means for which any personal information is processed.
In contrast, when Infocom processes the personal information of our customers’ clients, end users, and others on behalf of and at the direction of our customers, Infocom is acting as a “data processor.” For all instances in which Infocom acts as a data processor, individuals should contact our customer—the data controller—with any inquiries or requests in relation to their personal information.
b. Legal Bases of Processing. For individuals located in the European Countries at the time their personal data is collected, we rely on legal bases of processing your information under Article 6 of the EU General Data Protection Regulation (GDPR). The following chart summarizes our purposes of processing from Section 4 above and the corresponding legal basis for doing so.
Sub-Section and Purpose of Processing
Legal Basis of Processing
(a) To Provide You Our Services;
(b) To Provide You With Service-Related Communications;
(c) To Provide Customer Support or to Respond to You;
(f) To Enforce Compliance With Our Agreements or Policies;
(k) For Employment Purposes.
Based on our contract with you or to take steps at your request prior to entering into a contract.
(d) To Send You Marketing and Promotional Emails;
(e) For Internal Use and Services Improvement;
(h) For Customization
(i) For Research Purposes.
Based on our legitimate interests. When we process your personal information for our legitimate interests we also ensure that we consider and balance any potential impact on you and your rights under data protection laws.
(g) To Maintain Legal and Regulatory Compliance.
Based on our legal obligations, the public interest, or in your vital interests.
(j) With Your Consent.
Based on your consent.
Please note that you may withdraw your consent at any time by modifying settings within your customer account online, or by contacting us as described in the “Contact Us” section below. Note that we will obtain your express consent before we share your personal information with any third parties for marketing purposes.
c. Recipients. As noted in the “How We Share Your Information” section above, Infocom may share your personal information with our service providers providing business services on our behalf, with our advertising and marketing partners, as part of corporate transactions, within our corporate affiliates, as required by law, and with your consent.
d. Your EEA Data Subject Rights. Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
Request correction of the personal information that we hold about you.
Request erasure of your personal information. This enables you to ask us to delete personal information where there is no good reason for us continuing to process it.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), or where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
Request the transfer of your personal information to another party, when possible.
Not be subject to automated decision-making producing legal or significant effects on an individual, which we do not engage in.
To exercise any of these rights, please contact us as set forth in the “Contact Us” section below and specify which GDPR privacy right(s) you wish to exercise. We must verify your identity in order to honor your request.
e. Transfers Outside of the European Countries. As noted in the “International Transfers” section above, your personal information may be transferred to, stored, or processed in a country other than the one in which it was collected, including the United States. It may also be processed by staff operating outside the European Countries who work for Infocom or for our third-party service providers on our behalf. In such cases, we will take appropriate steps to ensure an adequate level of data protection of the recipient as required under the GDPR.
f. Complaints. If you have any issues with our compliance, you have the right to lodge a complaint with a European Countries supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact Us” section below.
13. Children’s Privacy Rights
Infocom Site and services are not directed towards children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. If a parent or guardian becomes aware that their child under 16 provided our Site with personal information, please contact us immediately so that we may be take appropriate steps to promptly remove such information from our systems.
14. Integration of Third-Party Platforms and Services
15. Contact Us
6F LV Locsin Building
6752 Ayala Ave. cor. Makati Ave.
Makati City, Makati 1226