Effective Date: Dec 1st, 2013. Last updated: Jan 8th 2018.
Personal information simply means any information or data that can be used to distinguish, identify or contact you.
Why we collect personal information and how we use it
Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customized experience. We may use collect, use, process and examine your personal information when reasonable, relevant and necessary to:
- Provide Coins.ph services and customer support timely and efficiently at your request;
- Process transactions and send notices about your transactions;
- Resolve disputes, collect fees, and troubleshoot problems;
- Prevent potentially prohibited or illegal activities;
- Customize, measure, and improve Coins.ph services and the content and layout of our website and applications;
- Deliver direct marketing, service update notices, and promotional offers based on your communication preferences;
- Compare information for accuracy and verify it with third-parties; and
- Monitor the quality and security of the network and train our staff.
When we can, we aggregate and anonymize this information such that you are never identified as an individual. For the avoidance of doubt, with this practice we try to present information in segments or categories and remove any personally identifiable information from the data.
We will not sell or rent your personal information to third-parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize Coins.ph services, content and advertising.
How we collect information about you
When you visit the Coins.ph website or use Coins.ph services or Coins.ph application, we collect information sent to us by your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, unique identifier, name and type, operating system, location, mobile network information and standard web log information such as your browser type, traffic to and from our site, and the pages you accessed on our website.
Before permitting you to use Coins.ph services, we may require you to provide additional information we can use to verify your identity or address or manage risk, such as your date of birth, social security number or other information. We also collect your contact details like billing address, telephone number, mobile phone number, email address. We may also obtain information about you from third-parties such as credit bureaus and identity verification services. You can check what we know about you by making a request to the Coins.ph Data Privacy Officer through the contact details provided below.
When you use Coins.ph services, we collect information about your transactions and your other activities on our website and we may collect information about your computer or other access device for fraud prevention purposes.
In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with our website or Coins.ph services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity that may affect the availability of Coins.ph services.
Finally, we may collect additional information from or about you in other ways such as interactions with our customer support team.
When you access our website or content or use our application or Coins.ph services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:
- Recognize you as a Coins.ph customer;
- Customize Coins.ph services, content, and advertising;
- Measure promotional effectiveness; and
- Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as “Flash cookies,” to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.
How we protect and store personal information
Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.
We store and process your personal information on our computers in Asia-Pacific and elsewhere in the world where Coins.ph facilities or our service providers are located, and we protect it by maintaining physical, electronic and procedural safeguards. We use computer safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and files. And we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
In our offices we have organized departments so that those persons who are authorized to view, monitor, analyze, and manage personal information are isolated from other employees.
Rights of Coins.ph customers
Filipino citizens and residents that are customers of Coins.ph irrespective of current jurisdiction have been guaranteed certain privacy and information security rights under the Data Privacy Act 2012. Coins.ph adheres to rights expressly stated in the Act where applicable.
How we share personal information to fulfill Coins.ph services
To process your payments we may securely share some of your personal information with the person or company that you are paying or that is paying you. This includes your contact information; date of sign-up; the number of payments you have received from verified Coins.ph users; and, whether you have verified control of a bank account. We manage these data sharing activities by the guidelines of our information security policy as well as this policy. In addition, this and other information may also be shared with third-parties when you use these third-parties to access Coins.ph services. Unless you have agreed to it, these third-parties are not allowed to use this information for any purpose other than to facilitate your transactions using Coins.ph services.
If you are buying goods or services and pay using Coins.ph, we may also provide the seller with your shipping and confirmed billing address to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide the buyer with the seller’s address so that any goods can be returned to the seller.
We work with third-parties, including merchants, to enable them to accept or facilitate payments from or to you using Coins.ph. In this case a third-party may share information about you with us, such as your email address or mobile phone number to inform you that a payment is sent to you or when you attempt to pay that merchant or through that third-party. We use this information to confirm that you are a Coins.ph customer and that bitcoin as a form of payment can be enabled, or where a payment is sent to you, to send you notification that you have received a payment. Also, if you request that we validate your status as a Coins.ph customer with a third-party we will do so. Please note that merchants you buy from and contract with have their own privacy policies, and Coins.ph cannot be held responsible for their operations, including, but not limited to, their information practices.
How we share personal information with other parties
We may share your personal information with:
- Service providers under contract who help with parts of our business operations such as fraud prevention, bill collection, marketing and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Financial institutions with which we partner.
- Law enforcement, government officials, or other third-parties when:
- We are compelled to do so by a subpoena, court order or similar legal procedure; or
- We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss;
- We report suspected illegal activity or to investigate violations of our User Agreement.
- Other third-parties with your consent or direction to do so.
Coins.ph will not sell or rent any of your personal information to third-parties for their marketing purposes and only shares your personal information with third-parties as described in this policy. If there is an actionable breach of your personal information, we will notify you within 72 hours.
If you establish a Coins.ph account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Coins.ph website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
We will notify you of material changes to this policy by updating the ‘Last Updated’ date at the top of this page. It is recommended that you visit this page frequently to check for changes.
How we protect your information
- We keep and protect your information using a secured server behind a firewall, encryption and security controls;
- We restrict access to your information only to qualified and authorized personnel who hold your information with strict confidentiality;
- We undergo regular audit and rigorous testing of our infrastructure’s security protocols to ensure your data is always protected; and
- We let you update your information securely to keep our records accurate. We will retain your personal data throughout the subscription of our products and services, and for a maximum period of five (5) years after account closure, in accordance with Philippine AML laws and regulations, as they might be amended from time to time.
How you can access or change your personal information
You have certain rights in relation to your personal data under the Data Privacy Act of 2012, which includes the right to object to processing, the right to access your data, the right to amend or rectify inaccurate data, and the right to erasure or blocking of data.
How you can contact us about privacy questions
If you have questions or concerns regarding this policy, you may contact us on our support page or by contacting directly our Data Privacy Officer at firstname.lastname@example.org.