This policy explains how the Operator ("we", "the Provider") collects, uses, and protects personal data in connection with the Fiduciary Service. We are committed to processing personal data lawfully, fairly, and transparently under the Philippine Data Privacy Act of 2012 (RA 10173), its IRR, and applicable NPC issuances.
Data controller: [REGISTERED ENTITY NAME], [ADDRESS]. Data Protection Officer: [DPO NAME / EMAIL]. NPC registration: [REG NUMBER — TO BE SET].
| Category | Examples | Purpose |
|---|---|---|
| Account data | name, work email, institution, role | provisioning, billing, support |
| Authentication data | device identifiers, passkey public keys, session tokens | strong customer authentication |
| Usage data | API call metadata, timestamps, audit events | security, rate limits, audit ledger |
| Billing data | plan, payment references (via processor) | subscription management |
We do not store full payment card numbers; card processing is handled by our payment processor. Authentication uses passkeys and one-time challenges; we store public keys, never private keys or passwords in plaintext.
For our own account, billing, and security data, we act as a controller. For personal data that a Customer institution submits about its own end-users, we act as a processor on that Customer's documented instructions, governed by our Data Processing Agreement.
Account data is retained for the life of the account plus any period required by law. Audit-ledger events are retained for the statutory record-keeping period applicable to the Customer's use case. You may request deletion subject to legal retention obligations.
We share personal data only with sub-processors necessary to run the Service (e.g., cloud hosting, email delivery, payment processing, and — where enabled — a licensed KYC/AML screening provider). A current sub-processor list is available on request. We do not sell personal data.
Under RA 10173 you have the rights to be informed, to access, to object, to rectification, to erasure or blocking, to damages, and to data portability. To exercise them, contact our DPO at [DPO EMAIL]. You may also lodge a complaint with the National Privacy Commission.
We apply organizational and technical safeguards including post-quantum signed audit records, encryption in transit, phishing-resistant authentication, least-privilege access, and a hash-chained tamper-evident ledger. No system is perfectly secure; in the event of a breach we follow our incident-response and NPC notification obligations.
Where data is processed outside the Philippines (e.g., global cloud regions), we apply appropriate safeguards consistent with RA 10173 and NPC guidance.
We may update this policy; material changes will be notified. Contact: [PRIVACY CONTACT EMAIL — TO BE SET].
