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1. INTRODUCTION
1.1 Welcome to the Bronco Online Shop run by SNSPI and its affiliates and affiliates (individually and collectively, "BRONCO", "we", "us" or "our"). SNSPI takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our BRONCO website (the "Site") (we refer to the Site and the services we provide as described in our Site collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully. If you have any questions regarding this information or our privacy practices, please see the section entitled "Questions, Concerns or Complaints? Contact Us" at the end of this Privacy Policy.
1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us, visiting our website, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEBSITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our website. We reserve the right to amend this Privacy Policy at any time.
2. WHEN WILL SNSPI COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
(a) when you register and/or use our Services or Site, or open an account with us;
(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form; (c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
(c) when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms, and emails;
(d) when you use our electronic services or interact with us via our application or use services on our website. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
(e) when you carry out transactions through our Services;
(f) when you provide us with feedback or complaints;
(g) when you register for a contest; or
(h) when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 When you visit, use or interact with our mobile application or the Site, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information we collect may include, without limitation, your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), and the pages you visit on our website and mobile applications and the times of visit. We may collect, use disclose and/or process this information only for the Purposes (defined below).
2.3 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc.. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.
3. WHAT PERSONAL DATA WILL SNSPI COLLECT?
3.1 The personal data that SNSPI may collect includes but is not limited to:
• name;
• email address;
• date of birth;
• billing address;
• payment information;
• telephone number;
• any other information about the User when the User signs up to use our Services or website, and when the User uses the Services or website, as well as information related to how the User uses our Services or website; and
• aggregate data on content the User engages with.
3.2 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing about it. Further information on opting out can be found in the section below entitled "How can you opt-out, remove, request access to or modify information you have provided to us?" Note, however, that opting out of us collecting your personal data or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services. For example, opting out of the collection of location information will cause its location-based features to be disabled.
4. SETTING UP AN ACCOUNT
In order to use certain functionalities of the Services, you will have to create a user account which requires you to submit certain personal data. When you register and create an account, we require you to provide us with your name and email address as well as a user name that you select. We also ask for certain information about yourself such as your telephone number, email address, shipping address, photo identification, bank account details, age, date of birth, gender and interests. Upon activating an account, you will select a user name and password. Your user name and password will be used so you can securely access and maintain your account.
5. VIEWING WEB PAGES
As with most websites, your computer sends information which may include personal data about you that gets logged by a web server when you browse our Site. This typically includes without limitation your computer's IP address, operating system, browser name/version, the referring web page, requested page, date/time, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.
6. COOKIES
6.1 We may from time to time implement "cookies" or other features to allow us or third parties to collect or share information that will help us improve our Site and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services or website are used or visited, by how many people and to track movements within our website. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and pages you have viewed. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor website usage.
6.2 You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our Site or the Services.
7. VIEWING AND DOWNLOADING CONTENT AND ADVERTISING
As with browsing web pages, when you watch content and advertising and access other software on our Site or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your computer sends us information on the content, advertisement viewed and/or software installed by the Services and the website and time.
8. COMMUNITY & SUPPORT
8.1 We provide customer service support through email, SMS and feedback forms. In order to provide customer support, we will ask for your email address and mobile phone number. We only use the information received from customer support requests, including, without limitation, email addresses, for customer support services and we do not transfer to or share this information with any third parties.
8.2 You can also post questions and answer other User questions in our community forums. Our forum and messaging services allow you to participate in our community; to do so, we maintain the information, such as your user ID, contact list and status messages. In addition, these and similar services in the future may require us to maintain your user ID and password.
9. SURVEYS
From time-to-time, we may request information from Users via surveys. Participation in these surveys is completely voluntary and you, therefore, have a choice whether or not to disclose your information to us. Information requested may include, without limitation, contact information (such as your email address), and demographic information (such as interests or age level). Survey information will be used for the purposes of monitoring or improving the use and satisfaction of the Services and will not be transferred to third parties, other than our contractors who help us to administer or act upon the survey.
10. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
10.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
(b) to manage, operate, provide and/or administer your use of and/or access to our Services and our website, as well as your relationship and user account with us;
(c) to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences;
(d) to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary;
(e) to respond to, process, deal with or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account actions;
(f) to enforce our Terms of Service or any applicable end user license agreements;
(g) to protect personal safety and the rights, property or safety of others;
(h) for identification and/or verification;
(i) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
(j) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any inquiries given by (or purported to be given by) you or on your behalf;
(k) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve the disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(l) to inform you when another User has sent you a private message or posted a comment for you on the Site;
(m) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our Services, to improve our Services or products and/or to enhance your customer experience;
(n) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with SNSPI Services;
(o) where you give us your prior consent, for marketing and in this regard, to send you by various modes of communication such as postal mail, email, location-based services or otherwise, marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom SNSPI may collaborate or tie up with) that SNSPI (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future.
(p) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on SNSPI or on its related corporations or affiliates;
(q) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(r) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(s) to audit our Services or SNSPIs business;
(t) to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
(u) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
(v) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves SNSPI as a participant or involves only a related corporation or affiliate of SNSPI as a participant or involves SNSPI and/or any one or more of SNSPI related corporations or affiliates as participant(s), and there may be other third-party organizations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organization or of any of the business or assets of an organization; and/or
(w) any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”).
10.2 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
11. HOW DOES SNSPI PROTECT CUSTOMER INFORMATION?
We implement a variety of security measures to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes. If you cease using the Site, or your permission to use the Site and/or the Services is terminated, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
12. INFORMATION ON CHILDREN
The Services are not intended for children under the age of 10. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 10 nor is any part of our Site or other Services directed to children under the age of 10. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted by any child under the age of 10.
12.1 Requesting Access and/or Correction of Personal Data
12.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Site. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at the email address listed below in Section 19.2.
12.2.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days (or, if you are resident in Malaysia, 21 days). Where we are unable to respond to you within the said 30 days (or, if you are resident in Malaysia, 21 days), we will notify you of the soonest possible time within which we can provide you with the information requested. Note that Privacy Laws may exempt certain types of personal data from being subject to your access request.
12.2.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
(a) correct your personal data within 30 days (or, if you are resident in Malaysia, 21 days). Where we are unable to do so within the said period, we will notify you of the soonest practicable time within which we can make the correction. Note that Privacy Laws may exempt certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
(b) we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.
12.2.4 Notwithstanding sub-paragraph (b) immediately above, we may, if you so request, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date the correction was made.
12.2.5 We will/may also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
12.2.6 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organization to refuse to correct personal data in stated circumstances.
13. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
13.1 If you have any questions or concerns about our privacy practices or your dealings with the Services, please do not hesitate to contact: shop@bronco.ph
13.2 If you have any complaint or grievance regarding how we are handling your personal data or about how we are complying with Privacy Laws, we welcome you to contact us with your complaint or grievance. Please contact us through email with your complaint or grievance: E-mail: shop@bronco.ph and Attention it to the "Personal Data Protection Officer". Please send all legal notices to shop@bronco.ph and Attention it to the “ADMINISTRATOR”.
13.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a Privacy Law complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “Privacy Complaint”. We will certainly strive to deal with any complaint or grievance that you may have fairly and as soon as possible.
14. TERMS AND CONDITIONS
Please also read the Terms of Service establishing the use, disclaimers, and limitations of liability governing the use of the Site and the Services and other related policies.