Ayala Plans, Inc. data privacy

Maintaining your privacy is an important part of the products and services that we provide. This Privacy Policy hereafter referred to as “Policy”, explains how we collect, protect, use and share information when you access our website and/or apply for and avail of our services.

This Policy outlines the general practices of Ayala Plans, Inc. (AP) in relation to our processes and content which is made available through our website. This Policy also covers the privacy practices for our customers who apply for and obtain services for our pre-need products such as Education and Pension Plans and other services that we may offer from time to time.

The privacy practices described in this Policy are primarily intended for individuals in the Philippines and are designed to comply with the Data Privacy Act of 2012 (R.A. 10173) and its implementing rules and regulations. When accessing our website and/or availing of our services from outside the Philippines, you acknowledge and agree that your information may be transferred to and processed in the Philippines following legal and regulatory standards for data protection that may differ from your current or home jurisdictions.

In designing our services and the processes as well as activities that support the delivery of any or all of these, AP proactively and appropriately identifies, assesses and addresses data privacy risks and seeks to follow the principle of “Privacy by Design” to ensure that the rights of our clients, stakeholders and the public are upheld.

When you apply for or avail of any service that AP offers or when you interact with our employees, authorized representatives and service providers, we collect your personal information which may include among others:

• Full name and personal particulars such as contact details, addresses, gender, birthdate, nationality, marital status, education;
• Specimen signatures;
• Digital photos and biometrics;
• Government ID details;
• Financial information (such as source of income, expenses, balances, investments, tax, insurance, financial and transaction history, income, etc.);
• Employment details;
• Business interests and assets;
• Images via CCTV and other similar recording devices and processes which may be observed when visiting our offices and/or using our other facilities;
• Voice recordings of our conversations with you;

We may as when necessary, seek to verify or augment any of these information with third-party entities including government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction and, in the process, gain additional information about you.

In the course of availing our products and services, we also collect information about your transactions and dealings which include your account activities, movements and interactions with third parties such as merchants and utility companies.

When you access our website, we may provide information about us as well as information regarding our services. In the course of using our website and electronic platforms, we may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. We may likewise use web analytic tools, including those of third parties’, that use cookies to collect anonymous information including your geographic location and data generated in connection with your activities when you visit the pages and our website.

We may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives and service providers.

We use the information collected to deliver and provide the services that you have availed to:

• approve, facilitate, administer, and process applications and transactions;
• respond to queries, requests and complaints and improve how we interact with you;
• send you statements, billings, notices, and other such documents necessary for continued use of our products and services;
• conduct studies and research for the purpose of reviewing, developing, and improving our products and services;
• perform profile analysis, behavioral modeling, and analytics to understand needs, preferences, and market trends to be able to improve and recommend suitable products and services;
• reach out to you regarding products and services information, including offers, promotions, discounts, rewards; and for personalizing your experience with our various touchpoints such as branches, call center, telemarketing, email, messaging, and other channels;
• perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;
• comply with our operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, the Insurance Commission rules and regulations, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time.
• comply with applicable laws of the Philippines and those of other jurisdictions including the United States Foreign Account Tax Compliance Act (FATCA), the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended (AMLA) and the implementation of know your customer and sanction screening checks
• perform other such activities permitted by law or with your consent.

We may share your personal information with our affiliates and third parties, under an obligation of confidentiality.

• We may share personal information with various units within AP and our parent, BPI to better understand how you use our products and services. This will allow us to improve our services and offer you opportunities to obtain other useful products and services that may deliver greater value to you.
• We may share information with our parent, BPI and affiliates to likewise offer you additional products and services that we believe you might find interesting.
• We may share with third parties that we engaged to support us in delivering our services to you. These may involve anonymous or aggregated information to help improve our services, and content.
• We may also engage third parties to help us operate our business. These include support in:
  • complying with legal requirements such as court orders;
  • addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property or security of our customers or third parties;
  • to carry out all other purposes set out above.

We fully recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc.  Appropriately, we strive to maintain the confidentiality, integrity, and availability of your personal information by employing physical, technological, and procedural safeguards.  We train our employees to properly handle your information.  Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards.

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time, remains in effect and until such time as it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes. Once the purpose for which it was collected shall have been completed, we will securely dispose of your personal information unless we are required to retain them for legal or regulatory purposes. 

In respecting your rights to privacy, you may opt to tell us:

1. to inform you of what we do with your personal information;

2. to provide you with information that we currently have about you, subject to restrictions applied to us as a pre-need/insurance company and a subsidiary of a bank and a company operating in the Philippines by certain laws and regulations, in an easy-to-access format and easy-to-understand language; 

3. not to send you marketing materials via email or SMS, not to share your information with our affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining, providing and completing the products or services that you have availed from us;

4. not to process your personal information upon withdrawing consent, unless processing is legally required;

5. to remove and dispose your personal information from our records, as allowed by applicable laws and regulations; 

6. to update any personal information upon your advice;

7. to electronically move, copy, or transfer it securely through available means.

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on any processing fee will be made available to you prior to making the request.

You may lodge a complaint regarding our use of your personal information and be assured that we will address your concerns promptly.  Should we fail to do so, you may address any complaint to our regulators, particularly the Insurance Commission and the National Privacy Commission, consistent with the rights granted to you under applicable laws and regulations.   

For any queries, clarifications or requests on any aspect of this Policy, the exercise of your rights pertaining to your personal information or to provide any feedback that you may have about our processing of personal information, please send us a message or visit our office.

You may reach us through these channels:

Email: dataprivacy@ayalaplans.com.ph

We will respond to you soonest during business hours

Phone: (+632) 8580-0821

Address: 8F BPI Buendia Center, 360 Sen. Gil Puyat Ave., Bgy. Bel-Air, Makati City 1209

Our office is open Monday to Friday from 830am to 430pm (excluding holidays)

We may modify or amend this Privacy Policy from time to time to keep up with any changes in relevant laws and regulations applicable to us or how we collect, use, protect, store, share or dispose of your personal information.  Any relevant updates will be posted on the AP website.

Personal Information/Data - refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Sensitive Personal Information/Data - refers to personal information:

• About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
• About an individual's health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;

Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and

Specifically established by an executive order or an act of Congress to be kept classified.

Last updated: December 2023