Privacy Policy

  1. About This Policy
  2. DeepSea and its affiliates (collectively “DeepSea," "we," "us," "our") put you, our customers, first. We care for you and we regard your privacy with the utmost importance. This Privacy Policy outlines our policy in relation to the collection, use, and protection of your Personal Data to provide you with a wonderful customer experience. It applies to all the services provided by DeepSea through its various products and services. From time to time, we may update our Privacy Policy to reflect current changes in our policy and the law. When we do so, we will notify you by posting it on our website for your information and reference.
  3. Information We Collect and Use
  4. In our commitment to be transparent with you, we’ve provided information below to give you an idea of what personal information or Personal Data we collect and process. The Philippine Data Privacy Act allows us to collect and process such information based on several criteria, including consent. When we collect Personal Data about you in each of our products and services, it is our policy to let you know exactly what we are collecting, why, and what criteria under the law, apart from consent, we rely on, before we do so.
    1. Data Management Platform
    2. DeepSea creates custom audiences using 917V first-party data segments and exports custom audiences to Second Party's / Client’s demand-side platform (“DSP”). When you set up an account with us and use our services, we collect and process the following Personal Data about you and the business entity. The information below will help you understand exactly what we are collecting, why, and what criteria under the law, apart from consent, we rely on before we do.
      1. Basic Identifiers, Contact and Account Information
      2. We collect and process the full name, email address, company name, mobile number, business address, and area/s of concern or type/s of inquiry who fill out the form in our website for the following purposes:
        1. To verify your identity to use our services;
        2. To determine your initial eligibility to use our services and other products we offer;
        3. To facilitate the creation of your account in our service platform and the implementation of appropriate security measures and access controls;
        4. To use the information to provide services;
        5. To fulfill our respective obligations based on the services you procure and our terms and conditions;
        6. To provide and communicate to you the services you availed of, including customer account management, requests for additional documentary requirements, service care, and support;
        7. To send communications from DeepSea regarding commercial and promotional alerts, advertisements, and surveys.
        We collect such information through our Contact Us form or when you avail of, or make inquiries about, our products and services.
      3. Cookies and Trackers
      4. Through the DeepSea website, we collect cookies, web beacons, small data text files or similar technologies primarily to ensure that the core functions of our website are optimally accessible to you including promotional materials. However, depending on your preferences, we may also collect and use such information for behavioral analytics to tailor-fit our marketing campaigns.
    3. Private Marketplace
    4. DeepSea acts as a liaison or broker in selling the publisher-partner’s digital ads inventory among selected properties (e.g. website, app). The Private Marketplace that we are offering is also divided into the following:
      1. PMP - An invitation-only marketplace where publishers offer a portion of non-guaranteed inventory to be sold at a specific, minimum (floor) price.
      2. PMP preferred - Individual buyers make deals with individual sellers at fixed prices (only one DSP and one buyer can be selected for the deal).
      3. PMP Guaranteed - Individual buyers make deals with individual sellers after agreeing to a guaranteed minimum spend at a fixed price (only one DSP and one buyer can be selected for the deal)
      When you set up an account with us and use our services, we collect and process the following Personal Data about you and the business entity. The information below will help you understand exactly what we are collecting, why, and what criteria under the law, apart from consent, we rely on before we do.
      1. Basic Identifiers, Contact and Account Information
      2. We collect and process the full name, email address, company name, mobile number, company registration details, business address, and area/s of concern of subscribers who fill out the form in our website for the following purposes:
        1. To verify your identity to use our services;
        2. To determine your initial eligibility to use our services and other products we offer;
        3. To facilitate the creation of your account in our service platform and the implementation of appropriate security measures and access controls;
        4. To use the information to provide services;
        5. To fulfill our respective obligations based on the services you procure and our terms and conditions;
        6. To provide and communicate to you the services you availed of, including customer account management, requests for additional documentary requirements, service care, and support;
        7. To send communications from DeepSea regarding commercial and promotional alerts, advertisements, and surveys.
        8. We collect such information through our Contact Us form and/or online account creation process when you avail of our products and services.
      3. Service Usage and Performance Information
      4. When you use our services, we collect and process information such as your rate of use, and IP address for the following purposes:
        1. To design and create new products and services based on customer behavior and preferences;
        2. To determine whether you’ve reached or exceeded the limits of your service;
        3. To generate data needed to enhance your customer experience, tailor content to meet your preferences and needs and to help us improve our network and quality of products and services;
        4. To manage your account, maintain service quality and security, provide after-sales care and support;
        5. To create and offer new products and services based on your behavior and preferences; and
        6. To find out what sorts of commercial and promotional alerts, personalized advertisements, and surveys we can share with you.
      5. Cookies and Trackers
      6. Through the DeepSea website, we collect cookies, web beacons, small data text files or similar technologies primarily to ensure that the core functions of our website are optimally accessible to you including promotional materials. However, depending on your preferences, we may also collect and use such information for behavioral analytics to tailor-fit our marketing campaigns.
  5. Information We Share in General
  6. In general, we outsource or contract the processing of Personal Data to third parties, such as but not limited to, vendors, service providers, or partners, to fulfill any of the purposes we’ve described under each products/services, including the verification of the existence, truthfulness, accuracy of the information you’ve provided us and compliance with government requirements, and/or securely store the information in cloud. They are only authorized to access and use Personal Data for contracted purposes and for the duration of our contract with them. They may have access to Personal Data for a limited time under reasonable contractual and technical safeguards to limit their use of such Personal Data. We require them to protect personal data with organizational, physical and technical controls that are consistent with this Privacy Policy. Save for the disclosures that we make in line with the preceding paragraphs, it is our policy never to share Personal Data with any third-party unless we obtain your consent or are otherwise required/allowed by law to do so. In any case, we will let you know exactly what we are sharing, why, and what basis under the law, apart from consent, we rely on, before we do so.
  7. How We Protect Your Information
  8. We secure and protect your personal data with proper safeguards to ensure confidentiality and privacy; prevent loss, theft, or use for unauthorized purposes; and comply with the requirements of the law. To detect and mitigate evolving threats to information security, we’ve implemented appropriate physical, technical, and organizational security to protect your information including:
    • A state-of-the-art Security Operations Center complete with a dedicated team that manages, monitors and protects our network and systems from potential risks to your information under fully documented security incident management procedures.
    • Regular review of our information collection, storage, and processing practices, including physical and electronic measures to guard against unauthorized access to our network and systems.
    • Contractually obligated confidentiality among our authorized employees, contractors, and other third-parties who may have access to your information.
    • Third-party risk assessment as well as contractually mandated minimum-security features against data leakage, unauthorized access, or disclosure, and accountability.
    • Access management across DeepSea employees, contractors, and other parties under a “need to know” standard.
  9. How Long We Keep Your Information
  10. We only keep your Personal Data in our records while you are a customer unless it is necessary to keep such information longer to fulfill the purposes for which it was collected, or for legitimate business or legal purposes such as security, fraud prevention or financial record-keeping. You may ask for our data retention schedule because we want to be transparent with you. When disposing of your Personal Data, we have established procedures for securely disposing of files that contain Personal Data whether the same is stored on paper, film, optical or magnetic media, Personal Data stored offsite, and computer equipment, such as disk servers, desktop computers and mobile devices at end-of-life.
  11. Your Privacy Rights
  12. DeepSea fully recognizes your rights under the Philippine Data Privacy Act of 2012, namely: Right to be Informed Right to Object Right to Withdraw Consent Anytime Right to Access and Data Portability Right to Dispute/Rectify Right to Suspend/Block/Erase Right to Indemnity Should you feel that there has been mishandling or misuse of your Personal Data, or wish to exercise any of your data privacy rights, you may contact our Data Protection Office below. Such communication is subject to DeepSea’s internal procedures and may be outrightly denied when determined to be vexatious or unreasonable.
    1. Right to be Informed You have the right to be informed of the details about how and why we collect and process your Personal Data including where we got it, to whom we share it and why, how we protect it, how long we keep it, how we dispose of it, and any changes to such processing activities before the same is undertaken. Such request is, of course, subject to DeepSea’s right to restrict access to linked information that may be confidential or proprietary in nature.
    2. Right to Withdraw Consent Anytime Where our collection and processing of your Personal Data depends on the consent you provide us, you have the right to withdraw your consent anytime subject to DeepSea’s internal procedures, including consent provided on behalf of minors/children. This, however, does not apply to instances where we rely on grounds provided by law, other than consent. Nevertheless, you always have the right to object. Please note, however, we may be compelled to terminate your DeepSea product or service where such information is necessary for its delivery. This includes updates on our latest offerings as well as participation in our events, promotions, or other activities.
    3. Right to Dispute/Rectify We keep our records as accurate as possible. Where there are any errors or inaccuracies to your Personal Data, we give you ways to dispute and rectify/update it, subject to DeepSea’s internal procedures.
    4. Right to Indemnity You have the right to be indemnified for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Data.
    5. Right to Object You have the right to object to the processing and/or sharing of your Personal Data especially where you feel that we do not have the lawful grounds to do so or may have violated your privacy rights in the process. Please note, however, we may be compelled to terminate your DeepSea product or service where such information is necessary for its delivery. This includes updates on our latest offerings as well as participation in our events, promotions, or other activities.
    6. Right to Access and Data Portability You have the right to reasonably request access for your Personal Data with us in a format that is portable and commonly accessible subject to DeepSea’s internal procedures. DeepSea, however, reserves the right to seek a reasonable fee where providing such information presents certain challenges due to its volume; and to restrict access to linked information that may be confidential or proprietary in nature or may impact other individuals.
    7. Right to Suspend/Block/Erase You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Data in our processing systems upon discovery and substantial proof that such information is inaccurate, incomplete, outdated, false, unlawfully obtained or no longer necessary for the purpose or purposes for which it was collected, and for such other cases provided in the Data Privacy Act of 2012.
  13. HOW TO REACH US
  14. For any questions or concerns regarding our privacy practices, you may contact our Data Protection Office as follows:
    Data Protection Officer Globe Telecom, Inc. The Globe Tower 32nd Street corner 7th Avenue, Bonifacio Global City, 1634 Taguig City, Metro Manila, Philippines Email: dpo-globecapitalventureholdingsinc@globe.com.ph
  15. THE ONE GLOBE COMMITMENT
  16. Globe respects the right of its subsidiaries, partners, and affiliates (“One Globe Group”) to implement their respective privacy policies and practices. As a member of the One Globe Group, we are committed to uphold the following principles:
    1. Openness, Transparency, and Notice We are open and honest with you and will ensure that you are provided with clear, prominent, and timely information regarding our data privacy practices. We will provide you with information about the collection of your Personal Data, access, sharing, and further use of your Personal Data, enabling you to make informed decisions about whether to use a mobile application or service.
    2. Purpose and Use We will limit the access, collection, sharing, disclosure, and further use of your Personal Data to meet legitimate business purposes or to otherwise meet legal obligations.
    3. User Choice and Control We will give you opportunities to exercise meaningful choice and control over your Personal Data.
    4. Data Minimization and Retention We will collect, access, and use only the minimum Personal Data necessary to meet legitimate business purposes and to deliver, provision, maintain, or develop applications and services. Personal Data will not be kept for longer than is necessary for those legitimate business purposes or to meet legal obligations and will subsequently be deleted or rendered anonymous.
    5. Respect User Rights You will be provided with information about, and an easy means to exercise, your rights over the use of your Personal Data.
      1. Education You will be provided with information about privacy and security issues and ways to manage and protect your privacy.
      2. Children An application or service that is directed at children will ensure that the collection, access, and use of Personal Data is appropriate in all given circumstances and compatible with applicable law.
      3. Accountability and Enforcement All responsible persons will be accountable for ensuring that these principles are met