Booth and Partners Philippines Incorporated
Privacy Policy

Last Updated: February 10, 2022

This Privacy Policy (“Privacy Policy”) by Booth and Partners Philippines Incorporated (the “Company”, “B&P”, “we”, or “us”) is committed to
respecting your privacy and recognizes your need for appropriate protection and management of any personally identifiable information of
any nature (collectively “Personal Data”) you share with us. The purpose of this Privacy Policy is to let you know what kind of information we
collect, how we use it, with whom it may be shared, what choices you have regarding our use of your information, and how you may review
and change some of the data you provide to us. If you do not agree to be bound by all the terms of this Privacy Policy, please do not
provide us any of your Personal Data, join or use any of our Services.

This Privacy Policy shall cover users, clients, employees, and third-party service providers (hereinafter referred to as “you”) who shall access
the website ( and other online facilities operated under the supervision of B&P.

Upon accessing this website, you commit to have read, understood, and agree with the contents of this Privacy Policy. You likewise agree to
be bound by the terms and conditions hereinafter provided referring to the collection, use, storage, transmission, retention, deletion, and
any processing of your Personal Data.

We may, at any time and at our sole discretion, amend, and update this Privacy Policy, without notice to you. You are responsible for
regularly reviewing this Privacy Policy. Any such amendments, modifications, and/or updates will be effective immediately upon posting of
such updated Privacy Policy or the amended policies (if any) or supplemental terms (if any) on the applicable Services, campaign, or activity.
Your continued access or use of our Services or entry to any of our activities after posting such amendments, modifications and/or updates
confirms your acceptance and consent to be bound by the Privacy Policy, as amended.

You are responsible for regularly reviewing this Privacy Policy. We will not be held liable for any changes in the manner of processing your
data as indicated here. Any such amendments, modifications and/or updates will be effective immediately upon posting on our website.
Your continued access or use of B&P’s website and third party after the posting of such amendments, modifications and/or updates
confirms your acceptance and consent to be bound by the Privacy Policy, as amended.

Collection of Personal Data

We may collect Personal Data from you in a variety of ways, including, but not limited to, when you visit access or use our website
( or any of our Services (the “Service/s”), subscribe to any of our newsletter or marketing materials, respond to
a survey, fill out a form, and communicate with us in connection with our Services through any means including, but not limited to, our
website or social media pages.

You may be asked for, as appropriate, your name, email address, phone and/or mobile number and other Personal Data as may be necessary
to provide you with our Services. As used in this Policy, Personal Data shall include both Personal Information and Sensitive Personal
Information as defined under the Data Privacy Act of 2012.

We will collect Personal Data from you only if they voluntarily submit such information to us. You can always refuse to supply your Personal
Data, except that it may prevent you from using any of our Services.

In the course of accessing our site, 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 analytics tools – including
those of third parties –that use cookies to collect anonymous information and data generated in connection with your activities when you
visit the pages in our Website.

In any case, we only ask for the minimum information as we would need to provide you with our Services or to answer your queries,
questions, and/or request for support consistent with the principle of proportionality in our Data Privacy Laws.

Use of Personal Data

Subject to the provisions of the applicable laws, this Privacy Policy, the terms of the service or activity, and applicable terms and conditions
of third-party applications, B&P may use and process your Personal Information for its business and activities which shall include the
following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To facilitate the creation of your Account: to allow you to create a personalized account for or your company’s use as well as to
    provide you with your user account credentials.
  • To manage your Account: to manage your user account for the purpose of updating the information provided during the
    account registration process.
  • To allow you to access our services: The personal data you provide can give you access to different functionalities of the service
    that are available to you as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products,
    items, or services you have purchased or of any other contract with us through the Service.
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a
    mobile application’s push notifications regarding updates or informative communications related to the functionalities, products,
    or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To manage your requests: To attend and manage your requests to ss.
  • To improve our services: We may collect feedback from your end to facilitate and update our website’s services and to better
    cater to your preferences as a user.
  • To advertise our products: Subject to your informed consent, we may collect your personal data to advertise our services,
    including products offered by our affiliates, which may be of interest to you and individually selected based on your preferences.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends,
    determining the effectiveness of our promotional campaigns and in general, to improve our Service and your experience.

B&P may process your Personal Information for any of the aforementioned purposes and in accordance with the terms of this Policy for the
duration as stated in the terms of the activity and for such period as it is allowed under the law to process and retain your Personal

Storage and Retention

Personal Data provided by you to us may be stored, processed, and/or accessed by us in jurisdictions in which we, our business partners,
our affiliates or agents maintain facilities, as applicable. By using or accessing our, you expressly consent to any such transfer of information.
We may use and share non-Personal Information with third parties to provide you with Services, among other purposes.

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 until such time as it is no longer required nor necessary to keep your information for
any other legal, regulatory or business purposes.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when
this data is used to strengthen the security or to improve the functionality of our Service or we are legally obligated to retain this data for
longer time periods.

If we have no ongoing legitimate business need to process your personal information and upon the expiry of the above archiving period, we
will either irreversibly delete or anonymize such information.

Sharing and Disclosure Personal Data

Subject to any limitation and consistent with the guidelines set under all applicable laws, you consent that we may provide any information
you provide and made available to us about you and in connection with your use of our site, our various social media platforms, and of your
participation in any of our activities, to third parties which include the following:

With the staff and employees of B&P and its affiliates;

  • With third parties to provide the Services requested, if any and as applicable;
  • With the general public if User Content is submitted in a public forum, such as blog comments, social media posts, or other
    features of our Services or activities that are viewable by the general public;
  • With third parties with whom you choose to let us share information;
  • With our subsidiaries and affiliated entities and their employees that provide services or conduct data processing, data
    centralization and/or logistics purposes on our behalf;
  • With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out
    work on our behalf, such as work related to:

    • compliance with legal requirements;
    • enforcing our terms of use or such other applicable policies with respect to the services that we provide;
    • 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; or
    • carrying out all other purposes set out above;
  • With regulators, law enforcement officials, government authorities or any competent authority in response to a request for
    information if we believe that disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal
    process, including the following instances:

    1. there is a complaint, dispute or conflict relating to the Service provided by B&P or any proceedings in defense of
      claims or enforcement of rights and/or upon any compulsory order by a court of competent jurisdiction or any other
      ground/s allowed under applicable law;
    2. it is necessary to enforce the terms of Services provided by B&P which you requested;
    3. it is required, as determined solely by B&P, by applicable law, regulation, ordinance, license, or operating agreement;
    4. it is necessary, as determined by B&P, to protect our safety, rights, property, or security or that of any third party; to
      detect, prevent, stop or otherwise address fraud, security, technical issues, or any activity which we, in our sole
      discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable;
  • with any other entity in connection with, or during negotiations of, any merger, sale of company assets, consolidation or
    restructuring, financing, or acquisition of all or a portion of our business by or into another company; and
  • with any third party to whom we transfer any of our rights and obligations.

Protection of Personal Data

B&P fully recognizes the value of your Personal Data particularly as it may include Sensitive Personal. Appropriately, we strive to maintain the
confidentiality, integrity and availability of your personal information by employing physical, technological and procedural safeguards.
We are committed to implement physical, electronic, and procedural safeguards to protect your Personal Data against loss, misuse, damage
and unauthorized processing, access, disclosures or modifications of Personal Information. 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 and with the applicable laws. We continuously review and enhance our security policies and security
measures to consistently maintain a high level of security.

We will strive to implement commercially reasonable administrative, technical and physical controls to secure your Personal Data, to
minimize the risks of theft, damage or loss of Personal Data, or unauthorized access, use, alteration or disclosure. However, the security of
your Personal Data also depends on you. Any transmission of your Personal Data by you is made at your own risk.

Your Data Privacy Rights

Under the Law, you are entitled to the following data privacy rights –

  • The right to be informed whether your Personal Information shall be, are being, or have been processed;
  • The right to object to the processing of your Personal Information;
  • The right to reasonably access your Personal Information;
  • The right to dispute the inaccuracy or error in your Personal Information and have us correct it immediately and accordingly;
  • The right to suspend, withdraw, or order the blocking, removal or destruction of your Personal Information from our records;
  • The right to file a complaint with the NPC for any violation of your data privacy rights;
  • The right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained
    or unauthorized use of your Personal Information not in accordance with this Statement; and
  • The right to data portability of your Personal Information

Links to Other Websites

Our site and/or our social media platforms may contain links to other websites, applications, and social media pages of third parties that are
not owned or controlled by B&P. We are not responsible for the privacy practices of such other websites, applications, or third parties and
we encourage you to read the corresponding privacy statements and policies.

Changes to this Privacy Policy

We may, at any time and at our sole discretion, amend, and update this Privacy Policy, without notice to you. You are responsible for
regularly reviewing this Privacy Policy. Any such amendments, modifications, and/or updates will be effective immediately upon posting of
such updated Privacy Policy or the amended policies (if any) or supplemental terms (if any) on the applicable Services, campaign, or activity.
Your continued access or use of our Services after posting such amendments, modifications and/or updates confirms your acceptance and
consent to be bound by the Privacy Policy, as amended.

Contact Us

Please contact us at the details below if you have any questions regarding this Privacy Policy:

Data Protection Officer
Data Protection Officer

Acknowledgement and Consent

By communicating with us through our Website, various social media platforms, or using any of our Services, you declare, acknowledge and
warrant that:

  • You have read and understood this Privacy Policy and agree and consent to the use, processing, and/or transfer of your Personal
    Data by B&P as described in this Policy;
  • You will keep yourself updated with any changes in our Privacy Policy, as we may modify, update or amend the same from time
    to time;
  • All information that you provide us during the use of our website and/or the account creation or verification process are true
    and correct based on existing records;
  • You agree to the material changes to the manner of processing, use and/or transfer of your Personal Data upon as may be
    governed by the existing Privacy Policy at the time when such data is processed, used, and/or transferred by us;
  • You agree to will immediately inform us of any suspicious activity regarding the use of this website and/or our Services within
    reasonable; and
  • Your use of our website and/or our Services shall be in accordance with the law and existing regulations of the national

By continuing to communicate with us, by continuing to use our Services, or by your continued engagement with us through any channel
following the modifications, updates, or amendments to this Privacy Policy, such actions shall signify your acceptance of such modifications,
updates or amendments.

By submitting the required Personal Data to us, you consent to our collection, disclosure and use thereof. You hereby expressly waive and
release Booth and Partners Philippines Incorporated, including its subsidiaries and affiliates, from any and all liability, claims, causes of
action or damages arising from our legitimate use of the submitted Personal Data.