WWW.GEORGE.PH

DATA PRIVACY POLICY

Update (October 19, 2021)

GEORGE OPTICAL Inc., (www.george.ph) is committed to protecting and respecting your personal data privacy. We recognize the importance of privacy as well as the importance of maintaining the confidentiality of personal information. This privacy policy ("Policy") sets out the basis on which your data will be processed, collected, used, and disclosed by us when you visit our website, and/or avail our products or services (collectively, "Services").

Please read the following carefully to understand our approach and practices regarding the processing of your personal data. This Notice may be updated from time to time to reflect changes in our system. You are encouraged to regularly review this Notice and to reach out using the contact information provided in this Notice in case you have concerns about how your personal data is processed.

A. Collection of Information

Your privacy is highly important to us and we have taken steps to ensure that we do not gather more information from you than is necessary for us to provide you with our services and to protect your account. Whenever you register an account, contact our customer service, transact or use our services, browse, read or interact with our website, or participate in our trade shows, industry events, or functions, the following information may be collected manually or automatically from you:

• Name
• Address
• Phone number
• Email Address

Please note that if you contact our customer service, we may record your conversation with us and collect additional information to verify your identity. This process will be done only with your consent.

In connection with any transaction and payment services, information, including:

• Bank account numbers
• Billing and delivery information; and
• Bank address

These data may be collected to facilitate the sale and purchase as well as the settlement of the purchase price of the products or services transacted.

When you visit our website, we may gather the following technical information about your visit: • IP address

• Browser software
• Operating system
• Software and hardware attributes
• Pages viewed
• Number of sessions
• Unique visits

These data shall not be linked to your name and profile. We shall use this to evaluate traffic for purposes of improving our services to you.

B. Specific Purposes of and Legal Bases for Processing Personal Data

We process Personal Data about you only where it is: necessary to provide you with the services you request, and to identify and authenticate you so you may use the Services; necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will be to operate our Services, manage our relationship with you and communicate with you as necessary to provide our Services to you and/or to pursue a legitimate commercial interest, Specifically, we gather and use your Personal Data for the following legitimate purposes:

• Verifying your identity as a matter of "Know Your Client" check;
• To operate our products and provide you with rich, interactive experiences.
• To respond to, handle, and to process queries, requests, applications, complaints, and feedback from you. • To manage your relationship/account with us.
• To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.      

C. Disclosure of Personal Data

There are specific instances where your data may be legally disclosed. We may disclose your Personal Data to our partners, or service providers engaged by us to assist us to service you or who otherwise process Personal Data for purposes described in this Privacy Policy or notified to you when we process your Personal Data.

Examples of these partners or services providers include:

• Our business partners (for example, in order for them to provide you with discounts or offers that may interest you).
• Marketing platforms, such as Google, Twitter, Facebook, and Instagram, and providers of analytics services relating to users' behavior, in order to tailor the content you see when using our application.

These marketing platforms may combine information they collect on our platform with data on their platforms and data they collect from other websites or through George Optical, www.george.ph, or other sources in order to conduct targeted advertising.

The activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy;

• Cloud computing service providers to provide cloud storage services;
• Warranty service providers to provide warranty services;
• Customer service providers to provide after-sale services; and
• Risk control service providers to assess the security of members' accounts and transaction risks.
  

For the purposes specified above, we may share your Personal Data with our affiliated companies and/or their designated Service Providers, which comprises a group of companies operating and leading digital marketing and advertising campaigns, promotional events, business to-business commerce, and other services. However, rest assured that affiliate companies, service providers, and related interests groups are compliant to data privacy laws of the country or state they are situated.

When we believe it is necessary to comply with applicable laws or to exercise, establish, or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations, or as otherwise required or permitted by applicable laws .

We may also disclose your Personal Data to any other person with your consent to the disclosure.

We may disclose your registered address to another user with your consent to such disclosure.

Please note that Information you submit to our website may be made publicly available depending on which part of the website (i.e. customer review, comments section, bulletin boards, link to social media) they were submitted and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication, especially personal data pertaining to others.

We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you.

D. Rights Regarding Personal Data

Our website and services are accessible in various jurisdictions which may provide data subjects with different rights. Your right as a data subject shall be that of access to Personal Data held by us and such other rights provided under the laws and jurisdiction applicable to you:

• Right to be informed IRR Sec. 34.a
• Right to lodge a complaint IRR Sec. 34.a.2.i
• Right to object (to withhold consent to processing)
• Right to access
• Right to rectification (to correct)
• Right to erasure or blocking
• Right to data portability
• Right to be indemnified

If you have any questions regarding this Privacy Policy or if you wish to exercise any of your rights with respect to your Personal Data, you may send your request to our Data Protection Officer whose contact information is provided at the end of this Notice. If and to the extent permitted by applicable law, we may charge you a fee for the processing of any request you make regarding your Personal Data.

E. Minors

The website and its contents are not targeted to minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact info@george.ph to remove the information.

F. Storage and Retention

Only authorized personnel have access to your personal information. They are stored in a secure cloud database applying the latest internationally acceptable security standards for six (6) months following determination that they are no longer necessary to serve the above-mentioned legitimate purposes, until upon your request for your personal information's removal in our database, or as required or permitted by applicable laws, after which, they are anonymized or deleted permanently.

G. Security Measures

Since personal data are stored in a cloud database, we are careful to ensure that we have transacted with a reputable cloud service provider/s that employ/s the latest internationally acceptable security standards to prevent unauthorized access to the Platform, to maintain data accuracy and to ensure the correct use of the information we hold. All our service providers must comply with our data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes.

For registered users of our website, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer.

Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

H. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Sites. Once posted on the Sites, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.

I. How to Contact Us

If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Policy, please contact us through our Data Protection Officer:

Officer: Ms. Irene Co-See

Office Address: G&B Building 2005 Taft Ave. Pasay City

Telephone Number: +6388348742

Email: info@george.ph

J. Analytics

Our website uses Google Analytics, an internet analytics service provided by Google, Inc., 1600 Amphitheater Parkway Mountain View, California, 94043, USA ("Google"). Google Analytics uses "cookies", which are text files that are stored on your computer and used to analyze the use of the Sites.

For example, Google's cookies allow us to tell us which pages our users are viewing, which ones are most popular, what time of day our Sites are visited, if users have previously visited our Sites, from which website users are redirected to our Sites were and the like. The data generated by the cookie about your use of the Sites will be transmitted to Google and stored by Google on servers in the United States. The website uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google's servers in the US and then truncated there. Google uses the data on behalf of the website operator to evaluate your use of the website, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics cookies, visit the Google Help pages and Privacy Policy: Digital Spring Marketing and Advertising Inc. Privacy Policy www.digitalspring.com.ph Google Privacy Policy: https://policies.google.com/privacy Google Analytics Help Center The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Through your browser settings, you can block cookies; however, this can lead to problems with the use of some functionalities of the website. Through the add-on "Google Analytics Opt-out" you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en More information can be found here: https://support.google.com/analytics/answer/6004245.