This Data Privacy Statement has been updated as of November 2023

Everbright Real Estate Inc. (“Everbright Real Estate”) respects and values your privacy by
providing appropriate measures in protecting and managing your personal data.

This Privacy Statement summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

By using our services and by using and continuing to use our website, you allow us to collect, maintain, use and disclose your personal information in the manner described in this Privacy Statement.

Our Privacy Practices
The privacy practices described in this Statement 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.

What We May Collect From You
Generally, we collect your personal information on a voluntary basis, either manually or electronically, when you submit to us your inquiries or avail of our services.

Information we collect directly
We collect the following types of personal information that you provide to us:

a. Name, residential or business address, contact phone numbers, email address;
b. Employment details;
c. Relevant financial information (e.g., sources of income, credit rating);
d. References (e.g., to support rental arrangements);
e. Copies of photo identification (e.g., driver’s license, passport, student ID); or
f. Any other personal information relevant to the service we are providing to you.

Information we collect from third parties.
We may collect or receive personal information about you and your property from third party sources, such as public databases, marketing partners, social networking sites, brokers and affiliated agents, and other real estate professionals, and third parties. For example:

Social networking sites. If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.

Real estate professionals. If you interact or list a property with a broker, independent agent, or other real estate professional associated with Everbright Real Estate, we may receive personal information about you and your property from them, such as your name and property address, listing and contact information, among other things.

Property records. We may collect information about individuals and real estate property through public databases, such as property ownership and tax records maintained by the relevant government agencies.

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, agents and service providers.

Your personal information will only be used to fulfill the specific services we provide to you, unless you give us permission to use it in another manner, such as to add you to one of our mailing lists.

How We Use Your Information
We use the information collected to deliver and provide services that you have availed for the following purposes:

• Providing our support and services
• Analyzing and improving our business
• Personalizing content and experiences
• Advertising, marketing, and promotional purposes
• Securing and protecting our business
• Defending our legal rights
• Auditing, reporting, corporate governance, and internal operations
• Complying with legal obligations

How We May Share Your Information
We may disclose the personal information that we collect about you to the following individuals:

• Service providers. We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.
• Third parties. We may disclose personal information to third parties in order to provide our services, facilitate your requests, or with your acknowledgement and consent, including with:
  • Independent real estate professionals and owners and operators of real estate brokerage companies to enable them to provide the services you requested;
  • Third parties that we engaged to support us in delivering our services to you;
  • Third parties with whom you choose to let us share information, for example other apps or websites that integrate with our services, or those with services with which we integrate; and
  • Third parties we work with to provide you with more personalized content and ads, and to track the effectiveness of campaigns

How We Protect Your Information
We recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc.

We strive to maintain the confidentiality, integrity and availability of your personal information by ensuring that only authorized personnel of Everbright Real Estate have access to the personal information and by employing physical, technological and procedural safeguards. Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards.

How Long Do We Keep Your Information
We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice unless a different retention period is required or permitted by law.

We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

Your Rights
Under the Data Privacy Act of 2012, you have the right to access, modify, erase and/or object to any processing of personal, sensitive or privileged data that you have provided to us.

As provided under the Data Privacy Act of 2012, data subjects have the following rights in connection with the processing of their personal data: right to be informed, right to object, right to access, right to rectification, right to erasure or blocking, and right to damages. Employees and agents of the Everbright Real Estate are required to strictly respect and obey the rights of the data subjects. The Data Protection Officer (DPO) shall be responsible for monitoring such compliance and developing the appropriate disciplinary measures and mechanism.

A. Right to be Informed
As a data subject, you have the right to be informed whether personal data pertaining to you shall be, are being, or have been processed.
You will be notified and furnished with information indicated hereunder before the entry of your personal data into the records of Everbright Real Estate, or at the next practical opportunity:

a. Description of the personal information to be entered into the system;
b. Purposes for which they are being or are to be processed;
c. Scope and method of the personal data processing;
d. The recipients or classes of recipients to whom the personal data are or may be disclosed;
e. Methods utilized for automated access, if the same is allowed by the data subject, and the extent to which such access is authorized;
f. The identity and contact details of the DPO;
g. The period for which the personal data will be stored; and
h. The existence of their rights as data subjects, including the right to access, correction, and to object to the processing, as well as the right to lodge a complaint before the National Privacy Commission.

B. Right to Access
You have the right to reasonable access to, upon demand, the following:

a. Contents of your personal information that were processed;
b. Sources from which personal information were obtained;
c. Names and addresses of recipients of the personal information;
d. Manner by which such data were processed;
e. Reasons for the disclosure of the personal information to recipients;
f. Information on automated processes where the data will or likely to be made as the sole basis for any decision significantly affecting or will affect the data subject;
g. Date when the personal information concerning the data subject were last accessed and modified; and
h. The designation, or name or identity and address of the DPO.

To obtain access to the aforementioned list, please submit your request via email to everbrightlistings@gmail.com or contact us through phone or messaging at +639171681688. Once your identity has been duly verified, we will promptly furnish the requested data.

A comprehensive record of the access request, encompassing specific details, the provided response, and any pertinent communication associated with the process, will be maintained.

C. Right to Object
You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing, or profiling. Subject to any modifications of the information initially provided, you will receive a notification via email at least 30 days prior.

Simultaneously, an official announcement will be posted on www.everbright.com.ph. You shall have the opportunity to refrain from granting consent for the processing of your personal data up to the 20th day following the receipt of the email notification. Should you have any inquiries or concerns regarding these modifications, you may direct your correspondence to dataprotection@everbright.com.ph.

Whenever you object or withhold your consent, we will no longer process your personal data, unless:

a. The personal data is needed pursuant to a subpoena;
b. The processing is for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which the data subject is a party, or when necessary or desirable in the context of an employer-employee relationship between Everbright Real Estate and the data subject; or
c. The personal data is being collected and processed to comply with a legal obligation.

D. Right to Erasure or Blocking
You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our filing system.

1. 1. 1. This right may be exercised upon discovery and substantial proof of any of the following:
         a. The personal data is incomplete, outdated, false, or unlawfully obtained;
         b. The personal data is being used for purpose not authorized by the data subject;
         c. The personal data is no longer necessary for the purposes for which they were collected;
         d. The data subject withdraws consent or objects to the processing, and there is no other legal ground or overriding legitimate interest for the processing by the company;
         e. The personal data concerns private information that is prejudicial to data subject, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
         f. The processing is unlawful; or
         g. The data subject’s rights have been violated.
      2. The DPO may notify third parties who have previously received such processed personal data that the data subject has withdrawn his or her consent to the processing thereof upon reasonable request by the data subject.
         You have the option to seek the erasure or blocking of your personal data by submitting a request through email to everbrightlistings@gmail.com or by contacting us via phone or messaging at +639171681688. The Listing Department Team will engage in a process to verify the identity of the requester, and upon successful verification, will expeditiously carry out the erasure or blocking of the data, if deemed necessary.

E. Right to Rectification
You are entitled to contest any inaccuracies or rectify errors in your personal data by submitting a formal request via email to everbrightlistings@gmail.com or by contacting us through phone or messaging at +639171681688.

The Listing Department Team will undertake identity verification of the requester, and upon successful verification, will promptly effectuate the necessary corrections, unless the request is deemed vexatious or otherwise unreasonable. In the event of correction, we will ensure the accessibility of both the revised and original personal data, concurrently notifying the intended recipients of such data.

It is understood that any recipients or third parties previously in receipt of the processed personal data will be informed of its inaccuracy and subsequent rectification, upon a reasonable request from the data subject.

F. Right to File a Complaint
You possess the entitlement to file a complaint with the National Privacy Commission or the relevant local supervisory authority in the event that you perceive your personal information to have been utilized inappropriately, maliciously disclosed, improperly disseminated, or subjected to improper disposal, or in the case of any infringement upon your data privacy rights.

We kindly request that you endeavor to resolve any concerns with us initially; however, you retain the right to engage with the authorities at your discretion. Communication regarding such matters can be directed to us via email at dataprotection@everbright.com.ph or by reaching out to us by phone or messaging at +(63) 917 508 1688.

G. Right to Damages
You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, taking into account any violation of your rights and freedoms as a data subject, as provided by law.

H. Right to Data Portability
In case your personal data was processed through electronic means and in a structured and commonly used format, you have the right to obtain a copy of your personal data in such electronic or structured format for your further use, subject to the guidelines of the National Privacy Commission with regard to the exercise of such right.

How to Contact Us
If you would like further information on our Privacy Policy or if you have any concerns over the protection of the information you have given to us or that we have collected from others, please contact our Data Privacy Officer at:
Email: dataprotection@everbright.com.ph
Mailing address: Unit 1102 Antel Corporate Center, 121 Valero Street, Makati City
Contact number: +(63) 917 634 8746

Changes to Our Privacy Statement
We may modify our Data Privacy Statement at any time to align with relevant laws and regulations and our policies and procedures, as applicable. All updates will be posted in our website and will take effect immediately, unless otherwise required by the applicable law or regulation.

Rest assured, that any changes in our policies will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless otherwise required by law.

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:

1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
2. 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;
3. 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
4. Specifically established by an executive order or an act of Congress to be kept classified.