Premier Software Enterprises, Inc. (referred to herein as the "PSEI", "we", "us" or "our") is committed to respect and protect its ciustomers’ personal data in accordance with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (“IRR”) and other applicable laws and regulations. We will keep secure and confidential all personal data obtained through the PSEConnect application, website, social media account, and over the course of performing business activities or that PSEI may collect unless required to be disclosed by law, rules, and regulations, or with your authorization.

Personal data refers to all types of personal information or any data about an individual who can be identified from that data, as more specifically defined under the DPA.

This PSEI Privacy Policy ("Privacy Policy") explains how and why PSEI collects personal data from you when you:

1. register or open an account in our PSEConnect application, an online trading platform made through the facilities of The Philippine Stock Exchange, Inc. (“PSE”) involving securities of companies listed in PSE;
2. use PSEConnect or our services; or
3. visit, register, access, use, download our mobile application, or disclose through our Websites or Web applications (as applicable, any software application made available by PSEI for use on a computer, tablet, mobile phone, or other mobile device or our social media accounts related to PSEConnect – ∧PSEConnect (Facebook, LinkedIn, Twitter, and Youtube);

How we use, store, disclose, and process your personal data, our legal bases for processing, cookies that we use, how we protect your personal data, your rights under the DPA, and the means by which you can control, to a certain extent, these processes.

PSEConnect and our Website use cookies to improve and tailor your browsing experience. Please read part of the Privacy Policy on cookies stated below for more information. If at any time you choose not to accept the terms and conditions of this Privacy Policy or you do not want PSEI to collect, use, store, disclose, modify, retain or process your personal data you should not download, register, disclose, use, transact with us, or open an account in PSEConnect, visit or use our Website or social media account, use our services, or transact with us.

This Privacy Policy complements, and does not limit or replace, the purposes for which you provide PSEI with your personal data which may be expressly given in any form for submission of personal data to PSEI or as required under the law or rules and regulations of the PSEI. Your use of the PSEConnect oneline trading platform, mobile application, Website, social media account, and our services, and any dispute over privacy are subject to this Privacy Policy, including any applicable limitations on damages and the resolution of disputes. If at any time you choose not to accept the terms of this Privacy Policy, you should not download, open an account, visit, or use the PSEConnect online trading platform, mobile application or visit our Website or social media account, transact with us, or seek our services or products.

This Privacy Policy applies only in circumstances governed by the Data Privacy Act of 2012 and its IRR. Please read this Privacy Policy carefully and revisit this page from time to time to review changes that may have been made as PSEI may, whenever necessary, update this Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any change in legal or regulatory requirements, and corporate or business changes.

The PSEI collects personal data fairly and lawfully. The legal bases for our collection and processing of your personal data will be one of the following:

1. to fulfill our contractual obligations to you, for example, to allow your use of our products or services;
2. to comply with our legal and/or regulatory obligations, for example, obtaining your name to enable us to meet our obligations under applicable laws;
3. to meet our legitimate interests, for example, we want to know how you use PSEConnect or our Website in order for us to enhance PSEConnect or allow your registration in PSEConnect, to enhance our services, or to create new ones; to convey to you the issues or concerns relating to your use of PSEConnect; to update you about PSEConnect or the services that you use; to maintain our records; and to review and plan our marketing and business development programs. When we process personal data based on this ground, we implement necessary safeguards which are designed to protect your privacy interests, freedoms, and fundamental rights protected under the 1987 Constitution;
4. when we are required to obtain your consent by law, for example, when we process sensitive personal information, when there is data sharing, or in relation to direct marketing activities. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy. If consent is withdrawn, we will be constrained to close your PSEConnect account or terminate the processing of your transaction or request unless there is a legal basis for further processing of your personal data without need of your consent.

The personal data that PSEI may collect from you depend on the nature and purpose of your interaction, transaction, or application with PSEI such as, but not limited to, the following:

• Your name (first and last name), contact details (email address and mobile number), and address information (country, province, and city).
• Username, password, information about your use of the Websites or PSEConnect, including, internet protocol (“IP”) address, and websites visited; and
• Any additional personal data that you may provide or through your correspondence(s) with us in connection with your concerns which we shall also consider and treat as personal data.

Your personal data are collected by PSEI when you (a) download, use, and open an account in PSEConnect, (b) transact with us or seek our services, and (c) when you browse our Website or our social media account. When you use PSEConnect, visit our Website or social media account, we use cookies to store information about how you use PSEConnect or the Website in order to enhance your user experience and to improve the quality of service we provide. Examples of this information may include your Internet Protocol address, the type of browser and operating system you are using, date and time of your use of PSEConnect or our Website. For more information, please refer to the cookies policy below.

The PSEI collects, uses, stores, modifies, retains, and processes your personal data for various lawful and legitimate purposes such as, but not limited to the following:

1. enable your registration or opening of an account in PSEConnect;
2. allow your use of PSEConnect;
3. provide you with our services or in order for us to improve said services;
4. improve or enhance PSEConnect;
5. convey to you matters pertaining to your use of PSEConnect or to act on your request/s;
6. conduct audit and review of our processes and systems, including PSEConnect, for purposes of managing risks, strategic and action planning, and compliance;
7. protect and enforce contractual and legal rights and obligations of PSEI;
8. comply with applicable laws, rules, and regulations, or policies issued by regulatory bodies, or assist in law enforcement and investigations by relevant authorities, including court proceedings;
9. send you updates or information about PSEConnect or our services;
10. allow your use or visit of our Website or social media account; and
11. any other purposes related to any of the foregoing.

We may share your personal data within PSEI and/or related parties in order to provide you with our products or services or to continue your relationship or transaction with us. Access to your personal data is limited to those employees, agents, and contractors of PSEI who need access to your personal data in order to provide you with our products or services and to carry out the legal and regulatory obligations of PSEI. Only personal data pertinent or relevant to the purpose is shared.

The PSEI will not disclose your personal data unless such disclosure is required by law, rules, and regulations, or with your authorization. In case you will consent to the disclosure, your pertinent personal data will be shared or disclosed to your broker or dealer of your choice and for purpose/s in connection with your opening and use of PSEConnect or for purposes specified by you.

We may also disclose aggregated information that does not identify, or when combined with other information, does not directly and certainly identify any individual.

We use cookies PSEConnect online trading platform to provide you with a good user experience, allow us to improve our platform, and to help your browser navigate through PSEConnect and deliver the full features of PSEConnect such as by allowing you to log in automatically or remembering settings (e.g. font size and other display preferences) you previously selected. Cookies are small, randomly encoded, text files that we store on your browser or computer, or mobile devices. By clicking “I Agree” or by continuing to use PSEConnect without changing your settings, you agree to our use and storing of cookies on your browser, hardware or device for purposes set forth in this Privacy Policy.

If you do not wish to accept cookies in connection with your use of PSEConnect or our Website, you must stop using PSEConnect or our Website or you should disable or delete the cookies associated with PSEConnect or our Website by changing the settings on your web browser. Please be informed however that if you will disable cookies, certain functions and pages on PSEConnect will not work in the usual way. To disable cookies, please visit the “Help” or “support” section of your browser to manage your cookies settings, for example:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies;
• Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies;
• Google Chrome: http://www.google.com/ support/chrome/bin/answer.py?hl=en&answer=95647.

Types of Cookies Used

PSEConnect use both persistent and session cookies. A persistent cookie enables PSEConnect to remember you on subsequent visits, resulting in faster and more convenient access to the services or functions offered by PSEConnect. Persistent cookies stay in your browser until you delete them manually or your browser deletes them on expiry date. Session cookies are temporary cookies that are erased when you close your browser. A session cookie is essential to ensure the correct functioning of PSEConnect and it is used to manage registration/login in PSEConnect and access to its or Website’s reserved features.

By registering or signing up for an account and clicking “I agree”, you agree and consent to our processing and sharing or disclosure of your personal data to the broker or dealer of your choice for any of the purposes set forth above.

When accessing your PSEConnect account or using your account outside of the Philippines, you acknowledge and agree that your personal data may be transferred to and processed in the Philippines pursuant to legal and regulatory standards for data protection that may be different from your current or home jurisdiction.

You also acknowledge and agree that the PSEI has put in place appropriate physical and technical security measures to protect your personal data. You are also aware that notwithstanding the said privacy protection measures that have been put in place by the PSEI, there is a risk that your personal data may be subject to unauthorized disclosure, processing, or breach. You also agree to hold the PSEI, its directors, officers, and employees free and harmless from any damage, loss, liability, or injury that you may suffer on account of any unauthorized disclosure, processing, or breach of your personal data, provided that there is no bad faith or gross negligence on the part of the PSEI or any of its officers or employees who directly process your personal data.

We store personal data collected in electronic and paper formats. The security of your personal data is important to us. Thus, in order to protect your personal data from misuse, interference, loss, unauthorized access, modification, and unauthorized disclosure we have adopted appropriate organizational, technical, and security measures such as by establishing limitations, when applicable, on access to personal data, document storage security policies, security measures on controlled access to our systems and premises, stringent selection of third-party data processors and agents, non-disclosure and privacy protection clauses in agreements, confidentiality agreements, and data privacy trainings of our officers and employees, and technology-based security tools, software, and measures to protect our Websites, Digital Services, information communication technologies, systems, and data.

We store your personal data physically or electronically with data storage or third-party service providers. For this purpose, we require non-disclosure agreement and make use of contractual arrangements to ensure those providers to take necessary and appropriate measures to protect your personal data and to restrict its access or use. We will not keep personal data longer than is necessary for the purpose for which they were collected, unless required otherwise required by applicable laws, and rules and regulations. We will take reasonable steps to safely destroy or permanently de-identify personal data if it is no longer needed.

You have rights as a data subject provided under Section 16 of the DPA and Section 34, Rule VIII of the IRR such as:

1. right to be informed of the processing of your personal data;
2. right to object to its processing, except (i) when it is needed pursuant to a subpoena, or (ii) when processing is for obvious purposes, including when it is necessary for the performance of or in relation to a contract or service or when necessary or desirable in the context of an employer-employee relationship, (iii) when the information is being collected and processed as a result of a legal obligation;
3. right to suspend, withdraw or order the blocking, removal, or destruction of personal data from the filing system upon discovery and substantial proof that the personal data is either: (a) incomplete, outdated, false, or unlawfully obtained; (b) being used for unauthorized purposes; (c) 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; (e) when the personal data concerns private information that is prejudicial to the data subject, unless justified by freedom of speech, of expression, or of the press or otherwise authorized; (f) processing is unlawful; or (g) when the personal information controller or personal information processor violated the rights of the data subject;
4. right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data;
5. right to reasonable access to your personal data that we store and process;
6. right to dispute any inaccuracy or error of your personal data in our records and to have it rectified immediately unless the request is vexatious or otherwise unreasonable;
7. right to data portability of your personal data when it is processed by electronic means and in a structured and commonly used format; and
8. right to lodge a complaint before the National Privacy Commission in case of violation of your rights.

If you want to access, update, or correct inaccuracies in your personal data, or have your personal data removed from PSEConnect or from our records under any of the grounds provided above or in case you have any request in relation to this Privacy Policy, please contact us through our email address – support@pseconnect.com or office address - 2/F Don Pablo Building, 114 Amorsolo Street, Legaspi Village, Makati, 1229 Metro Manila - and we will act on your request unless there are practical, contractual or legal reasons why we cannot process your request. We also reserve the right to refuse requests that, in our opinion, occur with unreasonable frequency or otherwise are unreasonable.

You may also contact the National Privacy Commission at:

Email: info@privacy.gov.ph or complaints@privacy.gov.ph

Address: 5th Floor Delegation Building, PICC Complex, Roxas Blvd, Pasay, Metro Manila 1307