1.1 Overall Privacy
Moneybees Forex Corporation (hereinafter "we", or "Moneybees") is committed to respecting and protecting your data privacy rights as a data subject in accordance with Republic Act No. 10173, otherwise known as the "Data Privacy Act of 2012", its Implementing Rules and Regulations and other applicable laws of the Republic of the Philippines.
The information you provide when you use the services provided by Moneybees (the "Service" or "Services") will be collected and used in the manner stated in this Policy.
As part of your use of the Services, you affirmatively consent to the processing and storage of your personal information, including the processing and storing of your personal information in the Philippines for the purposes of tracking individual use of the Service. By using the Service, you acknowledge that you understand and agree that the Philippines may not have the same level of protection for your personal information that exists in your country of residence or the same laws in your country of jurisdiction, and you nonetheless consent to the processing and storage of your personal information in the Philippines in accordance with limitations of Philippine industry practices. We will take measures as required to comply with Philippine law regarding the transfer, storage, and use of certain personal information.
1.2. What Information We Collect
As mandated by the Bangko Sentral ng Pilipinas (“BSP”) and the Anti Money Laundering Council (“AMLC”), in the usual course of banking business activities and for purposes of know-your-client (KYC), identity verification (IDV), customer due diligence (CDD), and transactions monitoring, we collect the following personal information from you and about you, including, but not limited to:
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1.2.1. Client Information (Information belonging to our Clients)
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i. Name;
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ii. Date and place of birth
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iii. Citizenship or nationality
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iv. Complete Address;
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v. Mobile Number;
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vi. Landline Number;
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vii. Email Address;
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viii. Virtual Asset Wallet Address;
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ix. Specimen signature or biometrics of the Client
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x. For Corporate Account, Information regarding your business entity such as, but not limited to:
a. Certificate of Incorporation
b. Latest Articles of Incorporation;
c. Latest By-Laws;
d. General Information Sheet;
e. Audited Financial Statement;
f. Secretary’s Certificate
g. Business Permit
h. BIR Registration
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xi. Any other information that may be requested to better establish the identity of the Client;
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xii. Any other information relevant to the efficient use of our Service;
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xiii. Any other information required by existing laws and regulations.
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1.2.2. Transactional Information
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i. Amount remitted
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ii. Any other information that may be requested to better establish the authenticity of the transaction/s involved;
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1.2.3. IP addresses
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1.2.4. Any personal information that may be disclosed when you interact with us.
1.3. Maintenance of Accuracy
To maintain accuracy of personal information, you may access the Services at any time and change any inaccuracies you may find by requesting to update your profile with us. You also have the option to delete your information from our database by updating your profile or sending us an email requesting for such deletion. Upon such change or request from a member, we shall notify third parties who have previously received or processed such information.
Pursuant to anti-money laundering (AML) regulations, if the records relate to on-going investigations or transactions that have been the subject of a money laundering case, they shall be retained beyond the stipulated retention period until it is confirmed that the case has been closed and terminated.
Pursuant to the Bureau of Internal Revenue Regulation No. 17-2013, documents pertaining to your billing statements, which indicate taxable transactions shall be preserved for ten (10) years. Further, we will keep your personal information as long as it is necessary: a) for the fulfillment of the declared, specified, and legitimate purposes provided above, or when the processing relevant to the purposes has been terminated; b) for the establishment, exercise or defense of legal claims; or c) for legitimate business purposes, which shall be in accordance with the standards of the banking industry.
1.4. How We Use Your Personal Information
Information you provide us may be collected and processed internally, or by authorized third parties. By using our Services, you consent to the collection, transfer, processing, and storage of information we collect whether done within or outside of the Philippines. We assure you that our actions concerning your personal information will be guided by this Privacy Policy.
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1.4.1. Delivery of Services
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1.4.2. Communications
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i. To send communication regarding the verification and updating of your personal information and sensitive personal information for purposes of Know-Your-Customers policy in accordance with law and regulations, which includes email liveness tests, and request for submission of documents and for updating of customer records.
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ii. To send email, SMS, and notifications regarding your Transaction/s with us including official receipts;
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iii. To send promotions relating to our services or products and services of authorized third parties; and
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iv. To send updates regarding our services and regarding communication from government regulatory and enforcement agencies.
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Members may opt out of these communications, except those which are required by our internal policies and by government regulations to be communicated to you.
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1.4.3. Service Improvement and Market Analysis
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We constantly strive to improve our Services and user experience. We will use your information to guide us in these efforts, to ensure that our services remain at the cutting edge and to ensure that your user experience remains pleasant and efficient. In addition, we will also use your information for assessment, record-keeping, market analysis, and generation of reports.
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We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyze your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services.
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1.4.4. Expanded Data Segmentation
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i. Connect behavioral data on our Platform (buying and selling actions) with your customer profile and demographics; and
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ii. Extract patterns of behavior based on the profiles we can identify from the information you have given us.
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1.4.5. Information Sharing
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Subject to applicable law, we may share, preserve, transfer, and disclose the information we collect, to the following:
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i. Companies that form part of our group of companies, to enable them to offer or improve their respective services or products;
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ii. Service providers that help us provide our services, to the extent needed to perform their duties and their functions, including service providers used for the logistics;
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Iii. To our officers, directors, partners, consultants, employees, agents, auditors, advisors or any other representatives on a need-to-know basis, to the extent needed for the fulfillment of the services;
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iv. Government regulators that have regulatory oversight and jurisdiction over Moneybees;
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v. Government authorities, in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that we are required to do so under the law;
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vi. Government regulatory and/or enforcement agencies in the Philippines and other jurisdictions for reports relating to your account history including, but not limited to limit increase requests, limit breaches, covered and suspicious transactions, and other reports ordered or requested by such regulatory and/or enforcement agencies;
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vii. Third-party service providers, partners or the like entities engaged by Moneybees to offer its products and services, and to assist in the administration and/or maintenance of its products, facilities, and services; and
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viii. Purchasers or potential purchasers of our rights and obligations relating to the Services we provide, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. In this case, all information collected are deemed assets that may be transferred to such third parties.
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1.4.6. Necessary to Protect Legitimate Interests, (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
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The information we collect may also be shared, transferred and disclosed when this is necessary:
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i. To protect our rights and interests and those of our business partners, customers or third parties, as may be required and permitted by law;
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ii. To detect, prevent and address fraud and other illegal activity;
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iii. To establish, exercise, or defend legal claims of the Company and the Related Parties; and
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iv. To pursue your legitimate interests, as may be required or permitted by law.
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1.5. Data Retention and Disposal
We will retain the personal data for as long as you maintain an account with us, or for a period of five (5) years, in accordance with guidelines issued by the BSP and the AMLC on the maintenance of records. You may request for the deletion of your personal data or information by contacting us through our official privacy email address: [email protected], if you no longer wish to keep your account, subject to existing laws, rules and regulations on data retention.
1.6. How We Secure Your Personal Information
We will protect your information through the use of secured servers within Asia-Pacific in the cloud, with up-to-date security protocols and technologies in place. Sufficient physical and technical methods and procedures are employed to safeguard and secure the information from unauthorized or unlawful processing. We utilize security measures such as instance security groups, access control lists, and private-public key pairs to prevent unauthorized personnel from accessing data from our servers. We authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
Our cloud vendor, Amazon Web Services (AWS), ensures security for the physical hardware, software, networking, and facilities that run their services, as defined in their AWS Security Whitepaper. We may request AWS to provide reports from third-party auditors who have verified compliance with a variety of computer security standards and regulations.
We use TLS / SSL (Transport Layer Security / Secure Sockets Layer) to ensure that data is encrypted while being transferred over the wire. We always use HTTPS (Hypertext Transfer Protocol Secure) for all our websites and web applications, to ensure all of our data to and from browsers are encrypted in transit.
1.7. Data Subject Rights
Please be informed that you have the following rights under the Data Privacy Act of 2012:
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1.7.1. Access Personal Data
- You may request access to any of the personal data held by the Company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer.
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1.7.2. Make Corrections to Personal Data
- It is your responsibility to inform us of any changes to the personal data that you have supplied during the course of your engagement.
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1.7.3. Object to the Processing of Personal Data
- You have the right to object to the processing of the personal data, including processing for direct marketing, automated processing, or profiling. You shall also be notified and be given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to you in this privacy notice.
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1.7.4. Erasure or Blocking of Personal Data
- You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our systems. Please note that depending on the type of personal information involved, you may be restricted from accessing any of our Services.
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1.7.5. Be Informed of the Existence of Processing of Personal Data
- You have a right to be informed whether personal data pertaining to you shall be, are being or have been processed, including the existence of automated decision-making and profiling.
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1.7.6. Damages
- Upon presentation of a valid decision, you have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
1.8. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to be responsible for our privacy program. If you have any questions about how we protect or use your Personal Information or about this Privacy Policy, you may contact us using the information below:
Data Privacy Officer
Moneybees Forex Corporation
Address: 4th Floor, Unit C & D Commerce and Industry Plaza Building, 1030 Campus Avenue, McKinley Hill, Taguig City, Philippines
Email: [email protected]
Our DPO will provide an initial response to your questions or complaint within five (5) business days and investigate and attempt to resolve your complaint within fifteen (15) business days. If a longer period is necessary, we will notify you accordingly.
1.9. Questions, Concerns, and Complaints
In case of complaints, concerns, or questions regarding our privacy policy or if you wish to exercise your data subject rights, you may address them to: [email protected].
For more details, please visit the website of the National Privacy Commission at https://privacy.gov.ph.
1.10. Changes to the Privacy Policy
If we modify this Privacy Policy, we will make it available through our Privacy Policy page and indicate the date of the latest revision.
