PRIVACY POLICY

WHO WE ARE

SUYEN CORPORATION (“Corporation”, “we”, “us” or “our”) is licensed to use the Trademarks of the ALDO Brand registered in the Philippines owned by Aldo Group International AG (Switzerland). The Corporation is also authorized by contract to operate the Sites of this brand found in https://www.aldoshoes.com.ph (“Website”). The terms of this Privacy Policy cover all of our operations through the Websites and our stores in the Philippines. This Privacy Policy describes how we, through all channels of communication, whether online on our Websites in Philippines or in person in any of our ALDO (“Stores”), process, collect, use, and disclose the personal information (as defined below) of its visitors (“you”, “your”, or “yours”).

We are committed to protecting your privacy rights and recognize the importance of protecting the information that we collect about you. We have prepared this Privacy Policy to describe to you our practices regarding the personal information we collect directly from users of our Site and recipients of our emails, including use of any of our services (through a mobile device or otherwise) or other offerings (collectively, the “Services”); when you purchase any of our products (“Products”); and as otherwise indicated in this Privacy Policy.

In conjunction with this Privacy Policy, you should also review our Terms of Service for a more complete understanding of the rules governing our Site, Products, and Services.

By visiting our Site, purchasing our Products, or using our Services, you acknowledge that we handle your personal information under the terms of this Privacy Policy, and you understand that our collection, use, and disclosure of your personal information is as set out in this Privacy Policy.

INFORMATION WE COLLECT
We may collect information about you in a variety of different ways:

1. Information you provide to us, such as while making a purchase, signing up for a loyalty or rewards program.

Online Order Information
When you make a purchase from our Websites or mobile apps, we may ask you to provide us with information about your purchase such as your name, email address, shipping address, phone number, date of birth, and payment information.

In-Store
When you visit one of our Stores, we may ask you for certain information at the point of sale or while interacting with one of our team members. This may include payment information, product information (such as shoe size), and other information about your purchase, including your name, email address, shipping address, and phone number.

If you connect your social media account to your online account, you will share certain personal information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be accessible to us when you connect your social media account to your online account.

Marketing Communications
If you would like to receive marketing communications from us, you may do so by signing up on our Websites or in our Stores. We will ask you to provide your email address or phone number so we can send you marketing materials. We also collect information when you participate in a contest or answer a survey.

Communicating with us
When you contact us about a customer service issue, or to make other inquiries, we collect the content of those communications, and any additional information about the method of communication such as phone, SMS, email, chat, or through social media platforms. For example, if you email us, we will collect your email address, if you send us a text message, we will collect your phone number, and so on.

Loyalty & Rewards Programs
If you enroll in a loyalty or rewards program such as the Aldo Crew, we collect information such as your name, email, telephone number, date of birth (optional), or mailing address in order to track your rewards, send you a birthday gift, and allow you to redeem them across our brands.

2. Information we collect while you interact with our Website, other apps, social media sites, and other products and services. This often involves information about your device such as IP addresses and MAC addresses, as well as information collected through cookies.

Websites
When you visit one of our Websites or use our mobile apps we may collect your device identifier such as IP address or MAC address, as well as browser and settings information, shopping preferences, and information about how you interact with our Websites and other digital products.

3. Information we collect about you from other sources, such as data analytics firms

Investigations
We may collect information about you in connection with investigations into fraudulent or criminal activities on our Websites, mobile apps, and in our Stores.

Other Sources
We may also collect information from other sources, including for example, joint marketing partners, data analytics firms, publicly available social media pages, and other third parties we work with.

4. Information we create, aggregate, or derive ourselves after we analyze the information, we collected about you, such as your shopping preferences.

Aggregated information
We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose. For example, we may calculate the percentage of our site users who have a particular telephone area code.

COOKIES

Strictly Necessary Cookies
Like many commercial websites, we also automatically collect information by way of electronic means, using cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. Most websites, including ours, wouldn’t work very well without certain cookies. They allow us to prevent crashes, display information, fix bugs, and ensure the security of our site (and your account). These types of cookies are often called “strictly necessary” cookies. Because they are needed for our sites to work, we don’t provide you with an ability to opt-out of these cookies. But you can remove them by using your browser settings. Keep in mind that certain features of our sites may not be available to you.

Why we use strictly necessary cookies:
• Technical reasons: cookies are used for technical reasons to enable the efficient working of our Websites, for example, to:
o Balance website traffic to ensure our customers receive a consistent and reliable service;
o Limit traffic to key parts of the website to maintain performance levels;
o Facilitate your usage of our Websites; and
o Store your acceptance of the Privacy Policy, cookies policy and website terms and conditions, without which access is not granted to our Websites.

Functional Cookies
Some cookies provide important services but are not strictly necessary for our Websites to work. These cookies use information about your interactions with us so we can suggest our Products and special offers for you or allow you to purchase our Products during a live streaming event. If your shopping is interrupted, they remember where you left off and send you reminders that you truly deserve that new pair of shoes. These reminders might be sent to you in an email, on social media, or while you’re browsing another website or on another device. We think these cookies are useful and will make it easier for you to shop with us. But you might disagree. If so, you can tell us not to use certain cookies by using the opt-out tools we have placed on our Websites. These options vary by geographic region

Interest based Marketing and Targeting
We may use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you (interest-based advertising). Interest-based marketing is a way of serving advertisements on the websites you visit and make them more relevant to you and your interests: shared interests are grouped together based upon previous web browsing activity and web users are then served advertising which matches their shared interests. This way, advertising can be made as relevant and useful as possible. Relevant ads can also be delivered based upon the website content you have just been viewing. This is known as retargeting.

We conduct remarketing campaigns using the Google Ads platform to advertise across the Internet, in particular on the Google Display Network. AdWords remarketing will display ads to you based on what parts of our Websites you have viewed by placing a cookie on your web browser. This cookie does not in any way identify you or give access to your computer or mobile device, it is only used to indicate to other websites that you visited a particular page and show them ads relating to that page. Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.

If you do not wish to see ads from us, you can opt out in several ways:

1. Opt out of Google’s use of cookies by visiting Google’s Ads Settings.
2. Opt out of a third-party vendor’s use of cookies by visiting the following links and help you opt-out of online interest-based marketing:
a. Network Advertising Initiative (NAI) - https://optout.networkadvertising.org/
b. Digital Advertising Alliance (DAA) - https://optout.aboutads.info/
3. Opt out of Instagram and Facebook’s targeted marketing by following the steps laid out in their respective Privacy and Cookie policies and/or websites. This won’t stop them from tracking you, it simply means that information won’t be used to show ads targeted to you.

However, doing so:
• does not mean that the advertising of our Products and Services on our own Websites will stop being personalized to your interests;
• may not stop all online behavioral advertising, since these websites apply to the third-party advertising agencies that have signed up to those services; and
• does not mean that there will no more advertising on our Websites or other websites you access. However, the advertising that you do see is likely to be less relevant to your interests.

Deleting browser cookies can remove your opt-out preferences, so you may need to opt out again.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info

Note on Do Not Track
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser. For information about Do Not Track, please visit: www.allaboutdnt.org

HOW & WHY WE USE YOUR PERSONAL INFORMATION

We use your personal information to provide you with our products and services and to operate our business. We often use the information we collect for multiple purposes. For example, if you make a purchase on our website, we collect several types of data from you and use it in multiple ways:

• We use your shipping address to make sure that our products arrive at your door.
• We may also use your contact information to send you a receipt of purchase.
• We may look at your experience on our website to make improvements to it and try to tailor it to your needs.
• We will also analyze the data you provide us and your behavior on our website to ensure that the activity is not fraudulent.
• We use your purchase information for other business-related purposes like accounting and financial reporting.
• We may also combine information we collect from you with information we obtain from other sources. This may include your online and in-store purchase transactions and other interactions you have with us and our partners.
• We often obtain your consent to use your information. But sometimes, obtaining your consent is not needed because we may use your information for our own legitimate interests, to fulfill a contract with you, or to comply with legal obligations imposed on us. For example, when you make purchases online, we process your information to fulfill our contractual obligations. When you visit our websites, we have a legitimate interest in using your browsing data to improve our site’s usability, and when you engage with us online, we have a legal obligation to ensure that you are not attempting to defraud, us or our customers.

If at any time you no longer wish to be contacted for marketing purposes, you can click on the link at the bottom of any promotional message or contact us at the contact information provided in the section “Contact”.

Providing you with Products and Services
We use your information to process, fulfill, and communicate with you about your orders, respond to your customer service inquiries, allow you to use in-store and online technologies, enroll you in rewards and loyalty programs, and to inform you of policy or product changes that may impact you. When we use information in this way, we do so for the purpose of fulfilling a contract with you, or to comply with a legal obligation.


For Marketing Communications and Promotions
We use your personal information to send you marketing communications about our Products and Services, contests, and promotions. We may send you emails, postal mail, text messages, phone calls, or social media messages that we believe you would be interested in. We will only send you marketing campaigns if you have specifically agreed to receive them. Note that you may always opt out of them at a later date.

If you no longer wish to be contacted for marketing purposes, please click on the link at the bottom of any promotional message or contact us at the contact information provided in the section “Contact”. However, should you wish for your details to be removed from our customer relationship management system completely, you will need to contact our Customer Services using the contact details in our Site.

For Business Reporting and Providing Personalized Services and Ads
We use your personal information to analyze or predict our customer preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Products and Services. We also use personal information to better understand you and your preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. We use information in this way with your consent or because we have a legitimate interest to do so.

Allowing you to participate in promotions and events
We may use your personal information to allow you to participate in local community events, promotions, and in-store experiences. Some of these may have additional rules containing information about how we will use and disclose your personal information. We use this information for the purpose of fulfilling a contract with you or because we have a legitimate interest to do so.

For other business purposes
We may use your personal information to learn more about our customer base, perform data analyses, address problems with our technology, improve our products and services or develop new ones, to investigate and prevent fraud or other illegal activity, to enforce our Terms of Sale and Use, and to provide a more consistent experience across our brands and channels. We may also use your information where we believe it is required to protect the rights, property, safety and security of the Corporation or The Aldo Group Inc., our employees, customers, and others. Finally, we may be required to use your personal information to comply with applicable law, for auditing purposes, or to respond to requests from government authorities. We will engage in these activities to fulfill a contract with you, to comply with a legal obligation, and/or because we have a legitimate interest in doing so.

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with our affiliated companies and brands, with third parties who provide services to you or us, with promotional partners, with social media companies, or with other third parties as needed to carry out our business, or comply with a legal obligation.

Public Authorities
We may share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Internal and Services-Related Usage
We use your personal information to continue improving and developing Products and Services that we may offer you, and to optimize your experience with us. Further, we use and retain information, including personal information, to analyze interactions with and performance of our Services, and to improve, supplement, or enhance our Services, or develop new Products and Services.

Affiliates
We may share your personal information with our affiliates, which may include a parent company, subsidiaries, joint venture parties, or other companies that we control or are under common control with us, in which case their use of your personal information will be treated in accordance with this Privacy Policy. Further, in the event of a corporate sale, merger, reorganization, spin-off, or similar event, we expect that information that we have collected, including personal information, would be transferred to one or more surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Displaying to Other Users
Any content that you post in a publicly viewable forum through our Services may be publicly displayed on our Site. You acknowledge and understand that any such channel or forum are for the public and not private mode of communication.

Information to Process Your Purchases
We may also share your personal information with the following third parties and for the following reasons:

• With financial institutions, credit card companies, credit reference agencies, and anti-fraud screening service providers to process payments and (where necessary) to carry out fraud-screening.
• Technical services providers, logistic, transport, delivery partners, and providers of customer support, to complete the contract that we have with you.
• Advertising and marketing related partners, to assist us in our marketing campaigns.
• Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf.

Information From Third Parties
We may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. We also collect information from third parties in order to enhance our ability to serve you, to tailor our content to you, to offer you information that we believe may be of interest to you, and to inform our commercial and operational decisions.

Third Party Payment Services
We make certain third-party payment service processors available to you. If you wish to use one of these services, your personal information will be collected by such third party and will be subject to the third party’s privacy policy. We have no control over, and are not responsible for this third party’s collection, use, and disclosure of your personal information.

Data Security And Risks Of Processing
We implement commercially reasonable and appropriate physical, administrative, and technical security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. While we implement these security measures with respect to our Websites, please note however that no data transmissions over the Internet can be guaranteed as 100% secure. Your own conduct may dictate your level of protection. As such, we cannot guarantee the security of any personal information you transmit to us. You understand that any personal information that you transfer to us is done at your own risk.

Nonetheless, our employees operate and hold personal data under strict confidentiality. They are required to sign non-disclosure agreements and have received training on the Corporation’s privacy and security policies to ensure confidentiality and security of personal data.

Rest assured that we only share your personal information to non-affiliated third parties in the ways permitted by applicable law or that are outlined within this Privacy Policy. Furthermore, if the disclosure of information contemplated within this Privacy Policy involves a transfer of the information to jurisdictions located outside your country of residence which does not have equivalent regulation regarding data privacy obligations, we will ensure that such recipient offers an adequate level of protection of your personal information, and if such a thing is not possible, we will ask for your prior consent before engaging in such a data transfers, detailing the information, the purposes, and the person with whom we intent to share the information.

How We Store Your Personal Information
Aldo is a global brand with a global footprint, but the majority of the personal information that we collect thru the Websites is stored in a secured server located in the Philippines. Your personal information may be subject to the laws of the countries in which it is stored or used. By providing us with any personal information, you understand that your information may be transferred, processed, or stored outside of your country of residence, which may have a different data protection regime from the country in which you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

Retention & Disposal Of Your Personal Information
When you place an order for Products through the Websites, we will retain your personal information for our records as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, as necessary or appropriate to provide the Services, and for business continuity purposes, unless and until you ask us to erase this information or after ten (10) years from the date of your last activity. We also retain information as permitted or required under applicable law to comply with applicable law, to resolve disputes, and to enforce our rights and agreements.

We will permanently delete your personal data when it is no longer reasonably required for the above-stated purposes or when you withdraw your consent (where applicable) or delete your account, provided that we are not legally required or otherwise permitted to continue to hold such data. If we are unable, for technical reasons, to delete some information from our systems, we will inform you and put in place appropriate measures to prevent any further use of the data. We may use anonymized data indefinitely.

International Visitors
The Sites are hosted in the Philippines and are intended for users located in the Philippines. However, like almost every website, our Sites can be accessed by international visitors. If you are located outside of the Philippines, please be aware that information we collect, including personal information, will be transferred to, and processed, and stored in the Philippines. The data protection laws in the Philippines may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the Philippines according to laws of the Philippines. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions which may have less stringent privacy practices than your own.

By using these Sites or providing us with any information, you consent to the transfer to, processing, usage, sharing, and storage of your information, including personal information, in the Philippines as set forth in this Privacy Policy.

Third-Party Websites And Features
The Sites may contain links to other websites and may include or contain certain social media or other features provided by third party platforms (i.e., the ability to share to Facebook or the Facebook Like button). These features may collect certain of your information and may set a cookie to enable the feature to function properly. The use of these third-party feature may involve the third-party operator providing certain information, including personal information, to us. If you click on social media icons on the Websites (such as for Facebook, Twitter or Instagram), we may have access to your personal information you provided on those third-party sites or applications. Your interactions with these features or other website are governed by the privacy policy of the third-party providing it. Our Privacy Policy applies only to our Websites.

Minors
The Websites are not intended for individuals under the age of 18. We do not knowingly collect personal information online from visitors in this age group without parental consent. If you are the parent or guardian and believe your child under 18 of age has provided us with personal information, please contact us to request deletion at the contact information provided in the section “Contact”.

Policy Changes
This Privacy Policy may be changed from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons, and will post any changes on this page. To the fullest extent permitted by applicable law, our use of information is governed by the Privacy Policy in effect at the time we use the information. By accessing the Webites after any such changes to this Privacy Policy, you are deemed to have accepted such changes.

Your Right To Control How Your Personal Information Is Used
You have the right to make requests regarding your personal information under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA”). Among others, you can:

1. Review the personal information we have about you or request a copy of it;
2. Ask us to update or correct personal information if it is inaccurate;
3. Request that we delete your personal information;
4. Opt-out of sharing your personal information with third parties for some purposes, including sharing that may be defined as sale under applicable laws;
5. Object to certain types of uses of your personal information;
6. Make choices about receiving email marketing; and
7. Tell us which cookies you want us to use when you shop online.

We will make reasonable efforts to honor your request regarding your personal information. If you ask us to delete or stop using your personal information, we may not be able to honor that request if we are required by law to retain such information or to process your payments or returns, fulfill your order, or comply with tax, audit or regulatory requirements.

To submit a request for access or deletion of your personal information, please contact us through:

By Email: dpo@benchmail.ph;
cc: ecommerce@benchmail.ph & aldo.support@benchmail.ph
By Mail:
Attention: Data Protection Officer
Suyen Corporation
Penthouse, Bench Tower, 30th St., corner Rizal Drive, Bonifacio Global City, Taguig City

If you wish to receive a copy of any other information we hold on you, we recommend that you make a request in writing and include the following information with your request:

1. Name and postal address;
2. Details of your request;
3. Corroborating information to establish your identity (e.g. photocopy of your valid government ID); and
4. Signature and date of the request.

If you are applying on behalf of another person, then signed authority from the individual is required.

When collecting personal information to verify your identity, we will only use that information for the purpose of completing verification. Regardless of your rights, we may not be able to alter or delete certain personal information if we are required to retain it to provide you with Services that you have requested or for us to fulfill other obligations to you, for security reasons, to comply with applicable law or regulations, for internal business, or other valid reasons.

Any information supplied or declaration made to you on these matters shall not be amended without prior notification. Provided, that the notification shall not apply should the personal information be needed pursuant to a subpoena or when the collection and processing are for obvious purposes, including when it is necessary for the performance of or in relation to a contract or service or when the information is being collected and processed as a result of legal obligation.

Furthermore, information that you have shared with others such as reviews or forum postings may continue to be publicly visible, and some copies of your information (e.g. log records, residual copies) may remain in our database, after being however anonymized.


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