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Privacy Policy

Effective Date: December 2024
Company Name: Syneria Technologies Opc.
Registered Address: 7th Floor, Inoza Tower, 40th Street, Taguig, Metro Manila, Philippines
Contact Email: [email protected]

Purpose and Scope

This Privacy Policy governs the manner in which Syneria Technologies (“Company,” “We,” “Us,” or “Our”) collects, processes, stores, shares, and protects Personal Data in accordance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and all other applicable laws and issuances of the National Privacy Commission (NPC).

This Policy applies to all clients, employees, contractors, consultants, applicants, website users, and any individual whose Personal Data is obtained, processed, or retained by the Company (“Data Subject”).

Definition of Terms

    For purposes of this Policy, the following definitions apply:
  • Personal 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.
  • Sensitive Personal Information includes data relating to an individual’s age, health, government-issued numbers, financial information, or any data classified by law as sensitive.
  • Processing refers to any operation performed upon personal data, including the collection, recording, organization, storage, updating, retrieval, use, or deletion thereof.
  • Data Subject refers to any individual whose personal data is collected and processed by the Company.
  • Data Privacy Act refers to Republic Act No. 10173 and its Implementing Rules and Regulations.

Personal Data We Collect

Depending on the nature of our engagement, we may collect the following categories of Personal Data:

    Client and Customer Data
  • Full name
  • Email address and contact numbers
  • Company details and designation
  • Billing and payment information
  • System logs provided to us during support services
  • Other information necessary to deliver our services

    Employee, Applicant, and Consultant Data
  • Identification documents
  • Government-issued numbers (TIN, SSS, PhilHealth, Pag-IBIG)
  • Employment history and CV details
  • Background check information
  • Payroll details

    Website and System Use
  • IP address
  • Browser type and device identifiers
  • Usage logs
  • Cookies (if applicable)

No data is collected beyond what is necessary for legitimate business purposes.

Legal Basis for Processing

    We process Personal Data only under lawful grounds recognized under the Data Privacy Act, including:
  • Consent of the Data Subject
  • Performance of a contract
  • Compliance with legal obligations
  • Protection of vital interests of the Data Subject
  • Legitimate interest of the Company, provided such interest does not override fundamental rights and freedoms

Purpose of Processing

    Personal Data is collected and processed for the following purposes:
  • Service Delivery – To perform systems integration, consulting, training, managed IT services, database support, and other engagements requested by clients.
  • Account Creation and Verification – To establish identity, maintain accounts, and verify legitimacy.
  • Communications – To send updates, notices, project reports, billing statements, and service-related information.
  • Human Resources – For recruitment, employment, compensation, and benefits administration.
  • Compliance – To meet regulatory, contractual, and audit requirements.
  • Security – To prevent fraud, unauthorized access, and violations of company policies.
  • Business Operations – To improve systems, maintain documentation, and support internal management functions.

Data Sharing and Disclosure

We do not sell or trade Personal Data.

    Personal Data may only be shared under the following lawful conditions:
  • With service providers, contractors, or consultants performing services on our behalf
  • With government agencies, when required by law, subpoena, or lawful order
  • With partner companies, but only when necessary to fulfill contractual obligations
  • With auditors, legal counsel, or regulatory bodies for compliance purposes

All third parties are required to maintain confidentiality and implement security measures consistent with this Policy.

Data Storage, Retention, and Disposal

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.

    Once retention periods expire, Personal Data shall be securely disposed of through:
  • Secure digital deletion
  • File shredding
  • Secure wiping or destruction of storage media
  • Archival measures consistent with NPC standards

Data Security Measures

    We implement organizational, physical, and technical security measures, including but not limited to:
  • Role-based access control
  • Encryption of sensitive records
  • Firewall and network safeguards
  • Strict approval processes for data access
  • Secure storage and transfer protocols
  • Regular security reviews and audits
  • Confidentiality agreements for personnel and contractors
  • Incident response and breach procedures

Despite these measures, no system is entirely immune from risk. The Company ensures reasonable and proportionate safeguards to protect Personal Data.

Rights of the Data Subject

  • Under the Data Privacy Act, Data Subjects have the right to:
  • Be informed of how their personal data is processed
  • Access their personal data
  • Correct or rectify inaccuracies
  • Object to processing based on legitimate interest
  • Suspend, withdraw, or order the blocking or deletion of their personal data
  • Data portability
  • File a complaint with the National Privacy Commission

Requests may be sent to our Data Protection Officer at [email protected]

Data Breach Protocol

    In the event of a data breach involving sensitive or high-risk Personal Data, the Company shall:
  • Conduct a prompt assessment
  • Mitigate and contain the breach
  • Notify the affected Data Subjects when warranted
  • Report the breach to the National Privacy Commission within the prescribed period
  • Document and maintain all breach-related records

Amendments to This Policy

The Company reserves the right to amend or update this Privacy Policy at any time to comply with legal, regulatory, or operational requirements. Revisions will be posted on our website or communicated through appropriate channels.

Contact Information

For inquiries, concerns, or requests related to data privacy, please contact:
Data Protection Officer (DPO)
Syneria Technologies Opc.
Email: [email protected]
Phone: +63.927 431-7464