Spotter

Sta. Clara International Corporation (“SCIC”, “we”, “us”) is your prime partner in nation-building, delivering legacy projects that contribute to the country’s progress and development, with the vision to be the Philippine’s top global builder and trusted business partner. SCIC aims to be of Service as a well-organized company with the Commitment to generating connectivity as a good business practice with its partners and clients to uphold SCIC’s Integrity in dealing with data and information with strong privacy practices that builds the Character of SCIC in maintaining trust and providing value to its partners, clients, stakeholders, and the public.   PERSONAL INFORMATION WE COLLECT I. Information that you personally give us:

a. When you apply for our services by filling out our forms and other similar or related documents through available channels; b. When you apply for a job with us; c. Become our Partner, Vendor, Contractor or Supplier; d. Get in touch with us for inquiries and/or requests.

II. Information from publicly or commercially available sources. Likewise, we may also obtain information from third parties to whom you have given consent for disclosure relating to you and where lawfully permitted. USE AND DISCLOSURE OF PERSONAL INFORMATION SCIC collects and uses your personal information for the following purposes: I. Create and nurture a relationship with you in order to provide you with the services you need by validating your identity relative to the specific service you availed from us. II. Improve our services and understand your needs and preferences, by being able to validate your identity we can analyze and manage your account in order to train our personnel and plan for future growth. III. Communicate relevant services, advisories, and responses to your questions and requests. IV. Comply with requirements under the law and court order to prevent imminent harm to the public and ensure public safety and order. V. Administration and management for reference and for compliance with applicable laws and regulations, in particular:

a. Management services and outsourcing arrangements b. Risk management c. Workforce management d. Performance management and training e. Administration of compensation and benefits f. Statistical and audit purpose g. Client reporting h. Government reporting i. Other legal and business-related purposes.

Generally, except in certain instances, SCIC will not share or disclose your personal information to third parties. in the event that we do share or disclose your personal information, we ensure that the parties shall use contractual or other reasonable means to ensure that proper safeguards are in place, to ensure the confidentiality, integrity and availability of any and all the personal information processed, prevent its use for unauthorized purposes, and generally, comply with the requirements of the Data Privacy Act of 2012, its Implementing Rules and Regulations, and issuances of the National Privacy Commission. Disclosure or sharing of personal information may be made to accredited/affiliated or independent/non-affiliated third parties, whether or local or foreign may be made as a necessary step for the execution of processes related to a declared purpose or as may reasonably be necessary as provided by law, as follows: I. Partner companies, organizations, or agencies, including subcontractors or prospective business partners that would represent themselves as our service provider and contractor. II. Government agencies and law enforcement. III. Other third parties which require the use of your personal information that is consistent with this policy and related laws.   PROTECTION AND SECURITY SCIC will take reasonable steps to ensure that the personal information collected, used, or disclosed are accurate, complete, and up-to-date by enforcing our privacy policy within the company. We maintain physical, technical, and organizational safeguards to protect your personal information from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction, as follows: I. Restricted and/or limited access to qualified and authorized personnel who handle your information with strict confidentiality. II. Personal information is kept only as long as necessary for the fulfillment of the purposes for which it was processed, exercise of legal claim, legitimate business purpose, or as may be provided by law. III. Use of secure server behind a firewall, encryption and security tools. IV. We let you update your information securely to keep our records accurate.   RETENTION The personal information we processed will be kept active until you request that it be deleted in our system. Should your account be inactive for a period of 10 years, the said account will be marked as inactive. Data including personal information will be completely removed from our file at the expiration of the period allowed by law and shall no longer be searchable and will be completely removed from our files and storage. SCIC reserves the right to retain your personal data under circumstances provided under the Data Privacy Act, or if necessary to resolve disputes, or as may be required to do so by law in good faith in order to comply with any legal obligation to protect the rights and interests or properties of SCIC or its affiliates. In so doing, SCIC will use already reasonable means to limit the use of such data to the extent necessary for the legal purpose it may serve. UPDATES AND CHANGES SCIC may, from time to time, update the privacy policy as may be applicable in compliance with law, rules, issuances, or regulations under the Data Privacy Act, including changes in our business operations to adapt and align with industry practices and for other legitimate purposes. Any update will be posted on our website and will be date stamped to notify you of any update.   CONTACT US For comments, questions, or requests you may get in touch with our Data Privacy Officer at [email protected], with Telephone Number: (02) 63 8706 5155 up to 57, Highway 54 Plaza, EDSA, Wack Wack, Mandaluyong City.   Approval and Effectivity The foregoing Privacy Notice is made effective upon approval of the undersigned Officers of the Company until revoked or amended.