Legal Policy

1.0 Purpose

• The purpose of this policy is to protect the data or personal information acquired by JETOUR AUTO PHILIPPINES INC., from its website or Apps from individuals, business or companies who visits the website or App for purposes of inquiry, transacting business with JETOUR AUTO PHILIPPINES INC. and browsing. This policy assures security of information gathered while ensuring free flow of information for effective and efficient transactions.

2.0 Scope

This applies to data or information whether personal, sensitive or business data acquired by JETOUR AUTO PHILIPPINES INC..

The policy comprises the following:

1. The Data collected

2. How the data is collected

3. Purpose of gathering the data

4. What to do with the data gathered

5. Data storage, disclosure and sharing

6. Security of Information

7. Data Retention and Disposal

8. Control of Data

9. Data Privacy Officer and Contact Information

3.0 Definition of Terms

a. JETOUR AUTO PHILIPPINES INC.

- refers to JETOUR AUTO PHILIPPINES INC., its employees, board of directors, stockholders, officers.

b. JETOUR AUTO PHILIPPINES INC. affiliates and subsidiaries

- refers to the sister company of JETOUR AUTO PHILIPPINES INC..

c. Consent of the data subject

- refers to any freely given, specific, informed indication of will, whereby the data subject agrees to the collection and processing of personal information about and/or relating to him or her. Consent shall be evidenced by written, electronic or recorded means. It may also be given on behalf of the data subject by an agent specifically authorized by the data subject to do so.

d. Data subject

- refers to an individual whose personal information is processed.

e. Direct marketing

- refers to communication by whatever means of any advertising or marketing material which is directed to particular individuals.

f. Filing system

- refers to any act of information relating to natural or juridical persons to the extent that, although the information is not processed byequipment operating automatically in response to instructions given for that purpose, the set is structured, either by reference to individuals or by reference to criteria relating to individuals, in such a way that specific information relating to a particular person is readily accessible.

g. Information and Communications System

- refers to a system for generating, sending, receiving, storing or otherwise processing electronic data messages or electronic documents and includes the computer system or other similar device by or which data is recorded, transmitted or stored and any procedure related to the recording, transmission or storage of electronic data, electronic message, or electronic document.

h. Personal information

- 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 by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

i. Personal information controller

- refers to a person or organization who controls the collection, holding, processing or use of personal information, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose personal information on his or her behalf. The term excludes:

(1) A person or organization who performs such functions as instructed by another person or organization; and'

(2) An individual who collects, holds, processes or uses personal information in connection with the individual’s personal, family or household affairs.

j. Personal information processor

- refers to any natural or juridical person qualified to act as such under this Act to whom a personal information controller may outsource the processing of personal data pertaining to a data subject.

k. Processing

- refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.

l. Privileged information

- refers to any and all forms of data which under the Rules of Court and other pertinent laws constitute privileged communication.

m. Sensitive personal information

- refers to personal information:

(1) About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;

(2) About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;

(3) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and

(4) Specifically established by an executive order or an act of Congress to be kept classified. 1

n. One System

- is all-in-one management software that JETOUR AUTO PHILIPPINES INC. and its programming partner XWARE I.T. Consultancy has designed and developed specifically for the needs of all JETOUR AUTO PHILIPPINES INC. Dealerships, Purchasing, Unit Sales, Service and Warranty, and Parts Sales, thus, it provides for a streamlined recording of all activities done and in producing coherent and efficient reports.

o. Brand App

- are applications created by JETOUR AUTO PHILIPPINES INC. and its programmers (JETOUR) for its customers for proper identification of products, price, and services.

p. Marketing Activities

- refers to activities related to advertising or marketing and promoting the sale of JETOUR AUTO PHILIPPINES INC. Vehicles, Spare Parts and Services. It involves sending invitation for sales promotion, marketing event, product launches and posting to social media of pictures and events related to JETOUR AUTO PHILIPPINES INC. Products.

q. Data Processing Officer (DPO)

- is the person assigned to monitor internal compliance and ensure that the company processes personal data in compliance with applicable data protection laws and the Data Privacy Manual.

4.0 Personal Information shall include but not limited to the following:

a. Individual

1. Name

2. Address

3. Age

4. Civil Status

5. Contact Information

6. Social Security System (SSS) Information

7. Tax Identification Number (TIN)

8. Philhealth Information

9. Home Development Mutual Fund (Pag-Ibig) Information

10. National Bureau of Investigation (NBI) Clearance

11. Police Clearance

12. Barangay Clearance

13. Birth Certificate

14. Marriage Certificate

15. Birth Certificate of Children

16. Valid government I.D.

17. Pre-employment medical results

18. Family Background

19. Educational Background

20. Work Experiences

21. Data Subject’s Pictures

22. Medical Information or Results

b. Business/ Corporations

1. Corporate Name

2. Corporate Address

3. Representative’s Name

4. Representative’s Address

5. Representative’s Civil Status

6. Representative’s Age

7. Representative’s Contact Information

8. Representative’s Tax Identification Number (TIN)

9. Company Background

10. Company Profile

11. Name of stockholders

12. Name of Directors

13. Name of Corporate Officers

14. Name of Company Representatives

15. Business Permit

16. Department of Trade and Industry (DTI) Registration

17. Articles of Incorporation and By Laws

18. Securities and Exchange Commission (SEC) Certificate

19. General Information Sheet (GIS)

20. Bureau of Internal Revenue (BIR) Registration

21. List of clients

22. List of suppliers

23. Financial Capacity

24. Data Subject’s Pictures and Logo

5.0 How data is collected

The data is collected through the following:

1. When inquiring at JETOUR AUTO PHILIPPINES INC.’s brand website.

2. When participating JETOUR AUTO PHILIPPINES INC.’s marketing activities

3. When communicating with JETOUR AUTO PHILIPPINES INC.

4. Application for employment at JETOUR AUTO PHILIPPINES INC.

5. Employment at JETOUR AUTO PHILIPPINES INC.

6. Upon product or service inquiry

7. Upon request for company accreditation

8. Endorsement of information from our accredited Dealerships

9. During negotiations with JETOUR AUTO PHILIPPINES INC.

10. Upon entering into sales or contractual relationship with JETOUR AUTO PHILIPPINES INC.

11. Upon entering into Business Transaction with JETOUR AUTO PHILIPPINES INC.

12. Walk-in clients

13. Those freely given by the data subject to JETOUR AUTO PHILIPPINES INC..

14. Upon entering JETOUR AUTO PHILIPPINES INC.’s company premises

15. Usage of JETOUR AUTO PHILIPPINES INC. App

6.0 Purpose of gathering data

The gathering of data shall be for the following purpose

a. Sales transactions

b. Service Transactions

c. Contractual Relationships

d. Business Negotiations

e. Business Transactions

f. Purchase Transactions

g. Application for Employment

h. 201 Employment file

i. Marketing Activity

j. Brand Promotions

k. Digital Marketing

l. Supplier Accreditation

m. Invitation for JETOUR AUTO PHILIPPINES INC. events

n. For purposes of providing excellent customer service

7.0 What to do with data gathered

a. Sales/ Parts/ After Sales Transactions or Services

i. Data gathered from browsing our website, communicating with JETOUR AUTO PHILIPPINES INC., marketing activities, inquiries, walk-in clients, or those endorsed by JETOUR AUTO PHILIPPINES INC.’s accredited Dealerships shall be used by our Sales Department for purposes of introducing and selling our products and services.

ii. Data gathered from browsing our website, apps or communicating with JETOUR AUTO PHILIPPINES INC., marketing activities, inquiries and walk-in clients may be endorsed to our Accredited Dealerships for purposes of introducing and selling our products and services to potential clients.

iii. Data gathered from our clients shall likewise be shared to JETOUR AUTO PHILIPPINES INC.’s Manufacturers and Assemblers and JETOUR AUTO PHILIPPINES INC. Suppliers for purposes of providing the utmost customer service to its clients

iv. Data gathered may also be shared to bank partners, insurance companies or government agencies whennecessary for processing of sales and service transactions, bank financing application, application for compulsory third party application for insurance and Land Transportation Office (LTO) registration.

b. Marketing Activity

i. Data gathered shall be used for marketing activities such as invitation for sales promotion, marketing events and product launches whether actual or virtual.

ii. Data gathered shall be used as client references and shall be endorsed to our authorized sales agents and accredited Dealerships for purposes of sales transactions with JETOUR AUTO PHILIPPINES INC..

iii. Data gathered such as pictures of Data Subject during marketing events or business transactions may be used by JETOUR AUTO PHILIPPINES INC. in promotional activities, including digital marketing.

c. Supplier Accreditation

i. Data gathered for purposes of supplier’s accreditation shall be used by JETOUR AUTO PHILIPPINES INC. in accrediting its suppliers for purposes of sales transactions, product inquiries, processing of payments, tax purposes and other related transactions.

d. Contractual Relationship

i. Data gathered shall be used in drafting contracts, memorandums, and other legal documents for purposes of entering into business transactions with JETOUR AUTO PHILIPPINES INC..

e. Legal Matters

i. Data gathered shall be used for establishment, exercise of JETOUR AUTO PHILIPPINES INC.’s legal claims or defense.

f. Business Negotiations

i. Data gathered may be used for negotiations for possible business transactions with JETOUR AUTO PHILIPPINES INC..

g. Purchase Transactions

i. Data gathered shall be used for transactions entered into by JETOUR AUTO PHILIPPINES INC. other than the transactions above- mentioned.

h. Application for Employment and Employment at JETOUR AUTO PHILIPPINES INC.

i. Data gathered from JETOUR AUTO PHILIPPINES INC. employees shall be used for employee information to be submitted to government agencies in connection with their employment, client referrals in terms of sales transactions and services, background investigation and other third party transactions which require divulging employee information for legitimate purpose.

ii. Personal Information gathered from employees or prospective employees may be used in legal claims and defense in cases filed by and against the company.

iii. Personal Information gathered from employees or prospective employees may be divulged to third parties conducting background investigations.

8.0 Data Storage, disclosure and sharing

Data gathered shall be stored at JETOUR AUTO PHILIPPINES INC.’s One System, Digital Data Base, Servers, Cloud, and Warehouses, Filing Cabinets and Vaults.

The name and contact information of unsuccessful employment applicants are stored in JETOUR AUTO PHILIPPINES INC.’s data base and filing cabinets for future reference. Personal Information of JETOUR AUTO PHILIPPINES INC. employees shall be stored in their 201 files Filing and AMS System. Personal information of JETOUR AUTO PHILIPPINES INC. separated employees shall be stored in JETOUR AUTO PHILIPPINES INC. Warehouse and AMS System.

Personal or Business/ Corporate Data of clients, suppliers or those other than the employees of JETOUR AUTO PHILIPPINES INC. shall be disclosed and shared with JETOUR AUTO PHILIPPINES INC. authorized Sales Teams, accredited Dealerships, Assemblers and Manufacturers, Suppliers, Bank Partners, Insurance Companies and to those providing shared services with JETOUR AUTO PHILIPPINES INC., JETOUR AUTO PHILIPPINES INC.’s affiliates and subsidiaries. The personal information shall be stored JETOUR AUTO PHILIPPINES INC.’s One System, Digital Data Base, Servers, Cloud, and Warehouses, Filing Cabinets and Vaults.

The data to be disclosed and shared shall only be limited to such extent necessary to render effective the purpose for which the Data is gathered such as but not limited to transactions with JETOUR AUTO PHILIPPINES INC., marketing activities or employment.

The data collected may also be disclosed to courts and government agencies pursuant to and in compliance with applicable laws and regulations, subpoena or court order.

9.0 Access to personal data/information

Access to Personal Data or Information of employees and applicants shall be restricted to Human Resource and Administration Division, Finance Division and Legal and Compliance Division.

Access to Personal or Business Data of clients, suppliers or those other than the employees of JETOUR AUTO PHILIPPINES INC. shall be limited to Sales and Marketing Division, Dealer Development Division, Legal and Compliance Division and Finance Division.

10.0 Security of information

JETOUR AUTO PHILIPPINES INC. is committed is ensuring the security of the data gathered from the data subject and JETOUR AUTO PHILIPPINES INC. undertakes to make the necessary actions and security measures in collecting, receiving, transmitting, sharing, storing and disposing of the data gathered.

JETOUR AUTO PHILIPPINES INC. likewise undertakes to gather the necessary consent forms in gathering data as well as entering into agreements such as but not limited to Data Sharing Agreement or Non-Disclosure Agreement for the protection of the Data Subjects.

Should there be unauthorized access of data from JETOUR AUTO PHILIPPINES INC. due to hacking, unauthorized sharing of information or downloading of information, or any kind of breach in information, JETOUR AUTO PHILIPPINES INC. shall immediately inform the Data Subject about such breach as well as place security measures to impede the further leakage of Data or breach of information.

11.0 Data retention and disposal

JETOUR AUTO PHILIPPINES INC. shall keep the data only for as long as it is necessary.

Personal information are only kept for five (5) years from the time of its last transaction or communication with JETOUR AUTO PHILIPPINES INC. except when retention thereof for a longer period is necessary such as but not limited to after sales service or if there is an existing or possible legal claim against or by JETOUR AUTO PHILIPPINES INC. from the Data Subject.

The Disposal of the Data shall be through deletion in the ONE System, App, Digital Data Base or shredding or burning of hard copy files.

12.0 Control of data

The Data Subject can request for a copy of his or her personal data or business data and the same may be updated or revised if the same is incorrect or inaccurate.

The Data Subject may likewise request for the deletion, blocking, revision or updating of his or her personal information by writing a letter or email to our Data Privacy Officer.

13.0 Data privacy officer and contact information

Data Privacy Officer

84424076-78 loc. 5122

Email: dpo@JETOUR AUTO PHILIPPINES INC..com

Lot Beside Bldg. 1055 Argonaut Highway, Subic Bay Freeport Zone

Feedback on our Privacy Policy

For questions or feedback about our Privacy Policy, you can email or contact us through the above mentioned contact information

Changes to Policy

JETOUR AUTO PHILIPPINES INC. reserves the right to change, revise or modify this policy as necessary.