Date Posted: Aug 14, 2018

Data Protection Policy - Part I

The purpose of this document ("Data Protection Policy") is to inform you how the PNB Savings Bank (“PNB Savings”) manage Personal Data (as defined below) which is subject to the Data Privacy Act of 2012 (R. A. No. 10173 or "the Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with PNB Savings and its related companies and entities (the “Companies”) as well as their respective representatives and/or agents ("Representatives"), collectively referred to herein as "PNB Savings", "us", "we" or "our"), submitting information to us, or signing up for any products or services offered by us, you agree and consent to PNB Savings collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to PNB Savings Bank’s authorized service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to PNB Savings with respect to your Personal Data, and your consents herein are additional to any rights which PNB Savings may have at law to collect, use or disclose your Personal Data.

PNB Savings may, from time to time, update this Data Protection Policy to ensure that this Data Protection Policy is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website: Please check our website regularly for updated information on the handling of your Personal Data.

I. Personal Data
In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from the data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include (depending on the nature of your transaction with us) your name, valid identification documents, contact number(s), mailing address, email address, transactional data and any other information which you have provided us in any forms you may have submitted to us, including biometric data, or via other forms of interaction with you.

II. Collection of Personal Data
1. Generally, we collect Personal Data in the following ways:
a. When you submit any form including, but not limited to, application forms or other forms relating to any of our products or services or any investments which you avail through PNB Savings;
b. When you enter into any agreement or provide other documentation or information in respect of your transactions with us, or when you avail of our products and services;
c. When you interact with our personnel, including relationship managers, branch managers and their assistants, like via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
d. When your images are captured by us via closed-circuit television cameras ("CCTVs"), or other equipment or devices while you are within our premises or when you attend events hosted by us;
e. When you use some of our products and services provided through online and other technology platforms, such as websites and apps;
f. When you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, promotional campaigns and other marketing activities;
g. When you are contacted by, and respond to, our marketing representatives, agents and other service providers;
h. When we seek information about you and receive your Personal Data from third parties in connection with your relationship and transactions with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
i. In connection with any investigation, litigation, or inquiry which may relate to you or any Connected Person. "Connected Person" may include but is not limited to any beneficial owner, authorized signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, attorney-in-fact, surety, third party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents, or nominees; and/or
j. When you submit your Personal Data to us for any other reason.

2. When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.
3. If you provide us with any Personal Data relating to a third party (your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party in providing us with his / her Personal Data for the respective purposes.
4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You agree to inform PNB Savings immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as PNB Savings may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

III. Purposes for the Collection, Use and Disclosure of Your Personal Data
1. Generally, PNB Savings collects, uses and discloses your Personal Data for the following purposes:
a. Responding to, processing, handling of, and resolving your complaints, queries, requests, feedbacks and suggestions;
b. Verifying your identity and customer due diligence;
c. Managing the administrative and business operations of PNB Savings, complying with internal policies and procedures including, but not limited to, facilitating business continuity planning;
d. Audit purposes;
e. Verifying or confirming trade orders or instructions from you or for your account including, but not limited to, instructions on fund transfers or remittances;
f. Facilitating business asset transactions which may extend to any mergers, acquisitions, or asset sales involving any of the Companies;
g. Matching any Personal Data held which relates to you for any of the purposes listed herein;
h. Preventing, detecting, and investigating crime, including fraud and money laundering or terrorist financing, and analyzing and managing commercial risk including, but not limited to, preventing and detecting loss of PNB Savings Bank’s proprietary and sensitive information,
i. Providing media announcements and responses like in relation to complaints or lawsuits;
j. Requesting feedback or participation in surveys, as well as conducting market research and/or for statistical, profiling or other purposes for us to design our products, understand customer behavior, preferences and market trends, and to review, develop and improve the quality of our products and services;
k. Project Management;
l. Managing the safety and security of our premises and services including, but not limited to, carrying out CCTV surveillance and conducting security clearances;
m. Managing and preparing reports on incidents and accidents;
n. Organizing events, seminars, and trainings;
o. Complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements, or arrangements for collecting, using, and disclosing Personal Data that apply to PNB Savings or that it is expected to comply, according to:
i. Any law binding or applying to it within or outside Philippines, existing currently and in the future;
ii. Any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations within or outside Philippines, existing currently and in the future; and/or
iii. Any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations that is assumed by or imposed on PNB Savings by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations.
p. To assist in law enforcement and investigations by relevant authorities;
q. In connection with any claims, actions or proceedings including, but not limited to, drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution, and/or protecting and enforcing our contractual and legal rights and obligations;
r. Archival management including, but not limited to, warehouse storage and retrievals; and/or
s. Any other purpose relating to any of the above.
These purposes may also apply even if you do not maintain any account with us, or have terminated such account.

2. In addition, PNB Savings collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

a. If you are a prospective customer:
i. Evaluating your eligibility to open an account with us and your financial and banking needs, and providing recommendations to you as to the type of products and services suited to your needs;
ii. Assessing and processing any applications or requests made by you for products and services offered by PNB Savings; and/or
iii. Any other purpose relating to any of the above.

b. If you are a customer holding an account with PNB Savings or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager, or other similar official who has been so appointed pursuant to bankruptcy or insolvency proceedings instituted in Philippines or elsewhere in respect of a PNB Savings customer or any security provider:
i. Opening, maintaining or closing of accounts and our establishing or providing banking and trust services to you;
ii. Processing fund transfers or any other instructions on your account;
iii. Where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number/s to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and/or in accordance with the terms and conditions of our agreement with you;
iv. Processing applications for and facilitating the daily operation of services and credit facilities provided to you or other persons or corporations for whom you act as surety or third party service provider;
v. Conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;
vi. Facilitating or processing your application for insurance products and/or trust services offered by PNB Savings and its business partners;
vii. Carrying out client reviews, for example, annual reviews of your portfolio;
viii. Establishing your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
ix. Providing internet banking services including, but not limited to, carrying out special handling requests for PIN mailers and tokens;
x. Networking to maintain customer relationship;
xi. Providing client servicing including, but not limited to, responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction;
xii. Facilitating the transfer of funds within PNB Savings bank accounts or from PNB Savings accounts to external bank accounts and vice versa;
xiii. Administering exceptional approvals, fee adjustments or waivers;
xiv. Dealing with and designing investment products like bonds, derivatives, equities, funds;
xv. Registering the pledge or charge that you or the security or the third party security provider has granted in favor of PNB Savings as security for the credit facilities granted by PNB Savings;
xvi. Administering credit, debit, prepaid or cash cards including, but not limited to, processing card applications, transactions and credit limit approvals;
xvii. Providing check deposits, clearing services;
xviii. Determining and collecting amounts owed by you or the borrower for whom you act as surety or third party security provider or those providing security or acting as surety for your liabilities and obligations;
xix. Enabling any Company or third party to perform the functions that PNB Savings may have outsourced to it in relation to the management of your account or transactions;
xx. Enabling an actual or proposed assignee of PNB Savings, or participant, or sub-participant or transferee of PNB Savings Bank’s rights, liabilities or obligations in respect to (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and/or
xxi. Any other purpose relating to any of the above.

c. If you are an employee or agent of a referrer or other intermediary:
i. Marketing services and products;
ii. Processing commission remuneration;
iii. Performing due diligence and reference checks; and/or
iv. Any other purpose relating to any of the above.

d. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by PNB Savings;
i. Managing project tenders or the supply of goods and services;
ii. Processing and payment of vendor invoices;
iii. Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities which includes disclosure to regulatory bodies or audit checks; and/or
iv. Any other purpose relating to any of the above.

e. If you are a party or counterparty to a transaction like beneficiary of a fund transfer or payment:
i. Providing cash, payment and transactional services including, but not limited to, the execution, settlement, reporting and/or clearing of the relevant transaction; and/or
ii. Any other purpose relating to any of the above.