Privacy Notice and Consent to Processing of Personal Data

1. Personal Information Controller

For personal data processed through Masinloc Connect, the Personal Information Controller is:

Controller

SENZ Strategic Communications and Digital Solutions

Platform

Masinloc Connect

Website

www.masinloc-zambales.com

Privacy contact

hello@masinloc-zambales.com

SENZ determines the purposes and means of processing personal data through Masinloc Connect. Service providers acting on its behalf may process personal data only for authorized purposes and subject to appropriate privacy, confidentiality, and security obligations.

2. Scope

This Notice applies to personal data processed in connection with Masinloc Connect, including information submitted by job seekers, professionals, applicants, business owners, contributors, employers or employer representatives where applicable, website users, and other persons who use or communicate with the platform.

3. Personal Data We May Process

Depending on the service used, Masinloc Connect may process the following categories of personal data:

Identification and contact information

• name and contact details;
• general location, municipality, barangay, or place of residence where relevant;
• age or date of birth where lawfully required;
• information voluntarily provided in forms, inquiries, or communications.

Professional, employment, and résumé information

• education, training, licenses, certifications, work history, skills, qualifications, and professional experience;
• employment preferences, target role, preferred work location, languages, achievements, portfolio links, and professional descriptions;
• résumé information and files voluntarily uploaded by the Data Subject.

Business and contributor information

• business or brand name, business contact information, location, public social links, descriptions, and submitted logos;
• story, history, cultural, photographic, documentary, or other community submissions;
• contributor name and contact details used for verification or clarification.

Technical, security, and usage information

• online, network, device, and session identifiers;
• connection metadata, browser and device characteristics, date and time of access, security events, request records, diagnostic information, and system logs;
• submission reference codes, consent records, access activity, and fraud or abuse indicators.

Masinloc Connect shall seek to collect only personal data that is adequate, relevant, suitable, necessary, and not excessive in relation to the declared purpose.

4. Sensitive Personal Information

Masinloc Connect does not intentionally request Sensitive Personal Information unless it is necessary, proportionate, and supported by a lawful basis. Users should not submit government identification numbers, financial credentials, medical information, or other Sensitive Personal Information unless expressly requested through an authorized process.

If Sensitive Personal Information must be processed, additional safeguards and the appropriate lawful basis shall be applied.

5. Purposes and Lawful Bases for Processing

Personal data may be processed for legitimate and declared purposes, including:

• creating, maintaining, reviewing, and administering submissions or profiles;
• providing résumé, professional-profile, business-submission, community-submission, or related platform services requested by the user;
• verifying information, contacting a submitter for clarification, and reviewing material before publication;
• facilitating professional visibility or recruitment-related services where expressly requested or otherwise lawfully authorized;
• operating, securing, maintaining, diagnosing, and improving the platform;
• preventing spam, fraud, abuse, unauthorized access, malicious activity, and other security threats;
• maintaining records necessary for legal, compliance, audit, security, or dispute-resolution purposes;
• complying with applicable laws, lawful orders, and valid requests of competent authorities;
• establishing, exercising, or defending legal claims.

Depending on the processing activity, Masinloc Connect may rely on consent, performance of a requested service or agreement, compliance with a legal obligation, legitimate interests permitted by law, protection of lawful rights and interests, or another lawful basis recognized under the Data Privacy Act.

6. Publication, Professional Visibility, and Employer Access

Submitting personal information to Masinloc Connect does not, by itself, make the information publicly searchable. A professional profile is not intended to be published where the Data Subject has selected a private option or has not authorized publication.

Where a Data Subject chooses public professional visibility, only information appropriate to the stated public purpose may be published after review.

Where a Data Subject requests employer matching, recruitment support, or another service that requires disclosure to a participating employer, Masinloc Connect may disclose only information reasonably necessary for that purpose and only where supported by an appropriate lawful basis. Employer access does not transfer ownership of a Data Subject's personal data and does not authorize unrestricted copying, resale, publication, scraping, redistribution, or unrelated use.

7. Uploaded Files and Résumé Information

Uploaded résumé files and other materials designated as private are not intended to be publicly indexed or made available through permanent public file links. Access may be limited to authorized personnel or service providers who require the information for the stated purpose.

Users remain responsible for reviewing information before submission and should avoid including information that is unnecessary for the service requested.

If Masinloc Connect later offers artificial intelligence-assisted résumé or profile editing, the relevant processing will be disclosed before use and any consent required by law will be obtained separately. Such tools must not intentionally invent qualifications, employment history, education, certifications, licenses, or achievements not supplied by the Data Subject.

8. Device Storage, Security, and Anti-Abuse Processing

Masinloc Connect may temporarily store an unfinished submission on the user's own device to allow the user to continue later. At present, the submission interface is designed to keep such a local draft for up to seven days unless the user completes or discards it earlier.

The platform may also process technical and security information to validate submissions, enforce rate limits, detect automated abuse, verify security challenges, prevent malicious uploads, investigate suspicious activity, and protect the integrity of the service.

9. Recipients and Personal Information Processors

Personal data may be made available, where necessary and lawfully authorized, to:

• authorized SENZ or Masinloc Connect personnel;
• hosting, database, storage, security, communications, and infrastructure service providers;
• technology providers used to deliver a user-requested function;
• verified or authorized employers where a Data Subject has requested or authorized a recruitment-related service;
• professional advisers, auditors, insurers, or legal counsel where reasonably necessary;
• courts, regulators, law-enforcement bodies, or government authorities where disclosure is lawfully required.

Masinloc Connect shall seek to limit disclosures to information reasonably necessary for the applicable purpose.

10. Cloud and Cross-Border Processing

Some service providers may operate systems, infrastructure, or personnel outside the Philippines. Where personal data is transferred, stored, accessed, or otherwise processed outside the Philippines, SENZ shall seek to apply reasonable and appropriate contractual, organizational, and technical safeguards consistent with applicable Philippine data privacy requirements.

11. No Sale of Applicant Personal Data

Masinloc Connect does not sell applicant personal data as a commodity for unrelated third-party commercial exploitation. Fees that may be charged for subscriptions, recruitment functionality, software access, platform services, administrative services, or other legitimate commercial services do not give a customer unrestricted ownership of, or unrestricted rights to, personal data maintained by Masinloc Connect.

12. Security of Personal Data

SENZ shall implement reasonable and appropriate organizational, physical, and technical measures designed to protect personal data against accidental or unlawful destruction, alteration, loss, unauthorized disclosure, unauthorized access, misuse, fraudulent processing, or other unlawful processing.

Measures may include role-based access restrictions, authentication controls, private file access controls, validation and anti-abuse mechanisms, security logging, database access policies, secure communications, backup and recovery procedures, and incident-response processes.

No internet-connected system can guarantee absolute security. This Notice therefore does not represent that all risks can be eliminated.

13. Retention and Disposal

Personal data shall be retained only for as long as necessary for the purpose for which it was collected, an active service relationship, legitimate operational or business requirements, compliance with law, security or fraud investigation, audit requirements, or the establishment, exercise, or defense of legal claims.

When continued retention is no longer justified, personal data shall be securely deleted, destroyed, anonymized, or otherwise disposed of in a manner designed to prevent unauthorized further processing, subject to legitimate backup, archival, legal-hold, or technical requirements.

14. Rights of the Data Subject

Subject to the conditions and limitations provided by Philippine law, Data Subjects may exercise applicable rights under the Data Privacy Act, including:

1. Right to be informed about the collection and processing of personal data;
2. Right to access personal data being processed and relevant information concerning such processing;
3. Right to object to processing in circumstances recognized by law;
4. Right to rectification of inaccurate or erroneous personal data;
5. Right to erasure or blocking where the requirements of law are met;
6. Right to data portability where applicable;
7. Right to damages where provided by law; and
8. Right to file a complaint with the National Privacy Commission.

Requests to exercise privacy rights may be sent to hello@masinloc-zambales.com. Reasonable identity or authority verification may be required before access, correction, deletion, or another action involving personal data is carried out.

15. Consent and Withdrawal

Where processing depends on consent, consent shall be freely given, specific, informed, and evidenced by written, electronic, or recorded means. Consent for one purpose shall not automatically constitute consent for an unrelated purpose.

A Data Subject may withdraw consent where the relevant processing is based on consent. Withdrawal shall not affect processing lawfully performed before withdrawal. Where no other lawful basis permits continued processing after withdrawal, the relevant processing shall cease subject to applicable legal, security, retention, and operational requirements.

16. Minors

Employment and professional-profile functions are intended only for persons legally permitted to participate in the relevant activity. Where personal data concerning a minor is processed, appropriate safeguards and any consent, authority, or representation required by law shall be applied.

17. Personal Data Breaches and Legal Requests

SENZ shall maintain procedures for assessing, containing, investigating, documenting, and responding to actual or suspected personal data breaches. Where notification to the National Privacy Commission or affected Data Subjects is required, notification shall be made in accordance with applicable requirements.

Personal data may also be preserved or disclosed where reasonably necessary and legally authorized to comply with law, a lawful court order, warrant, subpoena, regulatory requirement, or valid request of a competent authority; to investigate fraud or security incidents; to protect lawful rights and interests; or to establish, exercise, or defend legal claims.

18. Changes to This Privacy Notice

This Privacy Notice may be revised when the services, processing activities, technologies, service providers, security practices, business operations, or applicable legal requirements change.

Material changes affecting the nature, purpose, scope, method, or extent of processing shall be communicated appropriately. Where a new processing activity requires consent, the required consent shall be obtained before undertaking that processing.

19. Privacy Contact

Questions, requests, objections, correction requests, deletion requests, or other privacy concerns relating to Masinloc Connect may be sent to:

Organization

SENZ Strategic Communications and Digital Solutions

Email

hello@masinloc-zambales.com

Website

www.masinloc-zambales.com

20. User Declaration

When a user submits information through Masinloc Connect, the user confirms that the information submitted belongs to the user or that the user is legally authorized to provide it, and that the information is accurate to the best of the user's knowledge.

Nothing in this Notice shall be construed as a waiver, limitation, or relinquishment of any right available to a Data Subject under Republic Act No. 10173 or other applicable law.