PRIVACY POLICY

TRAZE Contact Tracing aims for full transparency about the personal data that it processes when you use this application. TRAZE Contact Tracing is Data Privacy Act (DPA) RA 10173 compliant and does not use Bluetooth/ GPS. In this Privacy Statement, we explain, among other things, what information we collect, why we collect it, and how we use the information.

The Privacy Statement applies to all end users of TRAZE Contact Tracing App: Individuals, government agencies, barangay, delivery crew, public transportation, ports and other establishments.

1. WHAT DATA WE COLLECT

DATA RELATING TO END USERS

Some of the information we process may be considered personal data under applicable privacy legislation. This personal information includes:

PARTNERS, ESTABLISHMENTS, GOVERNMENT AGENCIES, DELIVERY CREW AND BARANGAY

LAND TRANSPORTATION, AIRPLANES, TRAINS AND SHIP/VESSEL

AIRPORTS AND SEAPORTS

2. WHY WE PROCESS PERSONAL DATA AND THE LEGAL BASIS FOR OUR PROCESSING

We only process your data for purposes that are objectively justified by TRAZE Contact Tracing application and only as stated in this Privacy Statement. We process this data with respect to your right to privacy, including the need to protect personal integrity and private life and to ensure that your personal data is adequately protected against the risk of loss, misuse and unintended alteration.

Unless you are offered the option to provide prior consent to our use of your data, we process your data with legal basis in the Data Privacy Act (DPA) RA 10173 - Section 12. Criteria for Lawful Processing of Personal Information. We collect data primarily for the contact tracing of individuals and all the persons whom he got in contact.

END USERS (INDIVIDUALS)

For end users, we collect data to :

PARTNERS, ESTABLISHMENTS, GOVERNMENT AGENCIES, DELIVERY CREW, BARANGAY AND TRANSPORTATION

For our partners, we collect data to:

3. HOW WE COLLECT DATA

Generally, we collect data:

When we collect your data at end user level, we saved your critical information locally such as the your QR Code, your picture, history of scanned individuals, establishments, transportation, delivery crew, barangays, etc. We save the collected data in TRAZE Contact Tracing server which are then used for Contact Tracing process. This string equivalent of your collected data are encrypted when transferred to our TRAZE Contact Tracing server.


4. INFORMATION SECURITY – HOW WE PROTECT YOUR DATA from unauthorized access

In order to prevent unauthorized access or disclosure, we have put in place suitable technical handling to safeguard and secure the information we collect online. We have implemented organizational and technical procedures and measures that will ensure that your personal data is not compromised, not unintentionally changed, and available when required. Such measures include data encryption when we save your information, one time password (OTP) during your registration, user password during system log in, access restrictions and controls, back up routines, and disaster recovery routines.

We review and update our working procedures regularly to improve your privacy and ensure that our internal policies are followed. We strive to promptly correct any non-conformance with these policies.

5. HOW WE SHARE YOUR DATA

We may share your data:

6. RETENTION AND DELETION

We retain personal data only as long as necessary for processing it in accordance with the purposes described in this statement, or as otherwise necessary to comply with applicable laws. We retain the history of your scanning transactions for only (30) thirty days. When your data is no longer necessary or relevant for our purposes, or required by applicable laws, we take steps to have it deleted.

7. ACCESS, CORRECTION AND DELETION OF PERSONAL DATA

You have the right to access the personal data you have registered about you. For profile information, if any of the information you have registered is incorrect, we encourage you to make changes to your profile (Last Name, First Name, Email, Location/ City/ County, Cellphone number, alias). You may also withdraw any consents you have given at any time. Feel free to contact us for assistance at telephone number (02) 8403-98-11 or email us at TRAZE@cosmotech.com.ph.

8. YOUR RIGHT TO FILE A COMPLAINT

If you believe that we process your data in violation of your rights, you have the right to complain. You may always contact us directly at telephone number (02) 8403-98-11 before sending a complaint to the National Privacy Commission (NPC) office, so that we can try to solve or clarify the issue.

9. CONTROLLER AND CONTACT INFORMATION

TRAZE Contact Tracing is owned, developed and managed by Cosmotech Philippines, Incorporated located at 7761 Saint Paul Street, San Antonio Village, Makati City as the controller of personal information processed under this Privacy Statement.

If you have any questions about the Privacy Statement or any other questions regarding our privacy practices, please contact us at: TRAZE@cosmotech.com.ph