## Privacy Policy
Below is the privacy policy (the “Policy”) for KVARTA Corporation (the “Company”) website, [https://kvarta.ph](https://kvarta.ph) (the “Website”).

### User Consent

By communicating or providing your Personal Information to any phone call/s, e-mail correspondence/s, text message/s, snail mail/s, or signing up for, accessing, or using the Website, or any of its features, processes, functions and its related services (collectively the "Services"), you are hereby accepting and consenting to the practices described in this Policy.

In the event that you opt not to share your personal information (“Personal Information”, as defined below) with the Company or have the same transferred to any third-party, we will be unable to support your instructions or provide you with our services. Should you not to share certain Personal Information, we reserve the right to refuse your request for, or the continuation of, any of our services.

Should you submit Personal Information on behalf of another, you represent that you possess the proper authority to provide such information, including informing such person/s of this Policy, and allow us to use the same.

Unless otherwise defined in the Policy, terms used in the same have the same meanings as in the Company’s Terms and Conditions, accessible at [https://kvarta.ph/terms-and-conditions](https://kvarta.ph/terms-and-conditions)

### Scope of Use

The Policy informs you of the Company’s rules or guidelines in the collection, use, storage, processing, disclosure and security of your Personal Information when you use the Website.

The Policy applies to all information the Company processes in connection with your relationship with us as a customer or potential customer.

### Personal Information

In communicating with the authorized representatives of the Company, while using the Website or in any form of media, the Company and/or any of its authorized representatives may ask you to provide certain personally identifiable information that can be associated with you or the person you represent (collectively referred to as the “Data Subject”) that can be used to contact or identify the Data Subject.

The Personal Information collected and processed includes but is not limited to the Data Subject’s:

- Name, gender, civil status, date of birth, address, telephone or mobile numbers, email address, mailing address, proof of identification, and any other information voluntarily provided;
- Employment history, educational background, affiliation/s, and income information when applying a job with the Company;
- Information about his/her visit and/or use of the Company’s digital platform/s, website, mobile application, and those of similar character, including but not limited to traffic data, web logs or other communication data and the resources you access;
- Social media behavior when s/he tags, mentions, or posts of any development of the Company and its subsidiaries publicly on any social media platform;
- Work-related information, i.e. his/her employment, business, ownership, and participation, if s/he applies for vendor accreditation;
- Government issued IDs;
- (Subject) real property, which may include photographs or videos, as may be applicable;
- Any and all documents in relation to the subject real property, for verification purposes.

### Manner of Collecting Personal Information

The Company and/or any of its authorized representatives will be collecting and processing Personal Information relevant to its services when:

- The Data Subject communicates or provides his/her Personal Information through phone call/s, e-mail correspondence/s, text messaging, snail mailing, or filling out forms through the Company’s Website or social media platforms, and any and all forms of communication after the initial contact made;
- The Data Subject is registering interest, transacting with any of the Company’s authorized representatives, subscribing to any documentation of the Company’s products or services, participating in any of the Company’s meetings, gatherings, promotions, activities or events, or requesting information in any form;
- The Data Subject allows any third party to share his/her Personal Information with the Company;
- The Data Subject visits any of the Company’s premises with CCTV surveillance camera/s which are used for safety and security of persons;
- The Company or any of its representatives were referred to by any third party or business associate.
We may also collect your Personal Information from other sources, such as any information you provide us directly or indirectly, including information collected which you may have provided us through other related services, including our customer support team subject to applicable laws and regulations.

### Reasons for Collection of Personal Information

The Personal Information we collect from the Data Subject will be used to allow us to perform the services requested from us. We may use your Personal Information to:

- Assist the Data Subject in the use of the Website or other media of communication, and/or access to to the same;
- Verify the Data Subject’s identity and contact details;
- Verify the property, its ownership, location, condition, and other details as submitted or declared;
- Provide our services;
- Process communications, requests, correspondences, negotiations, send notice/s and/or about the Data Subject’s transactions with the Company;
- Contact the Data Subject and update him/her on the performance of our services;
- Conduct verification of the Data Subject’s application;
- Offer surveys, promotions, and marketing communications;
- Improve our Website, social media platform/s, and other marketing material content and layout;
- Improve our services;
- Respond to any inquiries, comments, or concerns regarding our services;
- Provide customer support;
- Exercise the Company’s legal rights for the protection of its interests;
- Other specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after collection of the Personal Information.
We do not share your Personal Information with any third parties for their business purposes, such as, including without limitation, marketing and advertising without your express consent and authorization.

### Sharing of Personal Information to Third Parties

We may employ or share the Data Subject’s Personal Information with external providers and/or third-party companies and/or individuals to facilitate our services, to provide the services on our behalf, to perform services-related actions, or to assist us in analyzing how our services are used. These external providers and/or third-party companies and/or individuals includes, but is not limited to the following entities:

1. Affiliates and/or members of the Company’s corporate family, including PIK-Broker LLC‚ as direct and indirect subsidiaries, to assist in providing the Company’s services, to help detect and prevent potentially illegal acts and violations of our policies, and to provide proper data analytics on the use of the Website and the Company’s media of communication including marketing materials;
2. Courts of Law, government officials, law enforcement, or other regulators in relation to a subpoena, court order, or other legal process or requirement under Philippine law or regulation, when we need to do so to comply with such law or regulation, or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, or to report suspected illegal activity or investigate violations of our Terms and Conditions;
3. Customer support for customer service purposes;
4. Banking or financial partners, as permitted by law or as required by the contractual business relationship;
5. Legal department, to ensure compliance with government rules and regulations and to protect us against harm to the rights, property, or safety, the other users of the Website or the public, as required or permitted by law;
6. Service Providers, to enable service providers under contract with us to support our business operations, such as but not limited to fraud prevention, marketing, customer service and technology services.
Some of these external providers and/or third parties may be located in other countries with different rules and regulations on processing personal information. By agreeing to this Policy, you acknowledge that Personal Information can be transferred cross-border to other countries and you are consenting to such transfer.

Please note that these third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose, use, or store your Personal Information for any other purpose.

### Special Notice – Minors

Use of the Website and the Company’s other media of communication is not aimed at persons under 18 years old and we will not collect, use, provide or process in any other form any personal information of persons under the age of 18 deliberately.

If you should be under 18 years old, please do not send us your personal information (for example, your name, address and email address). Nevertheless, if you wish to ask a question or use this Website in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.

### Changes in the Data Subject’s Personal Information

If you would like to review, change or delete any Personal Information you have supplied us with, please contact us immediately using our contact information listed below.

### Retaining Personal Information

We retain your Personal Information no longer than it is necessary and relevant for our services. For completing the process of transferring ownership of the property and retaining records of such for legal and taxation purposes, the Company shall generally retain Personal Information applicable perpetually. For maintaining employment records, the Company shall generally retain Personal Information applicable for five (5) years.

We may also retain Personal Information to comply with the requirements of any laws and regulations, to prevent fraud, to resolve disputes and various troubleshoot problems, and to take other actions permitted or required by applicable laws and regulations.

We will dispose Personal Information in a secured manner and in accordance with applicable laws and regulations, after such Personal Information is no longer necessary and ceases to be relevant for our Services, unless applicable laws and regulations require otherwise, or unless the requested by the Data Subject in writing.

### Security

Security of your Personal Information is our priority. Except as indicated in this Policy, we will not disclose your Personal Information to third parties without your express consent. Further, we take all reasonable procedures and exert our best efforts to ensure all Personal Information received shall be kept confidential and secure, whether online or offline. We protect your Personal Information using a variety of technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We may use and amend from time-to-time various security measures, as new technology becomes available, as appropriate, such as firewalls and data encryption, access controls to data centers.

### User Confidentiality

To further secure the privacy of your Personal Information, we advise to keep your any account details confidential at all times.

### Use of Cookies

Depending on your when you access our Website, we may use Cookies or similar technologies on your computer or other device to record information. Cookies are files with a piece of data, which may include an anonymous unique identifier and can be stored on your hard drive to help us improve your access to the Website and identify repeat visitors to the same. You are free to decline our Cookies on your computer or other device, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, use of the Website may be limited if you do not accept our Cookies.

### External Links

The Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be redirected to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

### Privacy Policy Updates

You are advised to review this Policy periodically for the latest information. The Company reserves the right to modify this Policy at any time, without any notice, by posting a modified version of the same on the Website or in any of the Company’s marketing materials. Nonetheless, we will do our best to notify you of any significant changes in the same. The Company will never materially change the Policy to make it less protective of the Personal Information collected in the past.

Any change will be effective immediately upon posting the same on the Website.

### Inquiries and Complaints

If you believe your Personal Information or that of the person you represent may have been misused or abused, or if you believe that the security and protection of your respective personal data may have been compromised, you may lodge your inquiries and complaints to the Contact Information below and briefly discuss such matter, together with your contact details for reference.

### Contact Information

Accordingly, if you have questions or concerns regarding this Policy, or if you want to withdraw any consent given or made herein, inquire or request for information regarding any matter relating to the processing of your respective personal data, you can contact us through the following information:

Email Address: <a href="mailto:dpo@kvarta.ph">dpo@kvarta.ph</a>

Contact Number: <a href="tel:(02)8540-2202">(02)8540-2202</a>

Attn: Data Protection Officer

KVARTA Corp.

30th Floor Yuchengco Tower, RCBC Plaza, 6819 Ayala Ave, Makati City, Metro Manila

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