PRIVACY POLICY
1. Introduction and Dealership Scope
This Privacy Policy outlines how our authorized automotive dealership (“Dealership”, “we”, “us”, or “our”) collects, protects, uses, and processes personal information from customers, prospective car buyers, and website visitors across the Philippines. We operate in rigorous compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all relevant circulars issued by the National Privacy Commission (NPC).
This policy applies to all personal information gathered via showroom consultations, website inquiries, test drive bookings, vehicle reservation agreements, quotation requests, vehicle service maintenance visits, and customer care hotlines.
2. Categories of Information We Collect
In our regular course of automotive dealership operations, we collect the following personal and sensitive personal information:
• Customer Identification & Contact Data: Full legal name, date of birth, nationality, marital status, residential address, personal and business mobile numbers, email addresses, and valid government-issued photo IDs (such as Driver’s License, Passport, or UMID) required to verify identity and confirm test drive eligibility.
• Vehicle Purchase, Registration & Ownership Records: Conduction sticker numbers, Vehicle Identification Numbers (VIN), engine/chassis numbers, vehicle sales invoices, delivery receipts, Land Transportation Office (LTO) Certificate of Registration (CR) and Official Receipt (OR), and trade-in vehicle appraisal records.
• Financing, Credit & KYC Verification Data: Proof of billing, Certificate of Employment and Compensation (COEC), Income Tax Returns (BIR Form 2316/1701), business registration permits (DTI/SEC), bank statements, and credit history required by accredited automotive financing banks and lending institutions for Know-Your-Customer (KYC) evaluation and auto-loan processing.
• Aftersales, Warranty & Service Records: Periodic Maintenance Service (PMS) logs, warranty claims, odometer mileage readings, recall campaign rectifications, repair orders, parts replacement history, and emergency roadside assistance requests.
• Connected Vehicle & Telematics Data: Where vehicles are equipped with connected telematics or mobile application pairing, telemetry data including State of Charge (SoC), charging cycles, battery performance indicators, GPS location diagnostics, and drive error codes.
• Digital Platform Analytics: IP address, device specifications, browser cookies, and interaction records on our website to enhance digital customer experience.
3. Purpose and Legal Bases for Data Processing
We collect and process personal data in accordance with legitimate business purposes, explicit consent, contractual performance, and statutory compliance:
• Sales Consultation & Test Drives: Administering test drive waivers, ensuring driver license validity, and coordinating model consultations.
• Contract Execution & Delivery: Fulfilling Vehicle Sales Invoices, chattel mortgages, sales order forms, insurance coverages (Compulsory Third-Party Liability / Comprehensive Motor Insurance), and LTO new vehicle registrations.
• Service & Warranty Fulfillment: Tracking manufacturer factory warranties, battery system health checks, safety recall notices, and scheduling PMS appointments.
• Regulatory Compliance: Submitting required commercial reports to the Department of Trade and Industry (DTI), Land Transportation Office (LTO), Bureau of Internal Revenue (BIR), Anti-Money Laundering Council (AMLC), and National Privacy Commission (NPC).
• Customer Engagement: Providing opt-in service reminders, customer satisfaction index (CSI) surveys, and exclusive dealership event invitations.
4. Data Sharing and Third-Party Disclosures
Your personal information will never be sold or rented. Data is disclosed only on a need-to-know basis under strict Data Sharing Agreements and Non-Disclosure Agreements with:
• Vehicle Manufacturer & Principal Distributor: For warranty registration, technical service bulletins, and factory quality monitoring.
• Accredited Financing & Banking Partners: For bank auto-loan pre-qualification, credit appraisal, and chattel mortgage processing.
• Accredited Insurance Underwriters: For motor vehicle insurance issuance, policy renewal, and claims adjustment.
• Government Authorities & Law Enforcement: To the LTO for vehicle registration and number plate releases, the BIR for fiscal invoicing, and other agencies when required by lawful orders or subpoenas.
• Authorized IT & Cloud Service Providers: Providing secure database hosting, CRM infrastructure, and messaging gateways subject to international security standards (ISO/IEC 27001).
5. Data Protection, Security and Storage Retention
We enforce strict organizational, physical, and technical safeguards, including 256-bit SSL encryption for online data transmission, firewalled networks, restricted showroom document storage, and role-based access privileges. Personal information is retained only for the duration necessary to satisfy customer warranties (e.g., up to 8 years on EV traction batteries and vehicle powertrain warranties), fulfill BIR tax audit retention periods (10 years), or comply with applicable Philippine statutory statutes of limitations. When data is no longer necessary, it is permanently purged via cryptographic wiping or certified physical shredding.
6. Rights of the Data Subject under R.A. 10173
Under the Philippine Data Privacy Act, you are entitled to exercise the following statutory rights:
• Right to Be Informed: Clear disclosure on how your information is gathered, processed, and secured.
• Right to Access: Requesting copies of your personal data held in dealership files.
• Right to Object: Refusing processing for direct marketing or profiling purposes.
• Right to Rectification: Correcting any inaccurate, outdated, or incomplete information.
• Right to Erasure or Blocking: Requesting the deletion or blocking of personal data upon withdrawal of consent or if processed unlawfully.
• Right to Data Portability: Obtaining personal data in a structured, commonly used electronic format.
• Right to File a Complaint & Seek Damages: Lodging complaints before the National Privacy Commission and seeking indemnification for privacy breaches.
7. Contact Our Data Protection Officer (DPO)
For inquiries, requests for data rectification, or exercising your privacy rights, please contact:
Data Protection Office – Authorized Dealership Customer Care
Email: dpo@dealership.com.ph / privacy@dealership.com.ph
Showroom Address: Authorized Dealership Center, Metro Manila, Philippines
National Privacy Commission Official Portal: https://privacy.gov.ph