I. Introduction
Betita Cabilao Casuela Sarmiento is a full service firm providing legal services to international and Philippine clients. We own and operate the website www.bccslaw.com and the Intellectual Property docketing system, GRAVITAS®. Our principal place of business is situated in the Philippines.
We respect the data privacy rights of all persons and entities we transact with and strive to comply with the Philippine Data Privacy Act of 2012 that all personal information we collect are processed in accordance with the general principles of transparency, legitimate purpose and proportionality, and the requirements of lawful processing.
Our Policy aims to describe the scope of our collection, use, access, transfer, storage, or otherwise processing of personal data, our data protection principles to safeguard personal data in our custody, and the rights of persons and entities whose personal data were, are, or will be, processed by us.
II. Definitions
For purposes of this Policy, the following shall have the respective meanings hereafter set forth:
“BCCS” (“us”, “we”, “our”, “the firm”) refer to Betita Cabilao Casuela Sarmiento;
“Web services” refers to bccslaw.com and GRAVITAS®;
“Data Subject” (“you”, “your”) refers to an individual whose personal, sensitive personal, or privileged information is subject to processing. Included in the term are our web visitors and users, as well as existing and potential clients, employees and vendors;
“Consent” refers to any freely given, specific, informed indication of will, where the Data Subject agree to the collection and processing of the personal, sensitive, or privileged information;
“Personal information” refers to any information where the identity of the Data Subject is apparent or can be reasonably and directly ascertained or when put together with other information would directly and certainly identify of a Data Subject;
“Personal data” refers to all types of personal information;
“Data sharing” is the disclosure or transfer to a third party of personal data under our custody;
“Processing” refers to any operation or any set of operations performed upon personal data including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data;
“Privileged information” refers to any and all forms of data, which, under the Rules of Court and other pertinent laws constitute privileged communication;
“Sensitive personal information” refers to personal information:
“Public authority” refers to any government entity created by the Constitution or law, and vested with law enforcement or regulatory authority and functions
III. Collection
A. Sources
BCCS may collect, directly or indirectly, personal data, from the following sources:
B. Types of Personal Information
C. Uses
Generally, we may process personal information in the following circumstances:
Some specific ways we use categories of personal data are explained below.
We use Contact data to communicate and respond to inquiries, identIfy a conflict of interest, and develop our business relationships through communications.
We use Billing data in the preparation of invoices, verify financial transactions and more importantly, ensure that we process payments only through official channels and/or release funds only to authorized personnel.
We use Web data to monitor the security as well as improve the functionality of our web services for users and visitors. Web analytics and interactions with our social media profiles make it possible for us to gain useful insight on what matters to our visitors and clients allowing us to improve our online presence and share only the most up-to-date and relevant information.
We use Verification data to conduct necessary background verification in order to comply with client due diligence such as those under anti-money laundering laws, KYC (“know-your-client”) and other compliance procedures and regulatory checks to prevent fraud or crime. We may not be able act on instructions unless we are provided with the necessary information to complete these mandatory checks.
We use Client data to provide legal services to our clients and render specific services, such as the trademark, copyright and patent registration and business registration, among others.
We use Recruitment data to evaluate applicants for employment, conduct appropriate background checks, communicate with the status of an application, and any other purpose relating to employment to BCCS.
We use Events data to run our events in order to improve our succeeding events and meetings.
We use Vendor data to deal with our suppliers who provide goods and services to us, as well as consider potential suppliers for our future requirements;
We use Preference data to meet specific needs.
We use Investigation data when we have been engaged to perform specific services to our clients involving the protection and enforcement of their rights against third parties who are usually the subject of the investigation.
We may, in limited circumstances, process Sensitive personal information when:
We will ask for consent before using personal information for a purpose that is not covered in our Privacy Policy.
D. Storage
Personal data are processed and held at our principal place of business in the Philippines where we take reasonable measures to comply with locally applicable data privacy standards. However, whenever necessary for the purposes stated in this Privacy Policy, information may be transferred outside of the Philippines where data privacy laws vary by country. With respect to data transferred to a third party, whether domestically or internationally, we use reasonable means to provide a comparable level of protection to the personal data, to the extent applicable to us.
The period of storage shall be for as long as necessary to fulfill the purpose for which the personal data was collected.
IV. Data Sharing
To the extent that we are required to do so by applicable laws and/or rules and regulations, we may share personal information with others, as follows:
BCCS will not share personal information with any other third parties without the consent of the data subject, unless the data sharing is for any of the following reasons:
V. Security
We take reasonable organizational, physical and technical security measures for the protection of personal data .
We take steps to ensure that any person acting under our authority and who has access to personal data, does not process them except upon our instructions, or as required by law.
Our security measures aim to maintain the availability, integrity, and confidentiality of personal data and are intended for the protection of personal data against any accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.
We take reasonable and necessary measures to protect personal data against natural dangers such as accidental loss or destruction, and human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination.
VI. Risks
While we are committed to protecting personal information that we collect, information transmitted over the Internet is not completely secure. As such, we cannot make a guarantee on the absolute security of information transmitted.
VII. Your rights
For any concern regarding your personal information and the exercise of any of your rights, you may contact the relevant Data Privacy contact as listed in this Policy.
Under certain circumstances and in accordance with applicable data protection laws in the Philippines, you are entitled to the following rights.
If you feel that your personal information has been misused, maliciously disclosed, or improperly disposed, or that any of your data privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC).
VIII. Data Privacy Contact
If you have any questions about this Policy, please contact us by sending an email to dataprotection@bccslaw.com or sending a letter to the address below:
Betita Cabilao Casuela Sarmiento
Suite 1104, Page One Building
1215 Acacia Avenue, Madrigal Business Park
Ayala Alabang, Muntinlupa City 1780
Metro Manila, Philippines
This Privacy Policy was last updated on 9 September 2019.