• accessing our Company website and portals, which includes browsing through any of our websites or mobile applications;
• visiting our physical offices;
• participating in gatherings and events organized or sponsored by our Company;
• any and all direct or indirect dealings with our Company, our officers and employees, as an investor, a shareholder, job applicant, an employee, a stakeholder, a customer, or in any other relevant capacity, including but not limited to invitations for polls and surveys circulated via electronic emails.

THE PERSONAL DATA WE COLLECT

We may collect and process Personal Data from you in the ordinary course of our business or to the extent necessary to respond to your requests, queries, and concerns which may include, basic information such as your name, residence, and contact details; sensitive personal information such as your age, financial information, biometric data, birthdate; educational background, ID with picture employment history, gender, government issued identifications, licenses, and certifications, health data (medical history, data on disability, medical diagnosis, opinions, fitness apps, Vascular scan), marital status, photograph, place of birth, proceeding for any offense committed or alleged to have been committed by an individual, signatures, social security number, tax identification number, tax returns, titles and other evidence of ownership, among others.

When you visit our websites or use any of our mobile applications, other such as browser type, operating system, IP address, domain name, number of times the website or the mobile application was accessed, including the frequency of such access, may be collected via cookies and other tracking technologies, such as transparent GIF files.

Aggregate Information, or non-personally identifiable and anonymous data, such as how many times you log onto our websites or mobile applications may also be collected. The transmission of such personal data is implicit in the use of web communication protocols or is useful for the improved management and optimization of the data and electronic mail sending system.

HOW WE USE COOKIES AND TRACKING TECHNOLOGIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Cookies allow websites to recognize your computer when you return, enabling it to display personalized settings and other user preferences. It also allows websites to respond to you as an individual. The websites and apps can tailor operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being visited. This helps us analyze data about webpage traffic and improve our website in order to tailor it to your needs. We only use this information for statistical analysis purposes after which, the data is removed from the system.

In general, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You will be given the opportunity to accept or reject the use of cookies on our websites in a pop-up box when you first access our website. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Most web browsers, however, automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You may choose not to accept cookies; however, this may restrict the services that you can access at our websites. Declining cookies may also prevent you from taking full advantage of our websites.

HOW WE USE THE PERSONAL DATA WE COLLECT  

When necessary, we request for your Personal Data for us to understand your needs and provide you with better service. We will process such Personal Data for specific purposes and only where there is a specific legal basis for doing so as laid down by the Privacy Laws. Specifically, we will process your Personal Data for the following purposes:

• As an investor or stockholder of record:
  • Establishing your identity as an investor or a stockholder of record in order to provide you services and accord you the benefits of an investor or a stockholder, which includes managing, administering, approving or facilitating any transaction or action in relation to your shares of stock, the payment of your dividends, and the registration of your shares in the stock and transfer books;
  • Collecting and analyzing collective investor or shareholder data or information, and conducting statistical analysis to improve the services to be provided to you including the expeditious response to your concerns and queries, and to ensure that the services to be provided to you as an investor or a stockholder of record are based on accurate and appropriate information
• As a job applicant:
  • Establishing your identity and qualification as a job applicant.
• As an employee:
  • Providing you with compensation and benefits that come with your employment in the company;
  • Offering you with opportunities for learning and career advancement;
  • Maintaining personnel and workplace health and safety standards;
  • Participating in our Company initiatives and events;
  • Maintaining company correspondence;
  • Promoting employee engagement and well-being;
  • Protecting employee vital interests;
  • Complying with law and regulation or legal obligation;
  • Marketing and promoting core human resources services;
  • Processing people analytics to improve organizational capability, enhance employee experience or solve business problems for and on behalf of the Company
• As a customer:
  • Answering queries and addressing concerns;
  • Fulfilling contractual agreements and obligations;
  • Improving the quality of our services;
  • Developing new offerings to meet your needs;
  • Promoting customer attraction or retention programs, value added services, data analytics and other statistical and analytical studies and for such other legitimate commercial and marketing purposes;
  • Assessing your continued qualification for availment of our services;
  • Maintaining or updating the Company’s customer records;
  • Updating you on the Company’s activities or other services which may interest you;
  • Building our statistical and analytical studies and database for internal reporting.
• As a stakeholder in any relevant capacity:
  • Complying with the due diligence requirements in fund-raising activities and transactions with lenders, creditors or financial institutions;
  • Complying with the reportorial obligations of the Philippine Stock Exchange (PSE) and the Philippine Dealing and Exchange Corporation (PDEx), and other self-regulating organizations that oversee the company;
  • Complying with the requirements of regulatory agencies and instrumentalities of the government including, but not limited, to the Securities and Exchange Commission (SEC) and the Bureau of Internal Revenue (BIR);
  • Complying with and responding to legal processes or lawful orders of any judicial or quasi-judicial bodies;
  • Maintaining business correspondence

HOW WE PROCESS YOUR PERSONAL DATA

We collect and process the Personal Data you provide via electronic mail or as provided in physical documents disclosed and transmitted. Personal data collected may be recorded and stored in both digital or electronic format, and in physical copies. Access to information is limited to authorized officers and personnel for the purpose of your engagement and through your transactions with us.

We may organize or consolidate the above-enumerated Personal Data to allow us to use the same for the foregoing purposes. We may also retrieve any of your stored data for the same purposes, as well as to update, modify or correct your data upon your request.

In all instances, the Company ensures that collection and processing are not undertaken through use of deceptive design patterns.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to ensuring that your Personal Data is kept secure. We have implemented suitable and adequate organizational, physical and technical security measures, policies and procedures intended to reduce the risks of accidental destruction or loss, the unauthorized disclosure or access to such information which are appropriate and adequate to the nature of the Personal Data we collect, and such other personal breaches and security incidents as defined under the Privacy Laws.

We implement the appropriate disposal (physical or electronic) of policies for documents, records, and assets to ensure that Personal Data are disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice the interests of the data subjects.

We may retain your Personal Data only for as long as necessary for legitimate business purposes in line with the principle of proportionality, to comply with laws, regulations, or lawful court order, or to establish or defend a legal action.

DISCLOSURE OF PERSONAL DATA

We may disclose your Personal Data with any of our Company affiliates or subsidiaries for the purposes of processing and documenting, profiling, statistical analysis, customer insights, credit scoring, marketing, and other analogous processes necessary to enable data sharing including cross selling of data across the affiliates and subsidiaries of the Company to the extent allowed by the Data Privacy Laws, as specified under the relevant Data Sharing Agreements.

The Company may also disclose or share your Personal Data to the following third parties as may be necessary to achieve the foregoing purposes, pursuant to data sharing agreements to be entered or similar documents to be executed embodying the data sharing arrangement:

• any agent, contractor, or sub-contractor performing services related to stockholders services;
• any consultant, adviser, auditor, or service provider we engaged to carry out functions or activities related to our legitimate business activities;
• any person to whom we propose to assign or transfer any of our rights and/or duties;
• any of our affiliates and subsidiaries, partner companies, and service providers with whom we have contracted through data sharing agreements for promotion of customer attraction or retention programs, value added services, data analytics and other statistical and analytical studies and for such other legitimate commercial and marketing purposes;
• any court of law or administrative agency of the government pursuant to a lawful order issued in relation to a pending case or proceeding before such court or agency;
• our lenders or creditors, underwriters, as well as the consultant, adviser or, auditor of the foregoing;
• your lawyer, attorney-in-fact, or duly authorized agent or representative, upon presentation of a duly executed special power of attorney; and
• any regulatory, quasi-judicial or judicial authority, or as otherwise considered necessary or appropriate for our legitimate business purposes.

Any access to Personal Data will be limited to the person who requires your Personal Data to perform the functions for collection has been undertaken, and as required or allowed by law. We do not sell, trade, or otherwise transfer your Personal Data to third parties without a data sharing agreement compliant with the Privacy Laws. We will comply with the data sharing provisions of the Privacy Laws or obtain your prior consent, as may be necessary, should we share your Personal Data to third parties. Any data sharing for commercial purposes will be covered by a data sharing agreement.

For the comprehensive list of the Company's subsidiaries and affiliates, please see our Conglomerate Map.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to ensuring that your Personal Data is kept secure. We have implemented suitable and adequate organizational, physical and technical security measures, policies and procedures intended to reduce the risks of accidental destruction or loss, the unauthorized disclosure or access to such information which are appropriate and adequate to the nature of the Personal Data we collect, and such other data breaches and security incidents as defined under the Privacy Laws.

NOTIFICATION OF CHANGES

We reserve the right to amend or update this privacy statement as necessary. Any substantial changes regarding the scope, purpose, nature, or extent of data processing will be made in adherence to the universally accepted Privacy Laws. We recommend that you check this privacy notice periodically to stay informed of any updates to our policies.

YOUR RIGHTS AS DATA SUBJECT

Based on the provisions provided under the Privacy Laws, we uphold the following rights data subjects, namely:

• Right to be informed. As a data subject, you have the right to be informed that your Personal Data will be, are being, or were, collected and processed.
• Right to access. In relation to your right to be informed, you also have the right to gain reasonable access to your Personal Data, such as: (a) contents of your Personal Data that were processed; (b) manner by which such Personal Data were processed; (c) date when your Personal Data was last processed and modified, among others.
• Right to object. You have a right to object to the processing of your Personal Data, including automated processing or profiling. Likewise, you have the right to be notified and given an opportunity to withhold consent to the processing in case of changes to the information given to you regarding the processing of your information. In connection thereto, the Company shall adequately explain to you the extent of the withdrawal requested including consequences thereof, which may include disclosure whether or not the Personal Data will be subject to further processing.
• Right to erasure or blocking. You have the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data.
• Right to damages. ou may claim compensation if you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Data.
• Right to file a complaint. You may file a complaint if you are the subject of a privacy violation or personal data breach, or if you are personally affected by a violation of the Privacy Laws.
• Right to rectification. You have the right to dispute any inaccuracy or error in your personal data and request to correct it, unless such request is unreasonable.
• Right to data portability. This means that you have a right to obtain a copy of your Personal Data either in an electronic or structured format to give you more control and manage your Personal Data.

REQUESTS, ACCESS, RECOURSE AND QUESTIONS REGARDING THIS PRIVACY STATEMENT

You are entitled to request that we:

• Provide you with a copy of your Personal Data and inform you of: (a) the source of your Personal Data; (b) the purposes and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entity with whom your Personal Data may be shared;
• Cease processing your Personal Data, in whole or in part, as may be personally requested, save to the extent it is lawful to do so without consent under the Privacy Laws;
• Refrain from transferring your Personal Data to third parties for the purposes of direct marketing or any other purposes not allowed;
• Correct any errors in your Personal Data; and Update your Personal Data as required.

If you have questions, concerns, complaints, or suggestions regarding our compliance with the Privacy Laws or if you wish to exercise your rights to access, rectification, object, portability, or deletion in instances allowed under the law, you may contact us through our Data Protection Officer as follows:

Data Protection Officer l Aboitiz Power Corporation
NAC Tower 32nd St., Bonifacio Global City 1635, Taguig City, NCR Fourth District, Philippines
Email : apdpo@aboitiz.com
Please use the following subject format:
Inquiry on Data Privacy

We will make every reasonable effort to correct, update and respond to your request promptly, unless we require further information from you in order to fulfill your request, and in each case, subject to legal and other permissible considerations. We will also investigate and endeavor to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Laws and other data privacy and protection policies we have put in place. You have the option of referring to the NPC any complaint that cannot be resolved with us directly.