Zip Privacy Policy

Welcome to Zip!

zip.ph Inc. (“Zip”, “we”, “our” or “us”) expects its employees, including those of its subsidiaries worldwide, as well as any third parties with whom Zip does business, to maintain the highest standards of ethics and compliance with applicable laws and rules.

Zip is committed to the highest standards of privacy and data protection compliance and expects all its employees and management to adhere to these standards.

Zip is bound by the Data Privacy of 2012 Act 2012 (“DPA”) of the Republic of the Philippines and the regulations promulgated thereunder (as may be amended from time to time). Zip adheres to the DPA and acts in accordance with this Privacy Policy where the information collected in the circumstances as set out in this Privacy Policy amounts to “Personal Data” under the DPA.

Zip operates an online payments platform that allows us to act as a technology service provider to facilitate merchants and vendors to accept and process credit card, debit card and other types of card payments in exchange for goods and services (“Merchants”). Our services comprise all software and services that we offer, including the Zip Checkout form that may be made available on a Merchant’s website, and other services that we offer through our website when you register for a Zip account (collectively referred to as the “Services”).

We understand that privacy is important to our online visitors and users. We respect your privacy and will take all reasonable steps to safeguard and protect your information as if it were our own.

This Privacy Policy will help you understand what Personal Data Zip collects; how it collects, holds, uses, processes, transfers and discloses that information; and the purposes of collection, use and disclosure.

Personal Data

The term “Personal Data”, refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

This Privacy Policy will help you understand the following:

• What does this Privacy Policy apply to?

• Collection and Use of your Personal Data

• Cookies and Web Server Logs

• Sharing and Disclosure of your Personal Data

• Retention of your Personal Data

• Protection of Personal Data

• Changes to this Policy

• Access, Correction and Complaints

Please also review, if applicable, your agreement with Zip, including our Terms of Service that shall govern in the event of any inconsistency with this Privacy Policy.

Zip Privacy Policy

1. What does this Privacy Policy apply to?

This Policy applies to Personal Data collected through the zip.ph website, including all subpages and successor pages (collectively referred to as the “Website”), and also applies to all Personal Data collected in the course of the Services that we offer.

This Policy does not apply in respect of Personal Data provided to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party website or company before deciding whether to provide any information.

By using our Website or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, please delete all cookies from your browser cache after visiting our Website and do not visit or use our Website or Services. Your continued use of our Website or Services will signify your acceptance of this Policy.

2. Collection and Use of Your Personal Data

We collect Personal Data from our Merchants and our Merchant’s customers (“Checkout Users”) in order to enable us to provide our Services.

Broadly speaking, we collect information in three ways: (1) when you provide it directly to us,

(2) when we obtain verification information about you or your company through trusted third parties (e.g. banks, credit bureaus), and (3) passively through technology such as

“cookies” (cookie collection is described below in the Section titled “Cookies and Web Server Logs”.

The types of Personal Data that we collect and our use of that Personal Data will depend on whether you are a Checkout User or Merchant.

Checkout Users

Checkout enables Merchants to collect payment information from Checkout Users for a number of payment methods. When you use a Merchant’s website to make a purchase, the Merchant will collect your Personal Data and provide it to us. This Personal Data includes your payment card information, your email address, your mobile phone number, and billing and shipping address. We will use this Personal Data as part of the payment processing process. When you use Zip Checkout on a Merchant’s website to store your payment credentials, we will use the Personal Data disclosed to us by the Merchant to complete purchases that you choose to make on other websites or applications that also use Zip Checkout, but only with your permission. Checkout Users can view our Privacy Policy via a hyperlink and are asked to confirm that their Personal Data be remembered.

This Personal Data described above will be shared and disclosed only as described below in the Section titled“Sharing and Disclosure of Personal Data”.

Merchants

When you visit our Website, you have the ability to conduct a limited number of live “test” transactions and experience our Services working without registering for a Zip live account. To monitor these test transactions, we collect your IP address, information about your computer, and other standard web log information. We also collect any Personal Data and credit card information that you provide to conduct the test transactions. We will not use this information to target any advertisements to you.

To gain full access to our Website and Services, you must register for a Zip live account. When you register for an account, we collect the Personal Data you provide, such as the following:

• Your name, company name, location, email address, phone number, and account password, to set up your account

• Your business and personal tax, or other government-issued identification numbers, as well as your date of birth, to verify your identity for underwriting purposes

• Your bank account information, to settle funds for your transactions

• Your IP addresses, devices, and locations used to access Zip, which will be linked to your account for fraud detection/prevention purposes

If you elect to not provide Personal Data in optional fields it may limit your ability to use our Services. We may retrieve additional Personal Data about you from third parties and other identification/verification services such as credit bureaus. In addition, we may collect Personal Data from you in other ways including emails, surveys, and other forms of communication.

Once you begin using our Services through your Zip account, we will keep records of your transactions and collect information of your other activities related to our Services.

This Personal Data described above will be shared and disclosed only as described below in the Section titled “Sharing and Disclosure of Personal Data”.

Website Visitors

To simply browse our Website, you are not required to provide any Personal Data. However, we may gather non-personally-identifiable information, as described directly above, solely for the purposes of monitoring and improving our Website and Services. We will not share this information with third parties or use it to target any advertisements to you.

Our Website and Services are directed to the general public. We do not knowingly collect information from children under 15 years of age or have any reasonable grounds for believing

that children under the age of 15 are accessing our Website or using our Services. If we learn that we have inadvertently collected Personal Data from a child under age 15, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 15, please contact us at [email protected].

3. Cookies and Web Server Logs

“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. Cookies can remember what information a computer accessed on one web page to streamline activities on related web pages and to make the online experience easier and more personalized. Log files are used to monitor, measure, analyze, improve, and troubleshoot our Services.

We use “cookies” and other technologies to collect non-personally-identifiable information from our Website and from other websites that use our Services. Where you request that your payment credentials be remembered by our checkout system, the cookies will also collect Personal Data about you. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent at our site.

We use cookie data to measure web traffic and usage activity on our Website for purposes of monitoring, troubleshooting and improving our Website and Services, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Website and the websites of Merchants that use our Services. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages on our Website and also across other websites or applications that use our Services. You can choose to disable cookies for our Website but this may limit your ability to use our Website and Services.

Marketing and Cookies Opt-Out

Where your consent has been obtained, we may occasionally email you with information about offers or new services. If you do not wish to receive this marketing material then please email [email protected]. You can also opt out of these email communications by replying with unsubscribe in the subject line, or via an unsubscribe link included in such communications. However, you will continue to receive certain email communications related to your account and your relationship with Zip.

If you wish to opt out of having cookies set on your browser, the only way to ensure that this happens is to manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. Note that disabling cookies on your browser prevents Zip from tracking your activities in relation to our Website and Services. However, it may also disable many of the features available through our Websites and Services and some aspects of our Services may not work properly if you do so. For more information, refer to your browser’s technical information. You may also consider visiting aboutcookies.org, which provides helpful information about cookies.

In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technology to identify the fact that you have visited our Website or seen one of our advertisements, and we may provide that information to one or more third-party advertising networks. The information we provide may include the time and date of your visit to our Website, pages viewed, links clicked and other non-personally identifying information. Those advertising networks may recognize the web beacon or cookie associated with your visit to our Website when you visit other websites on which they serve advertising, and they may make decisions about the advertisements you see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage you to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies.

4. Sharing and Disclosure of your Personal Data

Zip does not sell or rent your Personal Data to marketers or third parties. Zip may disclose Personal Data it collects about you to trusted third parties who are integral to the operation of our Website and Services for a variety of purposes in connection with providing our Services, operating our Website and, where you have consented, special offers to you. These third parties may include our agents, related bodies corporate, contractors, financial institutions, payment processors, verification services and credit bureaus, as well as any third parties that you have directly authorized to receive your Personal Data.

We may share Checkout User’s contact information, but not their card information, with Merchants as part of the Checkout User’s purchases.

We may store your Personal Data in locations outside the direct control of Zip, for instance, on servers or databases co-located with hosting providers. Some of our the related bodies corporate or third parties to whom we disclose your Personal Data are located outside of the Philippines. These countries may include the United States of America and Singapore. DPA also requires that the period of storage be disclosed.

We may also disclose your Personal Data to law enforcement, government officials, or other third parties if required by law or we believe in good faith that the disclosure is necessary to prevent physical harm and you are not legally or physically able to consent, to report suspected illegal activity, for the protection of rights of natural or juridical persons in court proceedings, or to investigate violations of our Terms of Service.

In addition, in the event of a potential or actual merger, acquisition, reorganisation, bankruptcy, or other similar events, certain information including Personal Data in our possession may be disclosed or transferred to and used by our successor or assign for the same purposes for which you have provided your consent to us for.

Any sharing or disclosure of your Personal Data will be in compliance with applicable data protection laws and regulations, including the DPA, including the right to access or to correct or file a complaint before the Privacy Commission created under the DPA.

5. Retention of your Personal Data

Personal Data that we collect and use for any purpose or purposes shall not be retained for longer than is necessary for that purpose or those purposes. This includes the Personal Data of Checkout Users.

Zip has a variety of obligations to retain the data that you provide us, both to ensure that transactions can be appropriately processed, settled, refunded or charged back, to identify fraud, and also to comply with laws applicable to us and to our banking providers and credit card processors. Accordingly, even if you close your Zip account we will retain certain information as necessary to meet our obligations, including where such retention is necessary for legal or business purposes. However, we will identify your account in our database as “inactive” or “closed”.

6. Protection of Personal Data

We take all reasonable steps to ensure that the Personal Data we collect, use or disclose is accurate, complete, up-to-date, relevant and stored securely to the extent possible and within our control.

We also take all reasonable steps to ensure that the Personal Data we hold is protected from misuse, interference, loss, unauthorized access, modification or disclosure by the use of various methods including access limitation, and industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.

Zip will provide some or all of its Services from systems located outside of the Philippines. As such, Merchants are required to disclose to Checkout Users that personally identifiable information may be transferred, processed and stored outside of the Philippines.

Zip maintains strict administrative, technical and physical procedures to protect information stored in our servers, which are located in the United States and Singapore. Access to information is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions.

7. Changes to this Policy

We reserve the right to make changes to this Policy from time to time. Please review this Policy periodically to check for updates. Your use of the Website and/or our Services constitutes consent to the Policy in force on the website at such time, save that if there are any changes to the Policy and such changes are material and/or retroactive, we may provide additional notice and/or an opportunity to “opt-in,” as appropriate under the circumstances. We may also advise you of changes to this policy by emailing and/or mailing the revised policy to any address(es) you provide us.

8. Access, Correction and Complaints

Merchants can update their account information by signing on to our Website with their Zip account.

If you have any questions or suggestions about this Privacy Policy or would like to access or seek correction of your Personal Data, or if you have complaints regarding our privacy practices, please contact our Privacy Officer by emailing [email protected] or as follows:

• We may, at our discretion, charge a reasonable fee for your access to the personal data.

• We aim to acknowledge receipt of all complaints within five business days and to resolve all complaints within 30 business days (although this may not be possible in all circumstances, and is dependent on the complexity of the issue).

• Where we cannot resolve a complaint within 30 business days, we will notify you of the reason for the delay as well as an indication of when we expect to resolve the complaint.