Maintaining your privacy is an important part of the products and services that we provide. This Privacy Statement, hereafter referred to as "Statement", explains how we collect, protect, use, and share information when you access our websites and/or apply for and avail of our products and services.

Seedbox Technologies, Inc. ("Seedbox"), together with Technologies, Inc., ATR Asset Management, Inc., and ATRAM Trust Corporation, and any of their respective parent, subsidiaries, and affiliates (collectively, the "ATRAM Group") operates the Seedbox Philippines, an online investment platform provider. This Statement outlines the general practices of Seedbox Technologies, Inc. and the ATRAM Group in relation to our processes and content which are made available through our websites, our online and mobile applications, and social media pages (collectively referred to as "websites"). This Statement also covers the privacy practices for our customers who apply for and obtain products and services from or through us, such as, but not limited to, investments, insurance, and other such products and services that Seedbox may offer from time to time.

The privacy practices described in this Statement are primarily intended for individuals in the Philippines and are designed to comply with the Data Privacy Act of 2012 (R.A. 10173) and its implementing rules and regulations. When accessing our websites and/or availing of our services from outside the Philippines, you acknowledge and agree that your information may be transferred to and processed in the Philippines following legal and regulatory standards for data protection that may differ from your current or home jurisdictions.

I. Information We May Collect

When you apply for or avail of any product or service offers by or through us, or when you interact with our employees, authorized representatives, agents and service providers, we collect your personal information. This may include, among others:

  1. your name and personal particulars such as contact details, address, gender, birthdate, education, nationality, family members and relationships;
  2. specimen signatures;
  3. government ID details including your TIN No., SSS No., or GSIS No.;
  4. financial information (such as income, expenses, balances, investments, tax, insurance, financial and transaction history, investment experience, investment horizon, risk appetite, liquidity requirements, financial goals, etc.);
  5. employment details;
  6. business interests and assets;
  7. images via CCTV and other similar recording devices and processes which may be observed when visiting our offices and/or using our other facilities;
  8. voice recordings of our conversations with you; and
  9. any other information that may be required by local and foreign regulatory agencies.

We may, as and when necessary, seek to verify or augment these information with third-party entities including government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction and, in the process, gain additional information about you.

In the course of availing our products and services, we also collect information about your transactions and dealings which include your account activities, movements and interactions with third parties.

When you access our websites, we may provide information about us as well as information regarding products and services available from our through us. If you have enrolled your account as a condition of use, you may conveniently access your accounts through our website. In the course of using our network of websites and electronic platforms, we may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. We may likewise use web analytics tools, including those of third parties’, that use cookies to collect anonymous information and data generated in connection with your activities when you visit the pages and our network of websites.

We may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives, agents, and service providers.

II. Use of Information

We use the information collected to deliver and provide the products and services that you have availed to:

  1. approve, facilitate, administer and process applications and transactions;
  2. respond to queries, requests and complaints and improve how we interact with you;
  3. send you statements, billings, notices and other such documents necessary for continued use of our products and services;
  4. conduct studies and researches for the purpose of reviewing, developing and improving our products and services;
  5. perform profile analysis, behavioral modeling and analytics to understand needs, preferences and market trends to be able to improve and recommend suitable products and services;
  6. reach out to you regarding products and services information, including offers, promotions, discounts, rewards; and for personalizing your experience with our various touchpoints such as branches, call center, telemarketing, email, messaging and other channels;
  7. determine the effectiveness of our marketing efforts and initiatives;
  8. perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;
  9. comply with our operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time.
  10. comply with applicable laws of the Philippines and those of other jurisdictions including the United States Foreign Account Tax Compliance Act (FATCA), the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended (AMLA) and the implementation of know your customer and sanction screening checks
  11. comply with legal and regulatory requirements such as submission of data to credit bureaus, credit information companies, the Credit Information Corporation (CIC) (pursuant to RA No. 9510 and its implementing rules and regulations) responding to court orders and other instructions and requests from any local or foreign authorities including regulatory, governmental, tax and law enforcement authorities or other similar authorities;
  12. perform other such activities permitted by law or with your consent.

III. Sharing of Information

Many of the products and services available in our online investment platform are provided by ATR Asset Management, Inc., ATRAM Trust Corporation, and third-party financial product providers or distributors. A list of third-party financial product providers presently available on the platform can be accessed here: {Insert link to list} and on the product page of our website. The foregoing lists shall be updated continuously as additional third-party product providers are made available on the Seedbox platform.

When you avail of products and services provided by the other members of the ATRAM Group, or other third-party financial product providers and distributors, you also become their client. Accordingly, it is necessary for us to use, process, and share your personal data to such members of the ATRAM Group and third-party providers for the same purposes enumerated above, as well as the following:

  1. To facilitate your account opening or application with the concerned subsidiary, affiliate, or third party financial product provider;
  2. To validate, consolidate or update your customer information records;
  3. To provide consolidated billings, investment summaries, or other reports as you may request;
  4. To send you reminders, announcements, promotions, offers, invitations and other notifications;
  5. To enroll you in loyalty or similar client-oriented programs of Seedbox;
  6. For research purposes or to design, financial, securities and investment or other related products or services for your use;
  7. For promotional and/or marketing activities of Seedbox or of the concerned subsidiary/ies, affiliate/s, or third-party fund providers; and
  8. To comply with a legal obligation to which Seedbox or the concerned subsidiary, affiliate, or third party fund provider is subject.

And by availing of such products and services, you also agree to their respective privacy policies of the relevant entity.

Additionally:

  1. We may share personal information with our parent, subsidiaries, affiliates and third parties in order to better understand the way you use our products and services. This will allow us to improve our services and offer you opportunities to obtain such other useful products and services that may deliver greater value to you.
  2. We may share information with our parent, subsidiaries and affiliates to likewise offer you additional products and services that we believe you might find interesting.
  3. We may share with third parties that we engaged to support us in delivering our services to you. These may involve anonymous or aggregated information to help improve our products, services, and content.
  4. We may also share information with third parties we engage, including third-party data processors, to help us operate our business. These include support in:
    • complying with legal requirements such as court orders;
    • enforcing our terms of use and other applicable policies with respect to the services that we provide;
    • addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property or security of our customers or third parties;
    • to carry out all other purposes set out above.

We may transfer, store, and/or process your personal data outside the Philippines. In doing so, we will comply with the Data Privacy Act and its implementing rules and regulations.

We wish to assure you that we do not, and will not, sell personal data to any third parties. All our engagements with third parties shall be fully compliant with our obligation of confidentiality imposed on us under the applicable agreements and/or terms and conditions or any applicable laws that govern our relationship with you.

IV. Data Retention

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time, remains in effect and until such time as it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes.

Under present Anti Money Laundering Rules and Regulations, all records obtained through customer due diligence, account files and business correspondence, and the results of any analysis undertaken must be kept, for, at least, five (5) years following the closure of account, termination of the business or professional relationship or after the date of the occasional transaction.

V. Protection of Information

We fully recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc. Appropriately, we strive to maintain the confidentiality, integrity and availability of your personal information by employing physical, technological and procedural safeguards. We train our employees to properly handle your information. Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards.

VI. Data Privacy Rights

In respecting your rights to privacy, you may opt to tell us:

  1. not to send you marketing materials via email;
  2. not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the services that you have availed with us;
  3. to provide you with information that we currently have about you subject to restrictions applied to us as a bank and a company operating in the Philippines by certain laws and regulations;
  4. to update your information;
  5. about your other concerns relating to how we collect, use, share, protect or dispose your information.

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you prior to making the request.

For any queries, clarifications or requests on any aspect of this Statement, the exercise of your rights pertaining to your personal information or to provide any feedback that you may have about our processing of personal information, please visit any of our office or call us at _____________. You may also email us at support@seedbox.com.ph which is manned during business hours.

You may also write our Data Privacy Officer at:

  • Seedbox DPO
  • (dpo@seedbox.ph)
  • Seedbox Technologies, Inc.
  • 8/F 8 Rockwell, Hidalgo St., Rockwell Center
  • Makati City 1210
  • Philippines

We may modify or amend this Statement from time to time to keep up with any changes in relevant laws and regulations applicable to us or how we collect, use, protect, store, share or dispose of your personal information. Any relevant updates will be posted on our website.

*Definitions:

Personal Information/ 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.

Sensitive Personal Information/ Data - refers to personal information:

  1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
  2. About an individual's health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
  3. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
  4. Specifically established by an executive order or an act of Congress to be kept classified.
  • Seedbox Data Privacy Statement v2.0
  • Updated: 2021 January 08

Seedbox Philippines is a digital platform that lets you invest in funds online.

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