Last Updated: October 3, 2023
Inquiro Inc. (“Inquiro” or “we” or “our”) cares about data privacy and is committed to protecting the personal data we process.
1. Where does Inquiro source the personal data it’s processing?
Inquiro is a B2B company, which means, we deal, transact, enter into contracts with and provide our products and services to other companies only. As a consequence, we do not collect personal data directly from data subjects, except from the following individuals:
- Inquiro’s employees, consultants and personnel;
- Individuals who submit their CV/resume and other personal data with the view of applying for a role in the company;
- Individuals who visit and use our website, submit questions in the contact form or those who inquire about our products and services through other channels; and
- Authorized representatives of our existing and potential enterprise clients.
We may also obtain and process personal data shared to us by our partners and affiliates under our existing partnerships with them. In such instances, we ensure that they have obtained the consent of their data subjects before sharing any personal data with us. We may likewise process personal data of the data subjects of our enterprise clients when we are contracted to do so.
2. What information does Inquiro process and what for?
The information that we process and use are either personal data or non-personal data. We process personal data, such as age, location, points of interest, lifestyle, connectivity and device information, to gain insights about consumers and market trends. These insights are then turned into non-personal data, such as statistical or analytical information, and anonymized or aggregated reports, that our enterprise clients may use to formulate their marketing strategies and offer their products to the correct audience.
We process the following personal data to continuously provide our services to our enterprise clients:
|Purpose||Category of Data Subject||Category of Personal Data||Criteria|
|Provision of products and services, to allow enterprise clients to create an account to use the business intelligence dashboard and for the provision of client support||Authorized representatives of our existing enterprise clients (e.g., employees or other personnel authorized to create a user account to access and use Inquiro’s products)||Name and work-related information, e.g., company-issued contact details and role||Contractual Obligation|
|Designing, developing, selling and operating products and services using processed data in the form of profiles processed by our partners and affiliates, and conducting data analytics and data enrichment on these profiles||Customers of our partners and affiliates||Personal data of our partners’ and affiliates’ customers, e.g., name, age range, location, points of interest, lifestyle, connectivity information, mobile number and device ID||Consent
|Provision of services such as data analytics, data enrichment, credibility scoring for our enterprise clients’ business use through anonymized or aggregated reports||Customers of our enterprise clients||Mobile numbers of our enterprise clients’ customers||Consent
|Communication of our enterprise clients’ marketing and advertising materials through the use of the services of Inquiro’s partners via SMS, social media or programmatic channels||Customers of our enterprise clients; customers of our partners and affiliates||Mobile numbers of our enterprise clients’ customers or ID assigned to a mobile device by the mobile device’s operating system||Consent
|Responding to leads or queries regarding our products and services||Individuals who visit and use our website or submit questions via the contact form or through other channels||Name and work-related information, e.g., company-issued contact details and role||Consent
Save for purposes where we obtain consent from data subjects directly, our partners, affiliates, and enterprise clients are responsible for obtaining consent from the relevant data subjects on our behalf for profiling, enrichment, and sharing of their personal data as well as for direct marketing and advertisements purposes.
We make sure that our partners, affiliates, and enterprise clients never share any personal data with us unless they obtain the consent from the data subjects or are otherwise required or allowed by law to do so.
Profiling & Automated Decision Making
We, our partners, and affiliates process personal data to create profiles that reflect insights on customers’ preferences. Automated processes are utilized to produce these insights for our enterprise clients’ business use, including choosing the right products and services they can offer to a particular audience.
To be clear, when we share data with enterprise clients for their business use, advertising, and marketing purposes, we only share anonymized and aggregated insights and reports.
3. Does Inquiro share personal data to other parties?
We do not share personal data to any external party, except if and when we outsource the enrichment of profiles. In such a case, only the mobile numbers or device IDs are shared with them and we make sure they are contractually obligated to access and use the personal data only for the duration of our contract with them. They are also required to protect personal data we share, and hold it confidential using organizational, physical, and technical security measures that are consistent with our policies.
4. How does Inquiro protect personal data?
We secure and protect personal data using appropriate safeguards to ensure confidentiality and privacy, prevent loss, theft, use for unauthorized purposes, and comply with the requirements of the law.
To detect and mitigate evolving threats to information security and data privacy, we have implemented appropriate organizational, physical, and technical controls to protect the personal data we process, including:
- A dedicated team that manages, monitors, and protects our network and systems from potential risks to personal data under fully documented security incident management procedures;
- Regular review of our collection, storage, and processing practices including physical and electronic security measures to guard against unauthorized access to our network and systems;
- Contractually-mandated confidentiality among our authorized employees, contractors, and other external parties who may have access to personal data we hold;
- External party risk assessment as well as minimum-security features against data leakage, unauthorized access or disclosure, and accountability; and
- Access management across Inquiro employees and external parties under a “need-to-know” policy.
5. Does Inquiro retain personal data, and for how long?
We retain personal data for a period dictated by the purposes for which the personal data is processed, or for other business or legal purposes such as security and fraud prevention.
In general, our retention and disposal schedule is as follows:
- Customer mobile numbers shared by our enterprise clients for processing – coterminous with the term of the agreements we sign with the enterprise clients, which can range from seven (7) days to one (1) year from signing of the agreement
- Information of our enterprise clients’ authorized representatives – coterminous with the term of the agreements we sign with the enterprise clients, which can range from seven (7) days to one (1) year from signing of the agreement (assuming there are no outstanding obligations)
- Information provided by individuals who send inquiries about our products and services – information provided through our website is deleted every 24 hours, while information provided through other channels is deleted every first week of the month
- Processed personal data shared to us by our partners and affiliates for designing, developing, and operating our products and services – applicable retention period follows what is stipulated in the agreements we sign with our partners and affiliates, which can range from one (1) year from signing of the agreements or until a specific date
We have also established procedures to securely dispose of files that contain personal data whether in digital or physical form.
6. Does Inquiro recognize data subject rights?
We recognize data subject rights under the Data Privacy Act of 2012, and we also ensure that our partners, affiliates and enterprise clients do the same.
These data subject rights include:
Right to Be Informed
Data subjects have the right to be informed of how and why we collect and process personal data, including where we sourced it, with whom we share it and why, how we protect it, how long we keep it, and how we dispose of it, and any changes to our data processing activities before they are implemented.
Right to Object
Data subjects have the right to object or withdraw their consent to the processing and/or sharing of their personal data especially when they feel that we do not have lawful grounds to do so.
When our processing of personal data depends on consent, data subjects have the right to withdraw their consent at any time subject to our, our partners’, affiliates’ or enterprise clients’ internal procedures. This, however, does not apply to instances where we rely on grounds provided by law, other than consent.
When a data subject submits a request to withdraw consent to us, we will discuss this with our partners, affiliates or enterprise clients, if applicable given the circumstance, to ensure the relevant parties are aligned and informed of the request. This will also give our partners, affiliates or enterprise clients the opportunity to update their records.
When a data subject submits a request to withdraw consent to our partners, affiliates or enterprise clients, they are legally and contractually obligated to update us to give us time and opportunity to exclude such personal data from further processing.
In addition, there are specific opt-out processes that data subjects can exercise without submitting requests to us or to our partners, affiliates and enterprise clients:
- Mobile app opt-out: If data subjects opt-out on their mobile device, the ID assigned to their device will not be used to build profiles or target them with interest-based ads. To opt out using a mobile device, visit the device’s privacy settings. For iOS, find Apple Advertising and turn off Personalized Ads. For Android, go to Ads where a data subject can either reset or delete the advertising ID.
- Mobile web opt-out: If data subjects intend to opt out of targeted advertising on their mobile webs, they need to go to their web browser settings.
Please note that the opt-out procedures are specific to the mobile device or web browser on which they are exercised. Thus, data subjects may still receive interest-based ads on their other device or other web browser. Nonetheless, if these specific opt-out procedures are exercised, the data subjects will continue to receive ads but not tailored to their interest.
Right to Access
Data subjects have the right to request reasonable access to their personal data in accordance with our internal procedures. We, however, reserve the right to seek reasonable fees when providing such data presents certain challenges due to its volume as well as to restrict access to linked data that may be confidential, proprietary, or belong to other individuals.
Right to Data Portability
Data subjects have the right to obtain a copy of their personal data or have it transmitted to other entities in a format that is portable and commonly accessible subject to our internal procedures.
Right to Rectify
We keep our records as accurate as possible. Where there are any errors or inaccuracies to data subjects’ personal data, we have ways for data subjects to dispute and rectify or update it, subject to our internal procedures.
Our partners, affiliates, and enterprise clients are legally and contractually obligated to inform us about any request to rectify personal data that is sent to them. In such a case, our partners, affiliates, and enterprise clients shall notify us of the rectified data so that we can make the necessary updates in our system.
Right to Erasure or Blocking
Data subjects have the right to suspend, withdraw, or order the blocking, removal, or destruction of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data, or personal data not necessary for the purpose for which it was collected, and for such other cases provided in the Data Privacy Act of 2012.
Right to Damages
Data subjects have the right to be indemnified for damages sustained, if any, due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of their personal data.
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8. How can data subjects reach Inquiro?
Should our partners or enterprise clients have questions or concerns about our privacy practices, or if a data subject wants to exercise any of his or her rights, our Data Protection Officer may be reached at:
Data Protection Officer
2/F Globe Telecom Plaza Tower 1
Pioneer St. corner Madison
Barangka Ilaya, Mandaluyong City
Metro Manila, Philippines