First Metro Investment Corporation (First Metro) complies with the Data Privacy Act of 2012, its Implementing Rules and Regulations and other applicable laws and regulations. First Metro is committed in safeguarding your privacy and ensuring that your personal and account information is protected. This Data Privacy Policy applies to all personal information that we collect from you for the purpose of providing you with our products and services. By giving us your personal information, you acknowledge and agree to the processing of your personal information following statutory and regulatory standards for data protection as well as the practices set out in this Data Privacy Policy.

Collection of Information
All identifiable information that you provide will only be used within the bounds of applicable Philippine laws and other rules and regulations that may be issued by the Bangko Sentral ng Pilipinas. Non-identifiable data collected from website visitors will only be used to track and serve relevant content users and address their concerns, if any.

When you avail of any of First Metro’s products or services or when you interact with our employees or authorized representatives, we collect your personal information so that we may provide valuable and useful content and services and to offer you additional products and services that we believe you might find interesting.

As defined under the Data Privacy Act of 2012, personal information is any information, from which the identify 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 the individual. In other words, is refers to any data that can be used to identify a person. This may include, among others:

• Personal contact information such as name, residential or office address, email address, birthdate, telephone/mobile phone number, nationality
• Proof of identification (government-issued identification cards or document) such as driver’s license, passport, etc.
• Profession, job, occupation, business or trade
• Latest account and financial information (including source of funds)
• Employment details
• Specimen signature/s

Use of Information
We use the information collected to deliver and provide the products and services that you have availed in order to:

• approve, facilitate, administer and process applications and transactions;
• daily operation or provision of financial products and services to you, managing or carrying out any of your transactions, requests or queries in connection with your contract with First Metro; transaction reporting; enforcement of our agreement with you;
• send you statements, notices and other such documents necessary for continued use of our products and services;
• enhance or upgrade First Metro’s system infrastructure, operational, technical and other internal systems and processes maintained by or on behalf of First Metro;
• comply with/implement internal credit risk and control management, administration, audit, administrative processes, compliance functions/programs/policies; the terms and conditions governing our products and services pursuant to the rules and regulations of the Securities and Exchange Commission and Bangko Sentral ng Pilipinas; legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction
• 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 (AMLA), as amended and the implementation of know your customer and sanction screening checks;
• 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;
• perform other such activities permitted by law or with your consent

We ensure that the handling of your information adheres to the established security standards and procedures. Further, up-to-date technology is in place to prevent unauthorized access which undergoes continuous assessment designed to improve means in securing your privacy.

Sharing of Information
We assure you that we do not, and will not, share, rent or sell personal information to third parties outside of our company (or the group of companies of which it is a part of) without your consent. All our engagements with third party service providers 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.

In some instances, we may share your personal information with our subsidiaries, affiliates and third parties as part of business operations, under an obligation of confidentiality. This means that we might share information with:

• our parent, subsidiaries and affiliates to likewise offer you additional products and services that we believe you might find interesting;
• other organizations or agencies or business partners that act as our service provider;
• government agencies when required by law or regulation or by competent order of the courts;
• other companies with whom our client have provided consent to share information

Protection of Information
The integrity, confidentiality and availability of your information are important to us. We strictly enforce our privacy policy by implementing stringent technological, organizational and physical security measures that are intended to protect your information from unauthorized access, use, alteration and disclosure. In addition, 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.

Nonetheless, we encourage you to be vigilant in protecting your personal data by ensuring that your personal information is not disclosed to others nor written where it may be accessible to others.

Retention of Information
First Metro takes reasonable steps to ensure that your personal information shall be retained for the period necessary to fulfill the purpose/s for which it was collected and such other purposes that you may have consented to from time to time or until such time as it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes.

Rights of Clients
The Data Privacy Act of 2012 and its Implementing Rules and Regulations afford our clients certain rights. In exercising these rights, you may:

• Object to the processing of your personal information;
• Opt 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;
• Access your data;
• Modify inaccurate data or update information;
• Update your information;
• Request for deletion or suppression of data

How to Contact Us
For any queries, clarifications or requests on any aspect of this Data Privacy Policy, 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, you may contact our Data Protection Officer through the following:

DATA PROTECTION OFFICER
45th Floor, GT Tower International
6813 Ayala Ave. cor. H.V. dela Costa St.,
1227 Makati City, Philippines
Telephone No.: (+632) 8858 7900 local 160
Fax No.: (+632) 8840 3706
Email address: dpcu@firstmetro.com.ph

Changes to Our Data Privacy Policy
From time to time, First Metro may modify or amend this Data Privacy Policy to comply with any changes in government and regulatory requirements; align with industry practices, or for other legitimate purposes. We assure you that we shall give sufficient notice if there are material changes, and we shall secure your consent, if required by law.

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