Data Privacy Policy

Effective Date: Dec. 1, 2013. Last updated: June 24, 2024.

I. INTRODUCTION

1. Coins.ph has created the following Data Privacy Policy (“Privacy Policy” or “Policy”) to let you know what personal information we collect when you visit our site and/or use the Coins.ph Services (“Services”), which is aptly described in the User Agreement Page (https://coins.ph/user-agreement), why we collect it and how it is used and stored. This Policy takes into consideration the rights and obligations as outlined under the Data Privacy Act 2012 (Republic Act 10173), its Implementing Regulations, and the applicable laws of the Republic of the Philippines.

2. We recognize the importance of the Personal Information you have entrusted to us and as such, we are committed to ensuring that your privacy is safeguarded, and we are transparent as to how we manage, protect, and process your personal information. This Privacy Policy is designed to guide you in understanding how we collect, use, disclose and/or process the personal information that you have entrusted to us.

3. Personal information simply means any information or data that can be used to distinguish, identify or contact you. This may include personal information or sensitive personal information. Under the Data Privacy Act of 2012, Personal Information 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, on the other hand, refers to sensitive personal information" 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 individual, 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 is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; or (4) specifically established by an executive order or an act of Congress to be kept classified.”

4. This Policy explains the data collection and data use practices of Coins.ph website and mobile application. Unless expressly declared, this policy does not apply to other online or offline Coins.ph sites, products or services. The terms “you,” “your,” and “yours” refer to the customer/purchaser utilizing our site. The terms “Coins.ph,” “we,” “us,” and “our” refer to Betur Inc. doing business as Coins.ph, including Coins Pro, and DCPay Philippines, Inc. a company operating under the Coins.ph brand. By using the Coins.ph Services website or mobile application, you consent to the data practices prescribed in this Privacy Policy. In the event that you do not consent to the processing of your personal information as laid out in this Policy, please do not use our services or access our website or mobile application.

5. We may update this Privacy Policy from time to time to comply with the law. It is recommended that you visit this page frequently to check for changes. This Privacy Policy is available on our website or mobile application for easy reference.

II. WHY WE COLLECT PERSONAL INFORMATION AND HOW WE USE IT

1. Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customized experience. We may collect, use, process and examine your personal information when reasonable, relevant and necessary to:

 a. Provide Coins.ph services and customer support timely and efficiently at your request;
 b. Process transactions and send notices about your transactions;
 c. Resolve disputes, collect fees, and troubleshoot problems;
 d. Prevent potentially prohibited or illegal activities; Customize, measure, and improve Coins.ph services and the content and layout of our website and applications;
 e. Deliver direct marketing, service update notices, and promotional offers based on your communication preferences;
 f. Compare information for accuracy and verify it with third-parties; and Monitor the quality and security of the network and train our staff.

When personal information that we may collect from you is used for separate purposes, we will provide you with the list of purposes and uses for which the personal information is collected so that you may freely opt in or out of such services or activities as you may see fit, pursuant to NPC Circular No. 2023-04 on withdrawal of consent.

2. When we can, we aggregate and anonymize this information such that you are never identified as an individual. For the avoidance of doubt, with this practice we try to present information in segments or categories and remove any personally identifiable information from the data.

3. We will not sell or rent your personal information to third-parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize Coins.ph services, content and advertising.

III. HOW WE COLLECT INFORMATION ABOUT YOU

1. When you visit the Coins.ph website or use Coins.ph services or Coins.ph application, we collect information sent to us by your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, unique identifier, name and type, operating system, location, mobile network information and standard web log information such as your browser type, traffic to and from our site, and the pages you accessed on our website.

2. Before permitting you to use Coins.ph services, we may require you to provide additional information we can use to verify your identity or address or manage risk, such as your date of birth, social security number or other information. We also collect your contact details like billing address, telephone number, mobile phone number, email address. We may also obtain information about you from third-parties such as credit bureaus and identity verification services. You can check what we know about you by making a request to the Coins.ph Data Privacy Officer through the contact details provided below. Should you wish to opt out of any ancillary service or process for which your personal information is collected, you may do so at any time through your user preferences or device settings as you may see fit, pursuant to NPC Circular No. 2023-04 on withdrawal of consent.

3. When you use Coins.ph services, we collect information about your transactions and your other activities on our website and we may collect information about your computer or other access device for fraud prevention purposes.

4. You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third-party with your Coins.ph account and authorizing Coins.ph to have access to this information, you agree that Coins.ph may collect, store and use this information in accordance with this Privacy Policy.

5. In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with our website or Coins.ph services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity that may affect the availability of Coins.ph services.

6. Finally, we may collect additional information from or about you in other ways such as interactions with our customer support team.

IV. HOW WE USE COOKIES

1. When you access our website or content or use our application or Coins.ph services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:

 a. Recognize you as a Coins.ph customer;
 b. Customize Coins.ph services, content, and advertising;
 c. Measure promotional effectiveness; and
 d. Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
 e. We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.

2. We also use Local Shared Objects, commonly referred to as “Flash cookies,” to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.

3. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add ons provides instructions on blocking, deleting or disabling cookies.

4. You may encounter Coins.ph cookies or pixel tags on websites that we do not control. For example, if you view a web page created by a third-party or use an application developed by a third-party, there may be a cookie or pixel tag placed by the web page or application. Likewise, these third-parties may place cookies or pixel tags that are not subject to our control and the Coins.ph Privacy Policy does not cover their use.

V. HOW WE PROTECT AND STORE PERSONAL INFORMATION

1. Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

2. We store and process your personal information on our computers in Asia-Pacific and elsewhere in the world where Coins.ph facilities or our service providers are located, and we protect it by maintaining physical, electronic and procedural safeguards. We use computer safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and files. And we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

3. In our offices we have organized departments and implemented data control systems so that those persons who are authorized to view, monitor, analyze, and manage personal information are isolated from other employees.

VI. RIGHTS OF COINS.PH CUSTOMERS

1. Filipino citizens and residents that are customers of Coins.ph irrespective of current jurisdiction have been guaranteed certain privacy and information security rights under the Data Privacy Act of 2012. We value and respect the rights afforded to you. As such, Coins.ph strictly adheres to data privacy rights expressly stated under the Data Privacy Act of 2012, where applicable.

2. Subject to internal processes, and requirements, conditions, and exemptions under relevant law and Data Privacy Laws, you are entitled to the following rights:

 a. To access your personal data;
 b. To dispute any inaccuracy or error in your personal data and require Coins.ph to correct or update the same;
 c. To obtain a copy of your personal data in an electronic or structured format for your further use;
 d. To suspend, withdraw, or order the blocking, removal, or destruction of your personal information from Coins.ph’s system, provided such action is not critical nor required by applicable laws and regulations to maintain the products and services that you availed with us;
 e. To file a complaint with the National Privacy Commission.

3. You may access the National Privacy Commission website at www.privacy.gov.ph, for a complete reference of your rights under the Data Privacy Act of 2012.

4. We reserve the right to charge you a reasonable fee for the handling and processing of your requests to access your personal data, where applicable. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that in most jurisdictions we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

VII. HOW WE SHARE PERSONAL INFORMATION TO FULFILL COINS.PH SERVICES

1. To process your payments we may securely share some of your personal information with the person or company that you are paying or that is paying you. This includes your contact information; date of sign-up; the number of payments you have received from verified Coins.ph users; and, whether you have verified control of a bank account. We manage these data-sharing activities by the guidelines of our information security policy as well as this policy. In addition, this and other information may also be shared with third parties when you use these third parties to access Coins.ph services. Unless you have agreed to it, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Coins.ph services.

2. If you are buying goods or services and pay using Coins.ph, we may also provide the seller with your shipping and confirmed billing address to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to pay your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide the buyer with the seller’s address so that any goods can be returned to the seller.

3. We work with third parties, including merchants, to enable them to accept or facilitate payments from or to you using Coins.ph. In this case, a third party may share information about you with us, such as your email address or mobile phone number to inform you that a payment is sent to you or when you attempt to pay that merchant or through that third party. We use this information to confirm that you are a Coins.ph customer and that virtual asset (e.g. bitcoin, etc.) as a form of payment can be enabled, or where a payment is sent to you, to send you notification that you have received a payment. Also, if you request that we validate your status as a Coins.ph customer with a third party we will do so. Please note that merchants you buy from and contract with have their own privacy policies, and Coins.ph cannot be held responsible for their operations, including, but not limited to, their information practices.

4. In relation to the sharing of and release of your personal information, you hereby acknowledge and agree that your personal information may be collected, used, disclosed, and/or processed or otherwise dealt with outside of the Philippines where Coins.ph, its subsidiaries, and affiliates, and third parties may operate their business, by providing Coins.ph services.

VIII. HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

1. We may share your personal information with:

 a. Service providers under contract who help with parts of our business operations. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
 b. Financial institutions with which we partner. Our partners are likewise bound by obligations to keep your Personal Data confidential and use them only for purposes for which we disclose to them.
 c. Companies that we plan to merge with or be acquired by. (Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. You will receive prior notice of any change in applicable policy.)
 d. Law enforcement, government officials, or other third parties when:

  i. We are compelled to do so by a subpoena, court order, or similar legal procedure; or
  ii. We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss;
  iii. We report suspected illegal activity or investigate violations of our User Agreement.
  iv. Other third parties with your consent or direction to do so.

2. Coins.ph will not sell or rent any of your personal information to third parties for their marketing purposes and only share your personal information with third parties as described in this policy.

3. If there is an actionable breach of your personal information, we will notify you within 72 hours.

4. If you establish a Coins.ph account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Coins.ph website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.

IX. HOW WE PROTECT YOUR INFORMATION

1. The integrity, confidentiality, and security of your information are particularly important to us. That’s why we strictly enforce our privacy policy within the company and we have implemented technological, organizational, and physical security measures that are designed to protect your information from unauthorized access, use, alteration, and disclosure. We also put in effect safeguards such as:

 a. We keep and protect your information using a secured server behind a firewall, encryption, and security controls;
 b. We restrict access to your information only to qualified and authorized personnel who hold your information with strict confidentiality;
 c. We undergo regular audits and rigorous testing of our infrastructure’s security protocols to ensure your data is always protected; and
 d. We let you update your information securely to keep our records accurate.
 e. As a Bangko Sentral ng Pilipinas regulated financial institution, we will retain your Personal Information, such as registration and transaction records, throughout the subscription of our products and services, and for a maximum period of five (5) years after account closure, in accordance with Philippine AML laws and regulations, as they might be amended from time to time.
 f. When retention is no longer required, your Personal Information will be destroyed in irretrievable and unusable form in accordance with our secure information destruction and disposal policy and with respect to applicable laws.

X. HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

1. You have certain rights in relation to your Personal Information under the Data Privacy Act of 2012, which include the right to object to processing, the right to access your data, the right to amend or rectify inaccurate data, and the right to erasure or blocking of data.

2. If you wish to have access to your personal information in our records; or you think that such personal information we have of you is incomplete, not up-to-date, or otherwise inaccurate; or prefer to opt out of this privacy policy you may get in touch with our Data Privacy Officer through the contact details provided below.

3. You may always review and edit your personal information at any time by logging into your account and clicking the ‘Profile’ or ‘My Account’ tab. If you close your Coins.ph account, we will mark your account in our database as “Closed,” but will keep your account information in our database as per the time limits above mentioned. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud, assist law enforcement, as required by law, or in accordance with this Privacy Policy.

XI. HOW YOU CAN CONTACT US ABOUT PRIVACY CONCERNS/QUESTIONS

1. If you have questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal information, you may contact our Data Protection Officer directly through the following address and contact information:

Company Name Address and Contact Information
Betur, Inc. (dba Coins.ph) 15th Floor Asian Century Center, 27th Street Corner 3rd And 4th Avenue, Fort Bonifacio, Taguig City

(02)882-26467 (882-COINS) from 8am - 7pm
(Mondays to Fridays)

privacy@coins.ph; dpo.betur@coins.ph
DCPay Philippines, Inc. 35/F Eco Tower Building, 32nd Street corner 9th Avenue, Bonifacio Global City, Taguig.

(02)882-26467 (882-COINS) from 8am - 7pm
(Mondays to Fridays)

privacy@coins.ph; dpo.dcpay@coins.ph

Please include your name, contact information, and the nature of your concern/request so that we can appropriately respond to your communication.

2. For other Coins.ph concerns, you may reach us on our support page through any of the following official channels: Coins.ph Help Center (https://support.coins.ph/hc/en-us and in mobile application) or by contacting our Coins.ph Hotline at (02) 882-26467 (882-COINS) from 8am - 7pm, Mondays to Fridays or simply send us a message through our mobile application or website.

Last updated: June 24, 2024