🇵🇭 Philippines Privacy Disclosure

1. Introduction

This Philippines Privacy Disclosure supplements our general Privacy Policy and provides specific information for individuals in the Philippines regarding how Asset Nexus Software Development and Marketing Firm collects, uses, and protects personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR).

2. Data Privacy Act of 2012 Compliance

2.1 Our Commitment

We are committed to protecting your personal data in accordance with the Data Privacy Act of 2012 (DPA). We have implemented appropriate technical and organizational measures to ensure the security and confidentiality of your personal information.

2.2 Personal Data Controller

Asset Nexus Software Development and Marketing Firm acts as the Personal Data Controller for the personal data collected through the Asset Dispatch TMS platform. Our contact information is provided at the end of this disclosure.

2.3 Registration with NPC

We have registered our data processing systems with the National Privacy Commission (NPC) in accordance with DPA requirements. Our registration details are available upon request.

3. Personal Data We Collect

3.1 Definition of Personal Data

Under the DPA, "personal data" means 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.

3.2 Types of Personal Data Collected

We collect the following types of personal data from Philippine residents:

• Common Personal Data: Name, email address, phone number, address, date of birth
• Sensitive Personal Information: Health information, medical certificates, driver's license details, CDL information
• Privileged Information: Information arising from attorney-client relationships, doctor-patient relationships (where applicable)
• Employment Data: Employment details, salary information, work history
• Location Data: GPS coordinates, location history, geofence data
• Financial Data: Bank account details, earnings, settlements, expense records
• Biometric Data: Facial recognition data (if used for authentication)
• Communication Data: Messages, call logs, notification preferences

4. Legal Bases for Processing

We process your personal data based on the following lawful bases under the DPA:

• Consent: You have given your consent for the processing of your personal data for specific purposes
• Contract: Processing is necessary for the performance of a contract to which you are a party (e.g., employment contract, service agreement)
• Legal Obligation: Processing is necessary for compliance with a legal obligation (e.g., FMCSA regulations, labor laws, tax requirements)
• Vital Interests: Processing is necessary to protect your life or health (e.g., emergency response, medical assistance)
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided that your fundamental rights and freedoms are not overridden
• Public Interest: Processing is necessary for the performance of a function carried out in the public interest

5. Purposes of Processing

We process your personal data for the following specific purposes:

• Service Provision: To provide and operate the Asset Dispatch TMS platform and its features
• Employment Management: To manage employment relationships, payroll, and benefits
• Compliance Monitoring: To ensure compliance with FMCSA, DOT, and other regulatory requirements
• Safety and Security: To monitor driver safety, track vehicle location, and respond to emergencies
• Financial Processing: To process payments, settlements, and reimbursements
• Communication: To communicate with users about services, updates, and important information
• Analytics and Improvement: To analyze usage patterns and improve our services
• Legal Compliance: To comply with legal obligations and regulatory requirements

6. Data Processing Principles

We adhere to the following data processing principles under the DPA:

• Transparency: We inform you about the processing of your personal data
• Legitimate Purpose: We process personal data for specified, explicit, and legitimate purposes
• Proportionality: We process only personal data that is adequate, relevant, and not excessive
• Accuracy: We ensure personal data is accurate and kept up to date
• Security: We implement appropriate security measures to protect personal data
• Retention: We retain personal data only for as long as necessary for the purposes of processing

7. Sensitive Personal Information

7.1 Definition

Under the DPA, "sensitive personal information" refers to personal information:

• About an individual's race, ethnicity, marital status, age, color, and religious or philosophical affiliations
• 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
• 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
• Specifically established by an executive order or an act of Congress to be kept classified

7.2 Processing Sensitive Personal Information

We process sensitive personal information only when:

• You have given explicit consent to the processing
• Processing is necessary for the exercise or performance of functions of government authorities
• Processing is necessary to protect your life or health
• Processing is necessary for medical diagnosis, treatment, or health care
• Processing is necessary for the protection of your lawful rights
• The information is necessary for the fulfillment of a contract with you
• Processing is authorized by law

8. Data Sharing and Disclosure

8.1 Sharing with Third Parties

We may share your personal data with third parties under the following circumstances:

• Your Employer: With your employer (carrier company) for employment and operational purposes
• Service Providers: With trusted third-party service providers (ELD providers, payment processors, etc.) who assist us in providing services
• Regulatory Authorities: With government agencies when required by law (NPC, DOT, FMCSA, etc.)
• Legal Proceedings: In connection with legal proceedings or to protect our rights
• Business Transfers: In connection with mergers, acquisitions, or sales of business assets

8.2 International Data Transfers

Your personal data may be transferred to and processed in countries outside the Philippines. We ensure that appropriate safeguards are in place for such transfers, including:

• Standard contractual clauses approved by the NPC
• Adequacy determinations by the NPC
• Binding corporate rules (where applicable)
• Other appropriate safeguards as required by the DPA

9. Data Subject Rights

As a data subject under the DPA, you have the following rights:

9.1 Right to be Informed

• You have the right to be informed whether personal data pertaining to you shall be, are being, or have been processed
• You have the right to be informed of the processing details, including the purposes, scope, and recipients of your personal data

9.2 Right to Access

• You have the right to access your personal data that we hold
• You have the right to obtain a copy of your personal data in a commonly used format
• Requests for access should be made in writing and will be processed within 30 days

9.3 Right to Object

• You have the right to object to the processing of your personal data
• You may object to processing based on legitimate interests if you have compelling legitimate grounds
• You may object to processing for direct marketing purposes at any time

9.4 Right to Erasure or Blocking

• You have the right to request the erasure or blocking of your personal data
• We will comply with such requests when personal data is no longer necessary for the purposes of processing
• Certain exceptions apply where retention is required by law or for legitimate business purposes

9.5 Right to Damages

• You have the right to claim damages if your personal data is processed in violation of the DPA
• Damages may include material damage and moral damages

9.6 Right to Data Portability

• You have the right to receive your personal data in a structured, commonly used, and machine-readable format
• You have the right to transmit your personal data to another controller without hindrance

9.7 Right to File a Complaint

• You have the right to file a complaint with the National Privacy Commission if you believe your rights under the DPA have been violated
• Complaints can be filed through the NPC's official channels

10. Exercising Your Rights

10.1 How to Make a Request

To exercise any of your rights as a data subject, you may:

• Send a written request to our Data Protection Officer
• Include your full name, contact information, and a clear description of your request
• Provide proof of identity to verify your request
• Specify the personal data to which your request relates

10.2 Response Time

We will acknowledge your request within 5 working days of receipt and will respond to your request within 30 days, subject to the complexity of your request. If we need additional time, we will inform you and provide an explanation.

10.3 Fees

We will not charge fees for processing your data subject rights requests, except in cases where requests are manifestly unfounded, excessive, or repetitive. In such cases, we may charge a reasonable fee based on administrative costs.

11. Data Security

11.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption: Data is encrypted in transit and at rest
• Access Controls: Role-based access control restricts data access to authorized personnel
• Authentication: Multi-factor authentication and secure login protocols
• Regular Audits: Regular security audits and vulnerability assessments
• Employee Training: Regular training on data protection and privacy
• Incident Response: Procedures for detecting, reporting, and responding to data breaches

11.2 Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the National Privacy Commission within 72 hours of becoming aware of the breach
• Notify you without undue delay if the breach poses a high risk to your rights and freedoms
• Provide details of the breach, its likely consequences, and measures taken to address it

12. Data Retention

12.1 Retention Periods

We retain your personal data for the following periods:

• Personal Information: Duration of employment plus 5 years
• Location Data: 6 months to 2 years depending on purpose
• HOS Data: 6 months as required by FMCSA
• Load Data: 7 years for business and legal purposes
• Financial Records: 7 years as required by tax laws
• Employment Records: Duration of employment plus 10 years
• Communications: 1-2 years for business purposes

12.2 Secure Disposal

When personal data is no longer needed for its intended purpose, we will securely dispose of it using appropriate methods such as deletion, shredding, or anonymization.

13. Children's Privacy

The Asset Dispatch TMS platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take immediate steps to delete such information.

14. Changes to This Disclosure

We may update this Philippines Privacy Disclosure from time to time to reflect changes in our practices, changes in DPA regulations, or other relevant developments. We will post the updated disclosure on this page with the revision date and will notify users of material changes.

15. Data Protection Officer

We have designated a Data Protection Officer (DPO) to oversee our compliance with the DPA and to serve as the point of contact for data subject inquiries.

16. Contact Information

For questions, concerns, or requests regarding this Philippines Privacy Disclosure or your data subject rights, please contact us:

17. National Privacy Commission

If you believe your rights under the Data Privacy Act of 2012 have been violated and you wish to file a complaint with the National Privacy Commission, you may contact them at:

This Philippines Privacy Disclosure is effective as of May 7, 2026, and will remain in effect until replaced by a revised version.