Robinsons Malls, including its parent company, subsidiaries, affiliates, officers and employees, is committed to uphold the privacy rights of individuals under the Republic Act No. 10173 (otherwise known as the “Data Privacy Act of 2012”), its implementing Rules and Regulations, and other applicable and related privacy regulations. This Privacy Policy describes how we collect, use, protect and manage your personal information, which you have provided freely and with your express consent, through this website.

All personal information collected is processed in adherence to the general principles of transparency, legitimate purpose and proportionality.

THIS PRIVACY POLICY EXPLAINS:

1. What information we collect and why we collect it;

2. How we use that information and to whom we may disclose it;

3. How we safeguard your personal information.

PERSONAL INFORMATION TO BE COLLECTED:

We may collect your personal information when:

You create a Robinsons Malls Promo Site account and log-in to your account. By logging-in to your account, you will be able to do the following:

● View ongoing promos and games;

● Join ongoing promos and games;

● Update your account profile;

● Delete your account profile;

● Participate in surveys or polls to improve customer experience/satisfaction;

● Receive notifications and updates (through call, text or email) about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications.

The personal information we collect may include but is not limited to the following:

Basic personal information such as name, birthday, gender, civil status, nationality, e-mail address, mobile number, and other information necessary to complete transaction and/or address your concern, request or complaint. In selected promos, we may ask for your mailing address, city/municipality, province. Please note that you are responsible for ensuring that all such personal information you submit through the Robinsons Malls Promo Site is accurate, complete and up-to-date.

In addition, we may also collect information about your visit and use of our website, your browsing behavior and session lengths that are collected by our website analytics tools and cookies that are transferred to your computer.

Collection and use of personal information:

Robinsons Malls collects, uses and discloses your Personal Information for the following purposes:

· For you to have a better online browsing experience;

· For you to create a Robinsons Malls Promo Site account;

· For you to view and/or join our promos and games;

· For you to provide reviews in our products and services;

· For you to subscribe/unsubscribe to our e-newsletters;

· To generate statistical insights;

· To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction;

· To respond to specific complaints, inquiries, requests or to provide requested information;

· To provide customer care activities, monitor our quality and security, and provide services timely and efficiently; and,

· To notify and update you (through call, text or email about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications;

· To comply with Robinsons Malls Promo Site’s obligations under the law and as required by government organizations and/or agencies;

· To comply with legal and regulatory requirements or obligations; and

· To perform such other processing or disclosure that may be required under laws or regulations.

DATA TRANSFERS:

The information that we collect may be disclosed or shared to our subsidiaries, affiliates, vendors, partners, service providers, or in any of the countries in which we make use of cloud services to assist us in providing and performing our services. If necessary, a data sharing and non-disclosure agreement shall be executed between Robinsons Malls and its subsidiaries, affiliates, vendors, partners or service providers. However, these companies may only use such personal information for the purpose(s) disclosed in this Privacy Policy and may not use it for any other purpose.

RETENTION AND DISPOSAL OF YOUR PERSONAL INFORMATION:

We will only retain your personal information for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal requirements. Thereafter your personal information shall be disposed

or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION:

Accessing Your Personal Information

You may get in touch with us and request your personal information stored in our database. The provision of such information will require submission of appropriate proof of your identity.

a. We may withhold personal information requested to the extent permitted by law;

b. You may inform us at any time not to process your personal information for marketing purposes;

c. In practice, you will either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Updating Your Personal Information

Robinsons Malls shall make all reasonable efforts to ensure that your personal information in our database is accurate and updated. Should you want to access, correct, delete or update your personal information, you may send the request to dpo@robinsonsland.com or get in touch with our respective customer support representatives.

As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once verified, we will proceed with the requested changes/s or modification/s then notify you that your request has been completed.

Withdrawal of Consent

If you decide to withdraw your consent for any or all purposes set out in this policy, you may send your detailed request to dpo@robinsonsland.com. Depending on the nature of your withdrawal of consent, Robinsons Malls may no longer be able to continue to provide you with our products and services.

PROTECTING YOUR INFORMATION:

Protecting Information Submitted Online

Robinsons Malls take precautions and place security measures to protect your information and maintain the safety of your personal information. When you submit information via any of our official website(s), social media accounts, digital platforms & mobile applications, such information is protected both online and offline. While reasonable & appropriate physical, technical & organizational measures are in place to safeguard your personal information, we cannot guarantee that the information collected or stored will be protected from all unauthorized access and thereby used in a manner that is inconsistent with this Privacy Policy.

We strictly enforce our Privacy Policy within Robinsons Malls Promo Site and we have implemented technological, organizational and physical security measures to protect your personal data we hold from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:

· We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.

· We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.

· Any personal data that you provide on the website is initially processed and stored by Robinsons Malls Promo Site using a secured connection, only authorized Robinsons Malls Promo Site can then access and download your personal data from the website.

· It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign-off when finished using a shared computer.

While reasonable & appropriate physical, technical & organizational measures are in place to safeguard your personal information, we cannot guarantee that the information collected or stored will be protected from all unauthorized access and thereby used in a manner that is inconsistent with this Privacy Policy.

MINIMUM AGE:

Robinsons Malls will only collect or use personal information from anyone age 18 years old and above. If you are seventeen (17) years old and below, you should secure the consent of your parents or legal guardians.

THIRD PARTY WEBSITES:

Our websites may contain hyperlinks and details of third party websites. From time to time, we will provide links to third-party websites or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal information to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should also review. Robinsons Malls’ Privacy Policy does not apply to such other sites or to the use that those entities make of your information. Robinsons Malls has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information. We therefore advise you to study their privacy policy. Once you leave our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information collected from you.

COOKIES AND SIMILAR TECHNOLOGIES:

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. Data generated is not shared randomly with any other party but only to those that Robinsons Malls deem it necessary at its sole discretion in order to benefit you and improve your browsing experience. We only use this information for statistical analysis purposes, after which the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. We may use your browsing behavior to develop promotional offers, products, and services that we feel are beneficial to you.

Most web browsers automatically accept cookies, but you can modify your browser to refuse or delete cookies. If you disable all cookies, you may not be able to take advantage of all the features of this website.

For you to fully enjoy your visit and browsing experience, only non-identifiable web traffic data are collected and analyzed, including:

- Your IP address;

- The search terms you used;

- The pages and internal links accessed on our site;

- The date and time you visited the site;

- Geolocation;

- The referring site or platform (if any) through which you clicked through Robinsons Malls Promo Site;

-Your operating system, and browser type.

Use the options in your web browser if you do not wish to receive (a) cookie(s) or if you wish to set your browser to notify when you receive (a) cookie(s). If you disable all cookies, you may not be able to take advantage of all the features of this website/mobile application.

Most mobile devices provide users with the ability to disable permissions (e.g., location services). Most likely, these controls are located in the device’s settings menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or your device manufacturer.

UPDATES TO THE PRIVACY POLICY:

Robinsons Malls may update this Privacy Policy to apply changes due to new laws and regulations affecting the Data Privacy Act or amendments thereto, changes in our business operations and environment. Any updates or changes will be posted on our official website.

HOW TO CONTACT US:

For any comments, questions, complaints or requests relating to this Privacy Policy, you may get in touch with:

Data Protection Office Email: dpo@robinsonsland.com

Telephone: (632) 397-1888 local 31185

Mobile: +639988403172