Privacy Policy
This Privacy policy is created in accordance with the Philippines’ Data Privacy Act of 2012 (“Data Privacy Act”). Our company fully respects and values your data privacy rights, and ensures that all personal data collected from you, including but not limited to, our guests, users, players, employees, suppliers, and partners (“You”, “Your”, “Players”), are processed in accordance with the general principles of transparency, and legitimate purpose, and proportionality.
All personnel of our company, regardless of the type of employment or contractual arrangement, must comply with the Data Privacy Act and other related laws and/or regulations in handling the personal and sensitive information of the Players.
The purpose of this Privacy Policy is to inform You of how the Company collects, processes, uses, stores and protects Your Personal Data as well as the rights You have with respect to the processing of Your Personal Data.
By visiting FBM E-Motion https://www.fbmemotion.ph/ website (“Website” or “FBM E-Motion) and/or using our services, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Website or provide us with your personal information.
If You choose not to provide Your Personal Information it may prevent Us from meeting legal obligations, fulfilling a contract, or performing services required to run Your account. Not providing Your Personal Information may mean We are unable to provide You Our products and services.
DEFINITIONS
“Personal Information” or “Personal Data”– 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.
“Processing” refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
“Services” – the provision of remote online games provided by the Company through the Website.
WHO WE ARE
Memo Multinational Corp, a company organized and existing under the laws of the Philippines, licensed to transact business by the Philippines Security and Exchange Commission, with SEC registration number 2020120004440-13 and its principal address on One Corporate Centre, Julia Vargas Ave. Cor. Meralco Ave. Ortigas Centre- Pasig City, Philippines. (“Company”, “We”, “Us”, “Our” and “FBM E-Motion”) is the data controller of Your personal data and control the ways and the purposes for which Your Personal data is used by the Website, as defined by law, including those that may be sensitive or confidential, as disclosed by You in any activity related to the Company, including registration, participation, and enjoyment of any promos, programs, rewards, and privileges provided by FBM E-Motion.
USE OF INFORMATION
We fully respect Your fundamental rights and consider the protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We respect the following basic principles:
We submit Your Personal Data only to lawful and fair processing, and we maintain complete transparency vis-à-vis the way we handle Your Personal Data.
We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice and We do not process it further in any manner incompatible with these purposes.
We process Your Personal Data only to the extent that it is necessary and appropriate to the purposes for which it is collected.
We make reasonable efforts to ensure that Your Personal Data is accurate and updated, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
In general, we comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.
TYPES OF PERSONAL DATA WE PROCESS
The information and data about You which We may collect, use and process includes the following:
Information that you provide to us by filling in forms on the Website or any other information you submit to us via the website or email;
Records of correspondence, whether via the website, email, telephone or other means;
Your responses to surveys or customer research that we carry out; Details of the transactions you carry out with us, whether via the website, telephone or other means;
Details of Your visits to the Website;
Any other Personal Data directly provided by You during Your interaction with Us.
Certain non-personal information is recorded by the standard operation of FBM E-Motion servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance Your online experience.
From time to time, FBM E-Motion gathers Players’ data via marketing activities such as promos, surveys, registration forms, downloads, etc. Participation in these activities happens on a voluntary basis, willingly – which allows the Players to decide whether to disclose any personal data. Such data may include contact information (e.g. name, email, phone number), demographic information (e.g. date of birth), or others. The data will be used to provide everyone with the service requested and to improve our services and may be used for marketing and promotional purposes by FBM E-Motion and its subsidiaries and may be shared with our promotional partners. Personal information is never sold or leased to any third parties.
The Player may choose to provide additional non-mandatory information that enables Us to provide more personalized service.
We may use Your contact information to send You information about Our companies and what we’re doing.
PURPOSES AND LEGAL BASIS FOR DATA PROCESSING
The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:
Administration and development of the Website and the Services;
Enhancement of user experience, including the provision of personalized
Services and improvement of the Website and the Services;
Development of new products, utilities and offerings;
Communicating with You in case You contact the Company or in case We need to provide You with important information or request Your feedback;
and Verifying compliance with the Terms and Conditions of the Website.
The Company may process Your Personal Data only with Your lawful consent for the following purposes:
Commercial communication, marketing, and advertising of Our Services. You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Privacy Policy. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your data prior to its revocation.
The Company may process Your Personal Data based on its legitimate interest for the following purpose:
Defending the Company against any legal claims.
DATA RECIPIENTS
For the execution of the purposes mentioned in this Privacy Policy, We may provide access or transmit Your Personal Data to the following recipients (“Data Processors”):
Law enforcement agencies, regulators, and other authorities;
Credit reference companies; Fraud prevention companies;
Identity verification companies;
Third parties You ask Us (or permit us) to share Your data with;
And Third parties necessary to provide products or services which you have requested.
Our internet and data hosting providers for hosting purposes; and third-party providers, such as external services providers and/or employees or service providers of related companies, for the smooth operation of the Website and Our information and communication systems.
The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.
All employees and personnel of the company shall maintain the confidentiality and secrecy of all personal data that come to their knowledge and possession, even after resignation, termination of contract, or other contractual relations. Personal data under the custody of the company shall be disclosed only pursuant to a lawful purpose, and to authorized recipients of such data.
Under conditions as allowed/permitted by law, FBM E-Motion may disclose user information in special cases when We have reasons to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone/ any organization who/ that may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other FBM E-Motion site users, or anyone else that could be harmed by such activities.
Lest otherwise provided herein, any other communications or materials You transmit to the Company’s site by electronic mail or otherwise will be treated as non-confidential and non-proprietary. Anything You transmit or post may be used by FBM E-Motion or its affiliates for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, FBM E-Motion is free to use any ideas, concepts, know-how, or techniques contained in any communication You send to the Company’s site for any purpose whatsoever including, but not limited to, developing manufacturing, and marketing of products/ services using such information.
In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities and in any other case that We are legally bound to do so, the Company may transfer Your Personal Data to public authorities to the extent specified by law.
SECURITY AND CONFIDENTIALITY
In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorized or accidental access, processing, deletion, alteration, or other use, the Company applies internal policies and takes all appropriate organizational, technical, and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs, and the nature, scope, context, and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.
Your Personal Data is processed solely by authorized personnel of the Company, bound by strict obligations of confidentiality.
DATA RETENTION
We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Privacy Policy.
Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes based on Our legitimate interest to defend the Company against any potential legal claims, before any competent court or public authority. After the period of retention, Your Personal Data is erased from Our databases and systems.
YOUR RIGHTS
We will assist You if You choose to exercise any of Your rights over Your Personal Data, including:
Withdrawing Your consent in any situation where We have asked for it, though this will not invalidate any previous processing from when We had Your consent;
Access to Your Personal Data that We hold or process;
Rectification of any inaccuracies or any missing Personal Data of Yours;
Erasure of any Personal Data that We process;
Restrict processing of Your Personal Data in cases explicitly provided for by law;
The ability to object to any processing data where We are doing it for Our legitimate interests;
The ability to contest a decision made entirely by automated processing, to express Your point of view and to request that a human review the decision.
For any requests relevant to these rights You can contact: [csupport@fbmemotion.ph].
YOUR OBLIGATIONS
By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate, and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.
If You are found to be in breach of Your obligations or if We have reasonable suspicion that the information You provide is false or incomplete or in any way contrary to applicable law or this Privacy Policy, We retain the right to take appropriate legal measures.
USE OF COOKIES
Our Website uses cookies. To find out more about how We use cookies in Our Cookie Policy.
CONTACT AND UNSUBSCRIBE
If You have any concerns or doubts, You can contact Us using: [csupport@fbmemotion.ph].
Players who wish to no longer receive Our promotional emails may withdraw their given consent and opt-out by clicking the unsubscribe link provided in every electronic message sent by Us.
CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy from time to time, so please review it frequently.
We will not enforce material changes to the Privacy Policy without Your express consent. If You decline to accept the changes to the Privacy Policy, or otherwise do not accept the changes within the time period, we may not be able to continue to provide some or all products and services.
