Privacy Policy

Your information is important to Cocolife Asset Management Company, Inc. (“CAMCI”) (collectively referred as “CAMCI”, “we”, “us” or “our”). We believe in the responsible use of information we collect about individuals.

We handle your Personal Data in accordance with Republic Act No. 10173, known as the “Data Privacy Act of 2012” (DPA) and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

CAMCI recognizes the importance of your rights as a Data Subject under the DPA as follows:

1. Right to be informed;
2. Right to object;
3. Right to access;
4. Right to correct;
5. Right to rectification, erasure or blocking;
6. Right to damages; and
7. Right to data portability

This privacy statement provides information on how we collect, use, manage and secure your personal information necessary to serve you better. Any information you provide to us indicates your express consent to the content of our Privacy Policy.

Personal Information Collection

Personal Information, under the DPA, 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.

Vital to our service is the collection of your personal information which may include, but shall not be limited to, the following:

• Name, gender, date of birth, birthplace, address, telephone/mobile number, and email address;
• Occupation, sources of funds, name of employer, nature of business, contact number;
• Nationality or citizenship, civil status, TIN, SSS or GSIS numbers;
• Information based on government issued IDs such as PRC, UMID, driver’s license or passport;
• Specimen signatures;
• Bank Account numbers which may be used to deposit the proceeds of redemption as decided by the investor.

When you provide information other than yours, you certify that you obtained their consent to disclose and process their information, or about another person. You also certify that all personal data you submit is accurate, complete and up to date.

Why do we collect your personal data?

To enable us to perform the processes related to your investment, other products, and services, it is important that CAMCI collects, uses and stores your personal data.

How do we collect your personal data?

CAMCI collects your personal data when you:

• Fill-out the prescribed forms (e.g., Account Opening Form, Signature Card and Purchase Form) in relation to your investment;
• Fill-out an Order form to add or redeem your investment;
• Amend your personal information;
• Communicate with us by responding to our letters, marketing materials or providing feedbacks;
• Visit our website (www.cocolifeasset.com) to register, view your statement of account, answer investor questionnaire for risk profiling or when you send us a message. In that regard, we require you to provide us with your full name, date of birth, e-mail address and contact number. We use cookies to ensure that you have an easier browsing experience, however, you may opt to delete or block cookies from the website, should you wish.

COOKIES and Related Technologies

A cookie is small piece of file that originates from a website. It is transferred to the user’s hard drive to record the user’s browsing activity. These are designed to remember pieces of information when users enter certain websites. Essentially, cookies will help you in browsing our site easier by, among other things, saving your name, addresses, passwords and other references. Most web browsers are set to automatically accept cookies, but you have the option to refuse all cookies or indicate when a cookie is being sent. However, if you choose not to accept cookies, you may experience some delay in browsing our website, it will not function properly or may be considerably slower.

How do we preserve and protect your personal data?

To maintain the integrity and confidentiality of your personal information, we have implemented measures to secure and protect them from theft, loss, penetration or breach. We put in place organizational, physical and technical security measures necessary to protect your personal information, as follows:

• Use of secured servers, firewalls, encryptions and other latest security tools;
• Limited access to personal information to duly authorized processors; and
• Maintaining a secured server operating environment by performing regular security patch update and server hardening.

How do we use and share your personal data?

CAMCI uses the personal data you submit to us, fairly and lawfully, only to:

• Process, administer and approve your investment and other related transactions;
• Arrange the products and services we offer that you availed from us;
• Communicate our latest products, services, promos and events that will enhance your client experience;
• Respond immediately to your needs, requests, queries and complaints;
• Comply with the law and all legal orders and processes;
• Perform the necessary processes in conducting due diligence and documentation; and
• Any other purpose relating to any of the above.

We may share your personal data only to the extent that is reasonable and necessary, to:

• Our officers and staff handling your investment transactions and requests;
• Our affiliates, partners, and other related parties;
• Any third-party service providers performing financial, administrative, technical and other related services;
• Government institution and other competent authorities which by law, rules or regulations requires us to disclose;
• Person or entity that we contractually entered with, that ensures the confidentiality standard we implement and adhere to the DPA;
• Any person that fall within matters of public concern, in order to carry out functions of public authority only to the extent of collection andfurther processing consistent with a constitutionally or statutorily mandated function pertaining to law enforcement, taxation and other regulatory function.

Where and how long do we store your personal data?

Your personal data will be stored in a secured electronic database system and documents or hard copies submitted to us will be kept in locked filing cabinets which are accessible only to authorized officers and staff of the company. We will delete your records from our database system and effect the destruction of hard copies of your files only after five (5) years from the date it was closed or fully redeemed. Once deleted, your personal data will no longer be accessible.

What if there are updates/changes in our Privacy Policy?

CAMCI may periodically update or amend its Privacy Policy in order to adhere to new and existing laws affecting the DPA, including any change or improvement we establish to secure your personal information. If we amend our Privacy Policy, we will post the updated version and date of revision in our website: www.cocolifeasset.com and will take effect immediately. Rest assured, however, that any updates or changes shall not alter how we handle previously collected personal data without obtaining your consent, unless required by law.

Contact us:

For your inquiries or feedbacks on this Privacy Policy and/or complaints, you may contact our Data Protection Officer at:

ATTY. RYAN ANTHONY S. MALIT

8th Floor COCOLIFE Building, 6807 Ayala Avenue, Makati City

Email address: rsmalit@cocolife.com