ZAPPP understands the importance and sensitivity of your personal data, hence, we are committed to protect your personal data and sensitive medical information.  Our Privacy Policy ensures that all appropriate standards for personal data privacy and protection are compliant with Republic Act No. 10173 or the Data Privacy Act of 2012 (“DPA”) and its Implementing Rules and Regulations. This policy embodies how we may collect, use and disclose your personal data or sensitive information as well as your rights as owners of this personal data. The entire ZAPPP work force and other affiliated health care providers including organizations controlled, owned and affiliated with ZAPPP are committed to follow this Privacy Policy.

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Scope

This Data Privacy Policy applies to Personal Information we collect on the website, social media accounts, ZAPPP applications and point of contact listed below (collectively the “Sites”):

• Website: www.zappp.ph

• Facebook: www.facebook.com/zappp.ph

• Twitter: twitter.com/zappp_ph

• Instagram: instagram.com/zappp.ph

• Tiktok: https://www.tiktok.com/@zappp.ph

• Zappp email: hello@zappp.ph

• Customer Feedback

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Personal Information We May Collect

Prior to, and while providing our services, we may ask you to provide us with certain Personal Data, Sensitive Information and Financial Details. These Personal Data may include, but are not limited to, information which may be used for the following:

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• Basic personal information, such as, Full Name, Nickname, Home/Shipping addresses, Email Address, employment information, telephone or other personal contact numbers for identification purposes, billing and receipt of payment for services rendered.

• Sensitive personal information, such as, Age, Nationality, marital status, gender, and health or your medical background (for the purposes of diagnosis or treatment of your skin or aesthetic condition, for quality improvement and coordination of care, training, research).

• Financial details, such as, Bank Account, credit card, and debit card information you have provided as a result of our transaction.

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You are responsible for ensuring that all data, whether personal information, sensitive personal information or privileged information, you submit to ZAPPP are accurate, complete and up-to-date.

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Personal Data Sharing Policy

As a general rule, we are not allowed to share your personal data to third party except in limited circumstances as listed below.By giving your consent, you authorize ZAPPP to disclose your personal data to accredited, affiliated third parties or independent/non-affiliated third parties in any of the following circumstances:

• As necessary for the proper execution of processes related to the purposes declared in this Privacy Policy.

• The use or disclosure is reasonably necessary, required or authorized by and under law (such as for criminal investigation, as requested by the court of law).

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This means we might provide your personal data to the following:

• Our affiliates, subsidiaries, partner companies, organizations or agencies including their subcontractors or prospective business partners that act as our service providers and contractors;

• Law enforcement and government agencies;

• All third parties, with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

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However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.  In such cases, we ensure that your Personal Data or Medical Information are disclosed with strict adherence to the principles of data privacy and confidentiality.

Collection of Personal Data

Your Personal Data may be obtained in various ways such as interviews for application and medical assessment, correspondence by telephone and facsimile, by email, via our website zappp.ph and from third parties.

However, most of the personal data we obtain are those that you have given to us yourself. You provide us personal data when you:

• Avail of, or apply for, our services by filling out application forms or other information forms through any of our available channels (e.g., online, upon admission, or through our medical personnel and representatives);

• Get in touch with us to inquire about our products and services, file a complaint, or request for service;

• Take part in our research and surveys

• When you apply for job with us.

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Purposes of Data Collection

The following are our purpose/s for collecting your personal data:

• To process your booking and other incidental request;

• To contact you about your booking and other arrangements;

• To process your payment and/or refund;

• To personalize your ZAPPP experience or provide services tailored to your requirements;

• To ensure the safety and security of all the patients, including investigating security and screening issues;

• To facilitate your participation in all ZAPPP programs and promotions;

• To conduct marketing activities including sending out of email and SMS, for our products and services and to conduct market and other research to improve our products, services and marketing activities;

• To process remediation and other applicable legal remedies (internal and external) inclusive of endorsement of your account to external legal counsel; and

• To update our records and keep your contact details and billing address up to date to allow us to communicate with you in case of emergencies, sending out advisories and inform you of programs and activities of ZAPPP

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Security

ZAPPP warrants that appropriate technical, organizational and physical security measures are in place for the protection of your Personal Data or Medical Information against unauthorized access, use, alteration, and disclosure.

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Data Retention Policy

When your Personal Data or Medical information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy, permanently de-identify or anonymize it. However, most of the Personal Data or Medical Information will be stored in files which we will keep for up to Ten (10) years.

Accessing Your Personal Data

You may access your Personal Data or Medical Information to update and/or correct it, subject to certain exceptions as provided by law. If you wish to do so, please inform us in writing.

We will not charge any fee for your access request, but we may charge a reasonable administrative fee for providing a copy of your Personal Data.

In order to protect your Personal Data, we may require some form of identification from you before releasing the requested information.

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Know Your Rights

• You have the right to be informed that your personal data will be, are being, or were, collected and processed.

• You have a right to access or obtain from an organization a copy of any information relating to you that they have on their computer database and/or manual filing system. It should be provided in an easy-to-access format, accompanied with a full explanation executed in plain language.

• You have the right to object to the collection and processing of personal information that was unlawfully obtained without your consent.

• You have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data under circumstances provided by law.

• You may claim compensation if you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data.

• You have a right to file a complaint with the National Privacy Commission f you feel that your personal information has been misused, maliciously disclosed, improperly disposed, or that any of your data privacy rights have been violated.

• You have the right to dispute and have corrected any inaccuracy or error in the data a personal information controller (PIC) hold about you.

• You have the right to data portability which allows you to obtain and electronically move, copy or transfer your data in a secure manner, for further use.

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Complaints and Procedure

If you wish to access, update your Personal Data / Medical Information or if you have queries, complaints, suggestions regarding about our Privacy Statement /Privacy Policy, you may reach us through the following contact details :

Address to: Data Protection Officer

Mail to Address: 7F Citibank Center, Paseo De Roxas, Salcedo Village, Bel-Air, Makati City

Telephone: +632 8539-5901 loc 8120

E-mail: dpo@zappp.ph

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To assist ZAPPP in dealing with a customer complaint, the customer must provide the following information:

• Full name

• Contact details

• A clear copy of your 2 valid Identification

• Name of officer, employee (and his/her division) who collected your personal data

• Details of Complaint

• Time frame over which the suspected wrongdoing occurred

• Documentary evidence in support of the complaint

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Upon receiving your complaint, ZAPPP's respective Data Protection Officer and/or Compliance Officer for Privacy shall confirm that the complaint shall be investigated and provide an estimated time of how long you should expect to wait to receive a full response.

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While ZAPPP endeavors to respond as promptly as possible, response time will vary depending on the nature of the complaint.

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The Data Protection Officer and/or the Compliance Officer for Privacy shall liaise with the relevant departments to investigate any complaint and shall notify the complainant of the result of the investigation and/or action/s taken as part of the complaint in writing within a reasonable period of time.

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Changes to this Privacy Statement and Privacy Policy

From time to time, we may change or update our privacy statement, policies, and practices to comply with government and regulatory requirements, to adapt to new technologies and protocols, to align with industry practices, or for other legitimate.