INTRODUCTION
The World’s Finest Liquor Inc. (“TWFLI”) is engaged in, among others, the business of retail of distilled spirits and other alcoholic beverages. It is wholly-owned by Emperador Distillers, Inc. (“EDI”), the Philippines’ largest liquor company and the world’s largest brandy producer.
TWFLI, respect your privacy and recognize your need for appropriate protection and management of your personal data that you have directly and voluntarily entrusted us. We have developed this Privacy Policy in order to protect your personal data in accordance with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (“NPC”) and other relevant laws of the Philippines.
Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to “any information, whether recorded in a material from 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”.
This Privacy Policy tells you how we process (meaning, how we collect, use, share, and retain) and protect your personal data. It also tells you what steps you can take if you want us to change how we use your personal data, or if you want us to stop using your personal data.
Why do we collect your personal data?
To enable us to comply with our corporate policies with respect to our customers, as well as with regulatory requirements being observed by TWFLI, it is important that TWFLI collects, uses, stores and retains your personal data when it is reasonable and necessary for a declared and specific purpose.
In general, we are using your data for any of the following purposes:
- To provide information about our products and services which may be of interest to you;
- To perform functions necessary to deliver the services, goods and other products offered by TWFLI;
- To provide customer care activities, monitor our quality and security, and provide services timely and efficiently;
- To respond to specific complaints, enquiries, requests or manage future interactive user function it may be necessary to ask for personal information;
- To comply with legal and regulatory requirements or obligations;
- When visiting any of our retail stores, brandy museum, whisky parks, and other locations, to provide safe and secure environment for store visitors, customers and employees; and,
- To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction;
- To perform such other processing or disclosure that may be required under law or regulations; and
- To generate statistical insights.
Other uses by nature of our transactions
In addition to the general uses mentioned above, we may use your personal information to process your transactions with us, in any of the following situations:
- When you want to become a part of TWFLI:
- To document the commencement of your employment with TWFLI;
- To comply with our obligations under law and as required by Government Agencies such as DOLE, BIR, HDMF, PhilHealth, and SSS;
- To inform and consider you for future job opportunities that may be of interest to you;
- To provide services to clients for which you are involved or endorsed as team member/practitioner;
- To engage independent contractors for the company;
- For information processing such as payroll, benefits application, and tax processing of the company’s Finance and Accounting;
- For generation of stockholder;
- For performance evaluation and career development of the employees including training and compliance monitoring;
- For demographics and data analytics; and,
- For marketing and sales initiatives such as TWFLI publications, events, and business programs and projects.
- When you are a vendor, a potential vendor, or a contractor:
- To conduct due diligence check prior to accreditation of suppliers;
- To evaluate feasibility of your proposal whether it is congruent with TWFLI;
- To serve as a reference for crediting accounts of accredited suppliers; and,
- To perform any other action as may be necessary to implement the terms and conditions of our contract.
- When you are a distributor, or customer:
- To evaluate and reward customers that meet the qualifications for accreditation;
- To monitor the activities of the customers in order to maintain accredited status with TWFLI;
- To serve as a reference and to process billings of customers;
- To serve as a source for analysis in granting credit limit; and,
- To perform any other action as may be necessary to implement the terms and conditions of our contract.
- When you are a participant in the marketing initiatives of TWFLI:
- 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;
- During events, we may obtain your personal information or take a picture of attendees which may be used for documentation and reporting for internal purposes. Also, we may use these pictures for our promotional activities and advertisements in social media pages and websites. We assure you that we treat all of our customers’ information confidential and we will prevent any unauthorized disclosure of it by our employees or any third party; and,
- To implement various marketing initiatives to promote our products and to provide incentives to our loyal customers.
- When you visit any retail shops, Whisky Park/s, Brandy Museum, dining/drinking places, lounges, and other locations of TWFLI:
- To fulfill your orders and transactions by providing goods and/or services;
- To provide a venue for your events, gatherings, meetings, and other drinking occasions;
- With respect to the CCTV cameras installations in these locations, then (i) to provide a safe and secure environment for everyone; (ii) to deter crime and anti-social behavior;
(iii) to assist in the detection, investigation and prosecution of offenses; and
(iv) to protect our property.
- When you interact with us through our “Planning an Event?” form:
- To process inquiries and requests received via the Whisky Park website;
- To share and forward relevant inquiries and requests to its affiliate, Megaworld Corporation (“MEG”), to properly address concerns involving events planning and coordination at the Whisky Park; and
- To solicit feedback for the services we provide.
What type of personal data we collect?
The common type of data collected by TWFLI from you, generally includes the following:
- Basic personal information such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
- Sensitive personal information such as age, nationality, marital status, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security number;
- Employment record such as educational background, employment history, certifications, trainings attended, resume and income information of your previous jobs;
- Financial details such as credit history, bank account, credit card, and debit card information you have provided as a result of our transaction; and
- Images recorded by our CCTV system cameras.
Please note that you are responsible for ensuring that all such personal data you submit to TWFLI is accurate, complete and up-to-date. Similarly, when you provide information other than your own, you attest that you have obtained the consent and authority of the owner of such information (such as your parents, spouse, children, dependent, or any other person) to allow us to process and/or disclose such information in accordance with our policy.
How we collect, acquire or generate your data?
We collect data when you:
- Visit our retail stores, brandy museum, whisky parks, and other locations;
- Place orders and avail any of our products and/or services;
- Book an event in any of our locations;
- Attend any of our events;
- Submit a job application;
- Submit a proposal and related business documents;
- Fill-out our forms and submit necessary documents;
- Submit information through any form on our digital platforms or contact us through any of our social media accounts;
- Purchase or avail of any of our products and promos;
- Respond to surveys, promotions, and other marketing and sales initiatives;
- Provide personal information in relation to inquiries, requests, and complaints;
- Disclose your personal information through phone calls, emails, SMSs or verbal communication with our authorized representatives.
Is https://whiskypark.com.ph/ using web analytics?
Our website does not use cookies. Thus, we do not retain any information based from your visits on our website.
What about the links to third-party websites?
We do not provide any personal data to third party websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. TWFLI’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. TWFLI 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.
Who we share your personal data with?
As a general rule, we do not share your data to third party except in limited circumstances as noted below:
By giving your consent, you authorize TWFLI to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:
- As necessary for the proper execution of processes related to the declared purposes in this Privacy Policy.
- The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).
This means we might provide your personal data to the following:
- Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors 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.
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.
What is our Privacy Policy regarding children?
As an alcoholic beverage retailer, we do not transact with children. TWFLI would never collect personal data from children.
We urge parents to be vigilant in regularly monitoring and supervising their children’s on-line activities.
How we protect your personal data?
We take reasonable steps to make sure that your personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce our Privacy Policy within TWFLI and we have implemented technological, organizational and physical security measures to protect your personal data that 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 https://whiskypark.com.ph/ is initially processed and stored by TWFLI. Using a secured connection, only authorized TWFLI personnel and third-party processor can then access and download your personal data from the system. In case of Event booking at the Whisky Park, personal data may be shared and transferred to relevant department of MEG that handles event planning and coordination. For more information as to how MEG handles your personal data, please visit https://www.megaworldcorp.com/privacy-policy.
- We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
- 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.
Where and how long do we keep your personal data?
In general, the data will be kept in accordance with the following retention standards:
1. If the data subject has an existing contract and transaction with TWFLI, information will be retained all throughout the contract period and 10 years after its completion.
2. If the data subject has no existing contract but has existing transaction with TWFLI, information will be retained during the transaction and 10 years after its fulfillment.
3. If the data subject has no existing contract and transaction with TWFLI, information will be retained for a retention period of 6 years.
Data collected will be retained in accordance with retention limit set by TWFLI standards, industry standards and laws and regulations.
You may wish to withdraw consent by giving us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent (e.g. we may not be able to fulfil our obligations under a contractual agreement or to inform you of our future products or services). Nevertheless, this will not affect the lawfulness of the processing that was carried out before you withdrew your consent or TWFLI’s right to continue parts of the processing based on other legal bases than your consent.
What if there are changes in our Privacy Policy?
From time to time, it may be necessary for TWFLI to change this Privacy Policy. If we change our Privacy Policy, we will post the revised version here and will take effect immediately, so we suggest that you check here periodically for the most up-to-date version of our Privacy Policy. Rest assured, however, that any changes will not be retroactively applied and will not alter how we handle previously collected personal data without obtaining your consent, unless required by law.
How you can access, correct and update the personal data we have about you?
To exercise your rights which include right to access, modify, erase and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or complaints to TWFLI, you may reach us through a written letter or through an email to our Data Protection Officer (DPO).
Our contact details are as follows:
Data Protection Officer
7F 1880 Building
Eastwood City Cyberpark
E. Rodriguez Jr. Avenue
Bagumbayan, Quezon City
Metro Manila Philippines 1110
Office: (02) 709 2222
Email: dpo@twfli.com
For other concerns regarding the full exercise of your rights, you may contact NPC through its website: https://privacy.gov.ph/
Our decisions to provide such access or consider any request for correction, erasure and objection to process your personal data as it appears in our records are always subject to any exceptions under applicable and relevant laws and/or the DPA, its IRR and other issuances of NPC.
