Please read this Policy carefully before using the Summit Sites. By clicking “I AGREE” at the end of this Policy, you signify that you have read and understood, and agree to our collection, storage, use and disclosure of your information, as applicable, as described in this Policy.
WHO WE ARE
Summit Media is incorporated in the Philippines. We are responsible for personal information collected directly through a Summit Site in accordance with this Policy.
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU AND WHERE IT COMES FROM
We collect information, including your personal information, to provide our services on and operate our Summit Sites. We also use the information we collect to provide better services to you. Depending on how you use our services and how you manage your privacy controls, Summit Media may collect and use your information as follows:
Personal Information you provide to us through direct interactions with the Summit Sites
You may provide us with your personal information, such as information that may identify you, when you create an account or register on any of the Summit Sites, participate in a promo or a contest or in any of our community forums, complete a survey, make a purchase, participate in any of our social networking features, subscribe to any of our magazines, to receive newsletters, promotional correspondence, or other electronic services, or send us an e-mail or feedback through any of the Summit Sites.
Depending on the choices you make when registering for, or during the process of using our services on the Summit Sites, you may be asked for and opt to provide the following personal information:
- Name, age, gender, marital status;
- Address, geographical location;
- Phone number, mobile number, e-mail address;
- Profile picture;
- User ID/ Username, password;
- Occupation, education, school;
- Social media account details (i.e., Facebook, Google, Instagram, Twitter); and
- Any other information you choose to provide in connection with your account or use of our services.
Information we collect from you automatically when you use the Summit Sites
When you interact with our Summit Sites and/or use our services through any device, platform, or program, we automatically collect the following information about you:
We never place information that may personally identify you on Cookies. Security measures have been employed on the Summit Sites to prevent unauthorized access to such information. Most web/mobile browsers are set to accept Cookies by default. You can choose to set your browser to remove or reject Cookies. However, if you choose to remove or reject Cookies, this could affect the availability and functionality of the Summit Sites which could prevent you from taking full advantage of our services or site features.
IP Address and Other Device Identifiers. Your Internet Protocol (“IP”) address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your university. Our server may also record the referring page that linked you to us (e.g., another website or search engine); the pages you visit on the Summit Sites, the places/sources/websites you visit after this Summit Site; the ads you see; the ads you click on; other information about the type of web browser, computer operating system, device, platform, related software and settings you are using; any search terms you have entered on this Summit Site or a referral site/platform; and other web usage activity and data logged by our web servers. We may use your IP address to help diagnose problems with our servers, gather broad demographic information, analyze trends among our users to help us improve and administer the Summit Sites. We may also link this information with information that you provide us when necessary to enforce compliance with our rules and policies or terms of service or to protect our Summit Sites, customers or others.
Location Information. Depending on your device/s permissions, we may collect and process your information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile browsers. This information may be used to serve personalized content and recommendations, gather broad demographic information, and analyze trends to improve our services or site features.
Information we collect from your Posts, Comments, Uploads
When you post/upload your own material/content (i.e., photos, videos, documents, comments, etc.) to any of the Summit Sites, including the community forums, and/or participate in any of our social networking features or any other feature that may be offered in the Summit Sites, we may collect such materials and information therein. Your posts/comments/uploads and any information therein may be publicly available for others to view.
Information from third party sources
We may receive information about you from other online and/or offline sources which may be combined with other information about you. For example, we may obtain data from:
Operators of third-party sites or apps, content distribution channels and platforms, or other devices and technologies when you interact with our content, products, services or ads available on those channels and platforms. The information we receive may include information about the content you view or access as well as your demographic information and information about your interests.
Third-party data suppliers such as data aggregators, data resellers, public databases and business partners. They may provide us with demographic information, information about your purchases on the Summits Sites, and other information that help us learn about you and other users of the Summit Sites.
PURPOSES FOR COLLECTING YOUR PERSONAL INFORMATION
We will only use your personal information as set out in this Policy. We have set out below a description of the ways we use your personal information (the “Purposes”). We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
To provide access and deliver our services to you through the Summit Sites
We use your information to provide you access to the Summit Sites. If you register an account on the Summit Sites, we may use your user ID or e-mail address to identify you as a user and provide you access to the relevant Summit Sites and services. If you log-in using your Google or Facebook profile, we may use your information in such profiles to identify you as a user on the Summit Sites and provide you access therein.
We may also use your information for processing your requests on the Summit Sites and your subscriptions, the products or services you purchase/avail of, or your participation in a survey, forum, contest, promotion, event or similar activities through the Summit Sites. If you subscribe to any of our services, we may use your e-mail address to send you a confirmation notice about the subscription. Similarly, if you enter a promo or a contest, we may use any information collected in accordance with the promo or contest mechanics and for notifying you if you are the winner. If you purchase any digital or physical products, we will use your email and/or mailing address to deliver the products you purchased. Depending on your setting/notification preferences, we may also send out e-mails to users and promo/contest participants to announce/send special offers, services, newsletters and other announcements from any of the Summit Sites, our partners and/or our advertisers that may be relevant or of interest to you. Subject to your consent, we may also register you as a member in any relevant programs when you submit your relevant information for purposes of joining the activities mentioned above.
To customize and improve your experience on the Summit Sites
We may also use your information to:
Collate your data to create a unified profile for you by matching relevant IDs for other visits made on different browsers, devices, or touchpoints and combining other online or offline data sources using these matched IDs to better understand your preferences;
Send you, via relevant forms of electronic communication, administrative notifications and responses to your inquiries;
Offer you tailored content, such as giving you relevant search results, content recommendations, targeted emails, native ad content, or notifications, and the like, when using the Summit Sites;
Determine how much time you spend on our Summit Sites and the manner you navigate the Summit Sites to understand your interests and to improve our services based on this data. For example, we may provide you suggestions on content that you can visit based on the items you have clicked on the Summit Sites;
Monitor and report effectiveness of the campaign/project delivery to our business partners and for internal business analysis;
Prevent repeatedly displaying same items to the same user;
Compile anonymous and aggregated information using information about the Summit Sites users that do not identify you and the other users for business analysis of consumer/client behavior;
Measure and monitor interaction with third-party advertisements placed on the Summit Sites.
To customize and improve the Summit Sites
Data Aggregation for Marketing Purposes. We may combine and use any and all information on you that we collect either from online or otherwise, including from third parties, for the purpose of marketing and delivering targeted ads and communications from us or our partner advertisers. In such cases, we create anonymous information from your personal information by excluding, masking, or transforming information (such as your name) that make the data personally identifiable to you (“Anonymous Information”). We may deliver communications such as emails or push notifications to you but as an aggregated group as a whole, which ensures that your specific contact information is not exposed to our partners. We may aggregate such Anonymous Information of Summit Sites users to develop and improve the products, services, and activities on the Summit Sites.
For Editorial Purposes. We may use information you provide us through emails, questions and answers, community forums, in response to polls, or through any other user-generated submission for editorial purposes, and may use your name and any stories you provide us in articles published online and in our magazines. By providing us with your personal anecdotes, you agree and consent that these may be attributed to you. You also agree and permit Summit Media to edit, rewrite, use, and reuse the content, including your name, likeness, photograph, and biographical information that you provide us, with or without attribution, including publication in the magazines, and in trade media, and advertising.
To provide you a safe and secure platform to access our services through the Summit Sites
We use the information you provide to provide you a safe and secure platform to access the Summit Sites services and features. We use your e-mail address and unique device identifiers to administer and protect the Summit Sites (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and hosting of data). If you provide us with your telephone number, we may use that information to SMS verify your telephone number in relation to your account and/or purchase and increase the trust and safety of the Summit Sites.
PROCESSING OR SHARING YOUR PERSONAL INFORMATION
We may share your personal information with the following parties for the Purposes stated above:
Summit Media Affiliates: We may share your data with our corporate affiliates (“Affiliates”) to analyze data for different Purposes and to improve our services. “Affiliate” means any entity that controls, is controlled by or is under common control with us, where “control” means ownership of more than 50% of an entity’s equity share or the ability to appoint a majority of its board of directors.
Third Party Vendors and Service Providers: We process and/or share your data with third party vendors and other service providers that help us deliver certain aspects of our Services such as in the following situations:
To provide products, services or functions on our behalf in accordance with your indicated preferences (e.g., to send you emails regarding your activities on the Summit Sites; processing payments for your purchases; fulfilling subscriptions you subscribed to; or delivering your purchases);
To process your orders and purchases made through the Summit Sites, we use third party service providers or SAAS / PAAS (Software as a Service / Platform as a Service) for e-commerce, payment processing, or order fulfillment;
When you have furnished us information that may identify you with the intent that it be forwarded to a third party for use in connection with a specified service you are electing to participate in (e.g., participation in activities with our e-commerce partners; signing up for services with our partners; services to help old friends locate you online; your agreement to receive promotional materials directly from a third party partner, etc.)
Our third party service providers are contractually obligated to comply with applicable data privacy laws and regulations and to agree to maintain the confidentiality of your personal information and not to use such information for any reason except to carry out the purpose(s) for which we engaged them. (“Service Provider Exception”). We do not permit third parties to collect your identifiable information from the Summit Sites unless you provide it to them directly.
3P-Partners.Some of the Summit Sites may from time to time partner with a retailer or other third party to offer online shopping opportunities, games, services, subscriptions, and other applications on a co-branded or cross-promotional basis. These transactions may take place on a Summit Site, or the site of the third party. In either case, personally identifiable information (or information that may identify you) that you provide in connection with the transaction or use for the service may be collected directly by, or shared by Summit Media with, the third party, as well as with any participating sponsor or advertisers of such opportunities and features.
Some of the Summit Sites may offer you the ability to access a third-party site with whom we have a relationship to access both sites through a co-branded registration process; in that event, your applicable registration information may be collected directly by, or shared by Summit Media with, the third party partner.
We require our 3P Partners to contractually agree that they will not use or disclose your personal information for any other purposes than necessary to perform their obligations in relation to our partnership, or to comply with applicable laws. Although we require our 3P Partners to protect the confidentiality and security of your personal information that we share with them, our 3P Partners will use your information in accordance with their own privacy policies. Any information that our 3P partners may collect and share with us shall also be in accordance with their own privacy policies. Please also check our 3P partners’ respective privacy policies before registering or participating in any of our collaborations with them.
Analytics Providers: In order to improve our Services, we will sometimes share your non-identifiable information with analytics providers that help us analyze how people are using our Services. For example, we use common industry-wide analytics software to understand how people use the Summit Sites so we can improve our services and increase user engagement.
Deliver Advertising and Other Content: We may partner with demand-side platforms that buy our ad placements through auctions. We share your information with them in a de-identified and aggregated form to enable the demand partners to analyze, identify, deliver, and display video advertisements that may be relevant to you. We may also share or permit third-party digital advertising companies and other third party service providers, to collect non-identifiable information about your use of our service over time so that they may play or display ads that may be relevant to your interests on the Summit Sites.
We do not permit third parties to collect your identifiable information from the Summit Sites unless you provide it to them directly and/or you provide consent thereto. The information we share is provided through Cookies or similar tracking technologies. This information is used to display targeted ads on or through the Summit Sites or on other websites or apps. Depending on your browser or electronic device, you may be able set your browser to delete, notify you of and reject cookies and other tracking technology by actively managing the settings on your browser or electronic device.
You can opt-out of receiving targeted advertising from third party online advertising companies which are members of the Network Advertisers Initiative by going to www.networkadvertising.org. In addition, the Digital Advertising Alliance (“DAA”) maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the DAA program (www.AboutAds.info/choices)
Business Transfer or Reorganization:We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner consistent with and assume the rights and obligations in relation thereto in accordance with this Policy (“Acquisition Exception”). After such a sale or transfer, you may contact the recipient with any inquiries concerning the recipient’s privacy practices.
Publicly available information:When you use certain aspects of our Summit Sites services, the information you provide may be visible to other Summit Sites users (i.e., a posted item/content, your response to a fellow user in the case of a chat message, your response to a post on a Summit Site’s public feed, or any information you post in the comments section of the Summit Sites, among others). This includes any information you post or chat, such as your name, your e-mail address, your location and your contact number, as well as any profile picture you upload, if any. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.
With Your Consent or Otherwise at Your Direction.In addition, we may share your information with third parties when you consent to or request such sharing (“Consumer Directed Exception”).
LINKS TO THIRD PARTY WEBSITES
Summit Sites may contain links to websites operated by third parties. This Policy does not apply to such third party websites or services or other websites which do not link to or post this Policy. If you follow a link to any of these third party websites, please note that these websites have their own privacy policies. As such, you agree and understand that we do not have any responsibility on or liability for your access of such third party links and for their respective policies. It is your sole responsibility to check the security of the third party links you access and review their applicable privacy policies.
We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We also require you to enter a password to access your registration information. Please do not disclose your registration password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, you acknowledge and agree that while Summit Media uses reasonable efforts to protect your personal information, Summit Media cannot guarantee its absolute security.
COMMUNICATION AND MARKETING
We may communicate with you by email, in-app notifications, push notifications from the Summit Sites, SMS text messaging, and/or other forms of electronic communication in connection with your use of the Summit Sites services to confirm your registration, to update you regarding your product purchases, and for other transactional messages in relation to our services.
We (or our service providers or advertising partners) may send you direct marketing communications and information about our services that we consider may be of interest to you. We will provide an option to unsubscribe or opt out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contact Us” section below.
If you opt out of receiving marketing or commercial communications, we retain the right to send you non-marketing communications such as correspondence about your relationship with us, information about transactions, or notifying you of updates to this Policy. Please note that we also carry out digital advertising campaigns from time to time that do not rely on your personal information.
OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
The applicable legal basis for which we process your Personal Data for the specific Purposes listed above, include the following:
Based on your consent: For the Purposes above and in accordance with this Policy, we will ask you for your consent to collect and process your personal information. By clicking “I AGREE” at the end of this Policy, you signify your consent. If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described in the “Contact Us” section below. Please note that if you withdraw your consent it will not affect any processing of your personal information that has already occurred based on your prior consent.
Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your personal information to comply with a relevant law/regulation or to fulfill our obligations under a contract to which you are subject. Where we process your personal information to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information in accordance with the applicable law unless it would impede our legal obligations. Where we are processing to fulfill our contract obligations under a contract where you are a party, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
Our legitimate interest: We may process your personal information based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services, scientific research, and education opportunities. In addition to the other rights you may have, described below, you have the right to object to such processing of your personal information. You can register your objection by contacting us as described in the “Contact Us” section below.
YOUR RIGHTS AS THE DATA SUBJECT
Summit Media is committed to protecting and respecting your personal data privacy in accordance with the Philippine Data Privacy Act of 2012 and other applicable laws, rules and regulations. Under the Philippine Data Privacy Act, you have the right to: (1) access; (2) make corrections on; (3) object to the processing of; (4) erasure or blocking of; (5) be informed of the existence of processing of, your personal information; (6) right to data portability; (7) right to damages from violation of data privacy; and (8) right to lodge a complaint before the National Privacy Commission.
If you wish to exercise your right to access, correction, cancellation, portability and objection rights as described below, or for complaints and other inquiries, please contact us as described in the “Contact Us” section at the end of this Policy:
to receive details of the source of the data, the purposes and methods of the processing, the logic applied to the processing, or if the latter is carried out with the help of electronic means, of the identity of data controller and data processors, the entities or categories of entity to which the data may be communicated and which may become aware of the data;
to update, correct, supplement, or delete the data, to block or render anonymous data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which such data have been collected or subsequently processed; to have a certification that the operations requested have been completed, as also related to their contents, to the entities to which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; to receive the personal data concerning you and copy or transmit it to another data controller (right to data portability); and
to object, on legitimate grounds, to the processing of data, despite the data being relevant to the purposes for which they were collected or to object, also partially (e.g., only in relation to certain communication means), to the data being processed in order to send advertising materials or for direct sales, or market research, or commercial information, profiling purposes, or to receive communications by traditional means only.
RIGHT TO OPT-OUT
Email Policy. We and our affiliates and partners fully comply with national laws regarding SPAM. If you wish to opt out our e-mail services, you may do so by following the unsubscribe instructions in the e-mail you received. We agree that we will not sell, rent, or trade your e-mail address to any unaffiliated third party partners without your permission.
User Registration. You may elect to change the details of your user registration at any time by logging in and editing your User Profile. If you wish to cancel or delete your User Registration, you may contact us at [email protected]. Please take note that when we delete any information, it will be deleted from the active database, but may be retained in our archives. We may retain your information for investigation of fraud or similar lawful purposes.
If you have opted-out as described above, and thereafter you provide your personal information when you elect to use a service or promotion that requires us to contact you or share your information with a third party (e.g., you enter a promo or a contest), then your previous opt-out preferences will not apply to such service. Despite your indicated preferences, we may send you service-related communications, including notices about your subscription, and we may continue disclosing your information to third parties under the Service Provider Exception, Legal Exception, and Acquisition Exception described above.
RETENTION OF YOUR PERSONAL INFORMATION
We will retain your personal information for the duration of your activities and transactions in connection with the products and services you availed of in the Summit Sites and/or for such period of time required for legal and regulatory purposes, and will be disposed of in a secure manner that would prevent further processing, unauthorized access or disclosure to any other party or the public or prejudice to your interest. Please note that we often need to retain certain data for recordkeeping, audit or legal/regulatory purposes and/or to complete any transactions that you began prior to requesting a change or deletion, access to which shall be restricted on a need-to-know basis, as may be required and allowed under applicable laws and regulations.
COLLECTION AND PROCESSING OF INFORMATION FROM OUTSIDE THE PHILIPPINES
Summit Media is a corporation registered in the Philippines and our data processing activities primarily occur in the Philippines in accordance with the Philippine Data Privacy Act of 2012 and other applicable laws, rules and regulations. You acknowledge that any personal data we collect may be transferred to, processed, and stored in the Philippines. You further acknowledge that the Philippines has standards for the processing and storage of personal data that may not be equivalent to (and may be less comprehensive than) those in the country where you reside and/or are a citizen, and you consent to our collection, transfer, processing, and storage of your personal data in the Philippines.
We may transmit your Personal Data to third parties whom we contract to carry out services on our behalf to perform activities or functions related to the processing purposes regarding your personal information described in this Policy. Our third parties are contractually obligated to comply with applicable laws and regulations. All data processing, subcontracting or data sharing agreements with our affiliates, third party service providers, advertisers, and/or partners will be in accordance with the requirements under the Philippine Data Privacy Act of 2012, and other applicable laws and regulations as may be hereafter passed and implemented.
WE DO NOT SELL YOUR PERSONAL INFORMATION
Summit Media does not sell information that directly identifies you, like your name, address, banking information, or phone records. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information, or in the limited additional circumstances outlined in our Policy (such as for fraud prevention purposes or where we are legally required to share the information). While we use your information to serve you relevant ads in our Summit Sites or on partner websites, any and all information that you provide us that may identify you are not for sale or shared in exchange for money.
If you are based in California and you want to exercise your “Do Not Sell My Personal Information Right” under the California Consumer Privacy Act, please send us an e-mail at [email protected] and [email protected] with the subject “Do Not Sell My Personal Information”.
SUMMIT SITES ARE NOT FOR USE OF CHILDREN UNDER AGE 18
The Summit Sites are not designed for use by anyone under the legal age of eighteen (18) years old (“Child”). If you are a Child, please seek the permission of your parent or guardian before using any of our Summit Sites. By clicking “I AGREE” at the end of this Policy, you represent and warrant that you are at least eighteen (18) years old or that your parent/guardian agreed to this Policy on your behalf. If you are a parent or guardian and believe that your Child is using our Summit Sites without your consent, please contact us at [email protected] to request the deletion of any information provided by your Child and indicate in the subject line “Deletion Request for Minor”. We reserve the right to ask you for verification of your relationship to the Child before we honor such a request.
Summit Media does not knowingly collect or solicit any information from anyone under the age of 18 on the Summit Sites. If we discover that a Child has created an account on any of the Summit Sites, we will immediately delete the account as soon as possible. We will not use the information for any purpose and will not disclose the information to third parties. However, as a parent or guardian of such a Child, you understand that you are legally liable for any transactions created by the Child. There are commercially available tools to help you limit your Child’s exposure to materials online. If your Child posted comments on a Summit Site, you may also request for us to delete these comments, by providing us with the website live URL address where the content resides, a copy of the content (cut and pasted into your email), and the date of publication and, if applicable, the user name associated with it. We will act as promptly as possible to remove any information (except in certain circumstances mandated by law) within our reasonable control. Note that our deletion does not ensure complete or comprehensive removal of such content from the internet and comments that may have been posted by others about your Child or your Child’s posts might remain accessible online.
We may update this Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). Your continued use of the Summit Sites and our products and services therein after we have notified you of changes to this Policy indicates your consent to such changes.
If you have any concerns or questions about any aspect of this Policy, please feel free to contact us at:
Summit Media Data Protection Officer
SUMMIT MEDIA DATA PROTECTION OFFICE
40F Robinsons Equitable Tower,
ADB Avenue corner Poveda Road, Ortigas Center,