Terms and Privacy
DATA PRIVACY POLICY
1. Introduction
Citadel Pacific Ltd., its subsidiaries, affiliated companies, and associated entities (collectively referred to as "CPL", "CPL Group", "we", "our", or "us") are committed to protecting and respecting the privacy of individuals whose personal information we collect and process.
We recognize the importance of safeguarding personal data and are committed to collecting, using, storing, retaining, disclosing, and disposing of personal information in a fair, transparent, secure, and lawful manner. This Privacy Policy explains how we handle personal data collected through our websites, online portals, mobile applications, products, services, and other digital platforms.
2. Scope
This Privacy Policy applies to all personal information collected by CPL through:
- Corporate websites
- Customer portals
- Mobile applications
- Online forms and registrations
- Customer support channels
- Marketing and promotional activities
- Business transactions and engagements
This Policy applies to customers, website visitors, applicants, business partners, contractors, vendors, service providers, and other individuals who interact with CPL.
3. Information We Collect
Depending on the service requested, transaction initiated, or interaction you have with CPL, we may collect only the personal information necessary to fulfill the intended purpose and support legitimate business, operational, legal, and regulatory requirements.
CPL collects only information that is adequate, relevant, and limited to what is necessary for the stated purpose of processing and in accordance with applicable legal and regulatory requirements.
4. How We Collect Information
Personal data may be collected through:
- Website registration forms
- Online inquiries
- Customer support requests
- Subscription forms
- Business transactions
- Mobile applications
- Cookies and similar technologies
- Direct communications with CPL representatives
- Third-party service providers authorized by law or contract
5. Purposes of Processing
CPL collects and processes personal data for legitimate business purposes, including:
- Providing products and services
- Managing customer relationships
- Processing transactions
- Responding to inquiries and requests
- Administering accounts
- Improving website functionality and user experience
- Conducting business operations
- Performing analytics and reporting
- Ensuring information security
- Preventing fraud and unauthorized activities
- Complying with legal, regulatory, and contractual obligations
Personal information is processed only for specific, explicit, and legitimate purposes.
6. Legal Basis for Processing
CPL processes personal information based on one or more of the following lawful grounds:
- Your consent;
- Performance of a contract;
- Compliance with legal obligations;
- Protection of vital interests;
- Legitimate business interests; or
- Other lawful grounds are permitted under applicable laws and regulations.
Where consent is required, we will obtain your consent before collecting or processing your personal data.
7. Sharing and Disclosure of Personal Information
Approved service providers and business partners may include cloud hosting providers, information technology service providers, payment processors, customer support providers, analytics providers, marketing service providers, and other third parties engaged to support the delivery of CPL's products, services, and business operations.
Personal information shall not be disclosed, transferred, or shared without a legitimate business purpose, legal basis, contractual safeguard, or applicable authorization. Access to personal information is limited to authorized parties with a need to know and who are subject to appropriate confidentiality and security obligations
8. Data Security
CPL maintains appropriate administrative, physical, and technical safeguards designed to protect personal information from:
- Unauthorized access;
- Unauthorized disclosure;
- Accidental loss;
- Misuse;
- Alteration;
- Destruction; and
- Other unlawful processing activities.
Sensitive personal information is subject to enhanced security controls and access restrictions.
9. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are located within the European Economic Area (EEA), United Kingdom, or other jurisdictions where the GDPR applies, you may have the following rights regarding your personal data:
- Right to Access – Request access to personal data we hold about you.
- Right to Rectification – Request correction of inaccurate or incomplete personal data.
- Right to Erasure ("Right to be Forgotten") – Request deletion of your personal data under certain circumstances.
- Right to Restrict Processing – Request limitation of how your personal data is processed.
- Right to Object – Object to processing based on legitimate interests, direct marketing, or profiling.
- Right to Data Portability – Receive your personal data in a structured, commonly used, and machine-readable format and transfer such data to another controller.
- Right to Withdraw Consent – Withdraw consent where processing is based on consent.
- Right Related to Automated Decision-Making – Not be subject solely to decisions based on automated processing that significantly affect you.
10. Your Data Protection Rights Under the National Privacy Commission (Philippines)
In accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its implementing rules and regulations enforced by the National Privacy Commission (NPC), data subjects are entitled to the following rights:
- Right to Be Informed – Be informed whether personal data is being processed and for what purposes.
- Right to Access – Obtain reasonable access to personal information held by CPL.
- Right to Object – Object to the processing of personal data, including direct marketing, automated processing, or profiling.
- Right to Correct – Request correction of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.
- Right to Erasure or Blocking – Suspend, withdraw, remove, destroy, or block personal data under applicable circumstances.
- Right to Data Portability – Obtain and electronically move, copy, or transfer personal data in a secure format where technically feasible.
- Right to Damages – Be indemnified for damages resulting from inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.
- Right to Lodge a Complaint – File a complaint with the National Privacy Commission regarding privacy concerns or violations.
11. Access to Personal Information
Access to personal information is restricted to authorized personnel and approved third parties who require access to perform their assigned duties or fulfill legitimate business requirements.
Access is granted on a need-to-know basis and governed through appropriate approval and security processes.
12. Cross-Border Transfers
Where necessary for operational, legal, or business purposes, personal information may be transferred to CPL affiliates, service providers, or business partners located in other countries.
Prior to any transfer, CPL will assess whether appropriate contractual, organizational, and technical safeguards are in place to ensure that personal information remains adequately protected and processed in accordance with applicable privacy and data protection laws.
CPL will implement appropriate safeguards to ensure that transferred personal information remains adequately protected and processed in accordance with applicable privacy laws.
13. Data Retention
Personal information shall be retained only for as long as necessary to:
- Fulfill the purpose for which it was collected;
- Meet business and operational requirements;
- Comply with applicable legal and regulatory obligations; or
- Protect CPL's legal interests.
Retention periods vary depending on the type of information, the purpose for which it was collected, business and operational requirements, applicable legal obligations, and regulatory requirements
Upon expiration of the applicable retention period, personal information will be securely deleted, anonymized, or destroyed.
14. Data Subject Rights
Subject to applicable laws and regulations, you may have the right to:
- Be informed regarding the processing of your personal data;
- Access your personal information;
- Request correction of inaccurate or incomplete data;
- Withdraw consent where processing is based on consent;
- Object to certain processing activities;
- Request deletion or erasure of personal information where legally permissible;
- Request data portability;
- Lodge complaints with applicable regulatory authorities.
CPL will evaluate and respond to requests in accordance with applicable laws and internal procedures.
15. Children’s Privacy
CPL does not knowingly collect, process, or store personal information from children unless permitted by applicable law or with the consent of a parent or legal guardian.
If CPL becomes aware that personal information has been collected from a child without the required authorization, reasonable steps will be taken to delete such information or otherwise comply with applicable legal requirements.
Parents or legal guardians who believe that a child has provided personal information to CPL without consent may contact the Data Protection Officer using the contact details provided in this Privacy Policy.
16. Automated Decision-Making
CPL does not currently use automated decision-making or profiling processes that produce legal effects or similarly significant effects on individuals.
17. Data Breach Management
CPL maintains processes for identifying, investigating, managing, and responding to security incidents and personal data breaches.
Any unauthorized use, disclosure, loss, alteration, destruction, or compromise of personal information will be promptly assessed and addressed through appropriate corrective and preventive measures.
18. Cookies and Website Technologies
Our websites may use cookies and similar technologies to:
- Enable website functionality;
- Improve user experience;
- Remember user preferences;
- Analyze website performance;
- Support security controls.
Additional information regarding cookies is available in the CPL Cookie Policy.
19. Third-Party Websites
Our websites may contain links to third-party websites or services.
CPL is not responsible for the privacy practices, content, or security of third-party websites. Users are encouraged to review the privacy policies of such websites before providing personal information.
20. Changes to This Privacy Policy
CPL reserves the right to modify or update this Privacy Policy from time to time.
Any changes will be published on the website and will become effective upon posting unless otherwise specified.
21. Contact Information
For privacy-related requests, concerns, complaints, or inquiries, please contact:
Data Protection Officer (DPO)
Email: dpo_rohq@citadelpacific.com
Citadel Pacific Ltd.
28F Tower 2, High Street South Corporate Plaza
26th Street corner 11th Avenue
Bonifacio Global City, Taguig City, Philippines
Telephone: (02) 8284 6000
22. Consent
By accessing and using CPL websites, applications, products, or services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, disclosure, storage, retention, and processing of your personal information as described herein and as permitted by applicable law.
TERMS AND CONDITIONS
1. Acceptance of Terms
These Terms and Conditions ("Terms") govern your access to and use of websites, applications, digital platforms, products, and services operated by Citadel Pacific Ltd., its subsidiaries, affiliates, and associated entities (collectively, "CPL", "CPL Group", "we", "our", or "us").
By accessing, browsing, registering for, or using any CPL website or service, you acknowledge that you have read, understood, and agree to be bound by these Terms and applicable laws and regulations.
If you do not agree to these Terms, you should immediately discontinue use of the website.
2. About Citadel Pacific Ltd.
Citadel Pacific Ltd. and its operating companies provide various products, services, and digital platforms to support business operations and customer engagement.
- Corporate Office
Citadel Pacific Ltd.
28F Tower 2, High Street South Corporate Plaza
26th Street corner 11th Avenue
Bonifacio Global City, Taguig City, Philippines
Telephone: (02) 8284 6000
3. Eligibility and Use of the Website
You may use this website only for lawful purposes and in accordance with these Terms.
You agree that you shall:
- Use the website responsibly and ethically;
- Provide accurate and complete information when requested;
- Comply with all applicable laws and regulations;
- Respect the rights of other users and third parties.
CPL reserves the right to restrict access to users who violate these Terms.
4. Age Restrictions / Children's Data
This website is intended for individuals who are at least eighteen (18) years of age or the age of majority in their jurisdiction, unless otherwise permitted by applicable law.
CPL does not knowingly collect, solicit, or process personal information from children without the consent of a parent, legal guardian, or other authorized representative where required by law. If CPL becomes aware that personal information has been collected from a child in violation of applicable legal requirements, CPL will take reasonable steps to delete or otherwise manage such information in accordance with applicable laws and regulations.
Parents or legal guardians who believe that a child has provided personal information through the website may contact CPL using the contact information provided in these Terms.
5. User Responsibilities and Prohibited Activities
Users shall not:
- Attempt to gain unauthorized access to systems, applications, networks, databases, or accounts;
- Introduce malware, ransomware, viruses, or harmful code;
- Interfere with website functionality or security mechanisms;
- Use the website for fraudulent, illegal, misleading, or deceptive activities;
- Harass, threaten, abuse, or impersonate other individuals;
- Copy, modify, distribute, or reproduce website content without authorization;
- Collect personal information from other users without consent;
- Engage in activities that may compromise the confidentiality, integrity, or availability of CPL systems
Violation of these provisions may result in suspension, termination, legal action, or reporting to appropriate authorities.
6. User Submissions
Where users submit information through:
- Contact forms
- Feedback forms
- Service requests
- Registrations
- Job applications
- Business inquiries
the user warrants that all information provided is accurate, complete, lawful, and submitted with appropriate authority.
Submission of false, misleading, or fraudulent information may result in rejection, suspension, or termination of access.
7. Intellectual Property Rights
All content available on this website, including but not limited to:
- Text
- Graphics
- Logos
- Trademarks
- Trade names
- Images
- Software
- Reports
- Documents
- Designs
- Audio and video materials
are owned by or licensed to CPL and are protected under applicable intellectual property laws.
Except as expressly permitted by law, no website content may be copied, reproduced, distributed, modified, published, transmitted, or otherwise exploited without prior written consent from CPL.
8. Privacy and Data Protection
Personal information collected through the website shall be processed in accordance with the CPL Data Privacy Policy and applicable data protection laws and regulations. Personal data shall be collected only for specific, explicit, and legitimate purposes and shall be protected against unauthorized access, disclosure, alteration, misuse, or loss.
Personal data shall be retained only for as long as necessary to fulfill the purposes for which it was collected and processed, including compliance with applicable legal, regulatory, contractual, operational, and business requirements. Retention periods may vary depending on the nature of the information and the purpose of processing. Upon expiration of the applicable retention period, personal data shall be securely deleted, anonymized, archived, or otherwise disposed of in accordance with CPL's Records Retention Policy and applicable laws.
For more information regarding the collection, use, retention, and protection of personal data, please refer to the CPL Data Privacy Policy.
9. Cookies and Similar Technologies
This website may use cookies and similar technologies to:
- Support website functionality;
- Improve user experience;
- Maintain security;
- Analyze website traffic and performance;
- Remember user preferences.
You may accept, reject, or manage your cookie preferences at any time through the cookie settings available on the website. Withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal.
By using this website, you acknowledge the use of cookies as described in the CPL Cookie Policy.
For more information, please refer to the Cookie Policy.
10. Third-Party Links
This website may contain links to external websites, applications, or services operated by third parties.
Such links are provided solely for convenience. CPL:
- Does not control third-party websites;
- Does not endorse their content;
- Is not responsible for their security practices;
- Is not responsible for their privacy practices;
- Is not responsible for their availability or reliability.
Access to third-party websites is at the user's own risk.
11. Security
CPL implements reasonable administrative, technical, and organizational measures designed to protect information assets and personal information from unauthorized access, disclosure, misuse, alteration, or destruction.
However, no internet-based system can be guaranteed to be completely secure. Users acknowledge and accept the inherent risks associated with online communications and technology.
12. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are located within the European Economic Area (EEA), United Kingdom, or other jurisdictions where the GDPR applies, you may have the following rights regarding your personal data:
- Right to Access – Request access to personal data we hold about you.
- Right to Rectification – Request correction of inaccurate or incomplete personal data.
- Right to Erasure ("Right to be Forgotten") – Request deletion of your personal data under certain circumstances.
- Right to Restrict Processing – Request limitation of how your personal data is processed.
- Right to Object – Object to processing based on legitimate interests, direct marketing, or profiling.
- Right to Data Portability – Receive your personal data in a structured, commonly used, and machine-readable format and transfer such data to another controller.
- Right to Withdraw Consent – Withdraw consent where processing is based on consent.
- Right Related to Automated Decision-Making – Not be subject solely to decisions based on automated processing that significantly affect you.
13. Your Data Protection Rights Under the National Privacy Commission (Philippines)
In accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its implementing rules and regulations enforced by the National Privacy Commission (NPC), data subjects are entitled to the following rights:
- Right to Be Informed – Be informed whether personal data is being processed and for what purposes.
- Right to Access – Obtain reasonable access to personal information held by CPL.
- Right to Object – Object to the processing of personal data, including direct marketing, automated processing, or profiling.
- Right to Correct – Request correction of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.
- Right to Erasure or Blocking – Suspend, withdraw, remove, destroy, or block personal data under applicable circumstances.
- Right to Data Portability – Obtain and electronically move, copy, or transfer personal data in a secure format where technically feasible.
- Right to Damages – Be indemnified for damages resulting from inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.
- Right to Lodge a Complaint – File a complaint with the National Privacy Commission regarding privacy concerns or violations.
14. Website Availability
While CPL seeks to provide continuous access to its websites and services, uninterrupted availability cannot be guaranteed.
The website may be unavailable due to:
- Scheduled maintenance;
- Emergency maintenance;
- System upgrades;
- Security incidents;
- Telecommunications failures;
- Events beyond CPL's reasonable control.
CPL reserves the right to modify, suspend, or discontinue any website feature or service without prior notice.
15. Disclaimer
The website and all information, content, products, and services made available through it are provided on an "as is" and "as available" basis.
To the fullest extent permitted by applicable law, CPL makes no warranties or representations, whether express or implied, including warranties relating to:
- Accuracy;
- Completeness;
- Reliability;
- Availability;
- Fitness for a particular purpose;
- Non-infringement.
Users assume all risks associated with their use of the website.
16. Limitation of Liability
To the maximum extent permitted by applicable law, CPL shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, loss of business opportunities, loss of goodwill, or business interruption arising from the use of the website.
Nothing in these Terms shall exclude or limit liability for:
(a) fraud or fraudulent misrepresentation;
(b) willful misconduct or gross negligence;
(c) violations of applicable data protection, privacy, or consumer protection laws where liability cannot legally be excluded; or
(d) any liability that cannot be excluded or limited under applicable law.
17. Suspension and Termination
CPL reserves the right, at its sole discretion, to suspend, restrict, or terminate access to the website without notice when:
- These Terms are violated;
- Security concerns arise;
- Regulatory requirements necessitate such action;
- Website operations are threatened;
- Unauthorized activities are detected
18. Compliance with Laws
Users shall comply with all applicable laws, regulations, and legal requirements governing the use of the website.
Where CPL conducts business across multiple jurisdictions, additional legal requirements of the relevant jurisdiction may apply.
19. Governing Law and Dispute Resolution
These Terms and Conditions shall be governed by and construed in accordance with the laws of the Republic of the Philippines, without regard to conflict of law principles.
The parties shall endeavor to resolve disputes amicably through good-faith discussions. Where resolution cannot be achieved, disputes shall be submitted to the competent courts of Taguig City, Philippines.
20. Changes to Terms and Conditions
CPL reserves the right to revise, amend, or update these Terms and Conditions from time to time to reflect changes in legal, regulatory, operational, security, or business requirements.
Updated versions of these Terms shall be published on the website and shall become effective upon posting unless otherwise stated.
Where changes materially affect users' rights, obligations, privacy practices, or use of the website, CPL may provide additional notice through appropriate means, including website notifications or other available communication channels.
Your continued use of the website following the effective date of any revisions constitutes acceptance of the updated Terms and Conditions.
21. Contact Information
For questions, concerns, or requests regarding these Terms and Conditions, please contact:
Data Protection Officer (DPO)
- Email: dpo_rohq@citadelpacific.com
Citadel Pacific Ltd.
- 28F Tower 2, High Street South Corporate Plaza
26th Street corner 11th Avenue
Bonifacio Global City, Taguig City, Philippines
Telephone: (+632) 8284 6011