THE TYPES OF PERSONAL DATA WE COLLECT

The types of Personal Data we collect vary depending on your transaction with us. These generally consist of the following:

• Personal information such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username, password, and one-time pin (OTP);
• Photographs, audio and video footage;
• Sensitive personal information such as birth date, age, nationality, marital status, biometric data, gender, health, education and government issued identification document which includes, but not limited to identity (ID) cards, licenses, social security numbers, etc.;
• Background and employment records including your educational background, employment history, certifications, trainings attended, resume and previous income information ; and
• Financial details such as credit history, bank account, pay slips, credit card, and debit card information.

Please be reminded that you are responsible for ensuring that all Personal Data, whether personal information, sensitive personal information or privileged information, you submit to skytowerspins is accurate, complete and up to date.

 

COLLECTION OF PERSONAL DATA

We collect Personal Data from you in a variety of ways through our forms, applications, contact channels and Team Members.

• Identification and Contact Information

In order to verify your identity, we may request your identification and contact information during inquiries, registration, room and table reservations, purchases, and other transactions. This includes, but is not limited to, your name, date of birth, contact address, contact e-mail, contact number, passwords, and one-time pins (OTP).

• Purchase, Transactional & Financial Information

We may collect transactional information that you provide us whenever you engage in transactions with any of our gaming or resort outlets, either on-property or online. This includes credit or debit card details, account numbers and balances, identification information or documents, and details of your transaction history.

• Third Party Information

We may also collect information about you from other parties. We will use Personal Data only where you have provided your consent to the third party or where skytowerspins has a legitimate interest to use the Personal Data to provide you with our services or fulfil a legal or regulatory obligation.

ANALYTICS

skytowerspins engages third-party service providers to analyze web traffic data. This service uses cookies or web beacons.

Cookies are small files that our website puts on your personal computer (PC) or mobile device to store information about your preferences. Cookies can improve your browsing experience by allowing our website to remember your preferences or letting you avoid signing in each time you visit our website. If you don't want our website to store cookies on your PC or mobile device, you can block cookies. But blocking cookies might prevent some pages from displaying correctly, or you might get a message from our website letting you know that you need to allow cookies to view our website.

For you to fully enjoy your visit and browsing experience, only non-identifiable web traffic data are collected and analyzed, including:

• Your internet protocol (IP) address;
• The search terms you used;
• The pages and internal links accessed on our site;
• Demographics;
• The date and time you visited the site, including frequency of visits;
• Geolocation;
• Your operating system; and
• Web browser type.

Use the options in your web browser if you do not wish to receive cookies or wish to set your browser to notify you when you receive cookies. Click on the "Help" section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

LINKS TO THIRD-PARTY WEBSITES

From time to time, we will provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to you, and we do not provide any Personal Data to these websites or advertisers, and therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should review as well. skytowerspins’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. skytowerspins 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.

SHARING OF PERSONAL DATA                               

Generally, we do not share your Personal Data with third parties. However, there are limited circumstances wherein your Personal Data is shared with third parties in order (1) to complete your transactions with us, or (2) to comply with legal or regulatory obligations.

When you give your consent in our consent forms, or agree to terms and conditions for certain transactions, you authorize skytowerspins to disclose your Personal Data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign, so we can execute or perform the processes related to the purposes declared in this Privacy Policy. The use or disclosure of your Personal Data will only be performed when it is reasonably necessary or required or authorized by or under relevant laws and regulations.

This means we might provide your Personal Data to the following:

• Regulatory Bodies

We may share your personal data with regulatory bodies, such as the Anti-Money Laundering Council, the Philippine Amusement and Gaming Corporation (PAGCOR), and other departments, bureaus, and agencies of the government, including law enforcement agencies, when we believe it is necessary for us to comply with a legal obligation under applicable laws.

We may also share your personal data to respond to a legal procedure, a national emergency, specific requirements of public order and safety, or fulfill a constitutional or statutory mandate of a public authority.

• Service Providers and Others

We may share your personal data with our service providers for us to give you quality services and offers that you deserve. These service providers may include our affiliates, subsidiaries, partner companies, contractors, vendors, organizations, or agencies including their sub-contractors or prospective business partners.

All third parties with which we share Personal Data are required to use it in a manner that is consistent with this Privacy Policy. These third parties may only use such Personal Data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

DATA PRIVACY OF MINORS

skytowerspins is very sensitive to privacy issues, and it is especially careful in its communications with children. skytowerspins does not knowingly or intentionally collect personally identifiable information from persons under the age of 18. Persons under the age of 21 are not permitted to play in our gaming facility or loiter in gaming areas.

Personal Data pertaining to children and collected from their parents is used by skytowerspins or other entities that provide technical fulfilment or other services to skytowerspins. These Personal Data are not sold

Meanwhile, we urge parents to regularly monitor and supervise their children's on-line activities.

PROTECTING YOUR PERSONAL DATA

We take reasonable steps to ensure that the Personal Data we collect, use or disclose are accurate, complete, and up to date. We strictly enforce this Privacy Policy within skytowerspins, and we have implemented technological, organizational and physical security measures to protect your Personal Data 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 secured servers behind a firewall.
• We employ encryption on computing devices and physical security controls.
• We restrict access to your Personal Data to qualified and authorized personnel who hold your Personal Data with strict confidentiality.
• Personal Data that you provide to us through our website and applications can only be accessed and processed by authorized personnel through secure connections and environments.
• We reveal only the last four digits of your credit card numbers when confirming an order.
• We use multi-factor authentication when verifying your identity.
• We employ standard physical safeguards and measures such as fire suppression systems, role based room access, and the like.

RETENTION OF PERSONAL DATA

Generally, we adhere to the following Personal Data retention standards:

1. If the data subject has an existing contract and transaction with skytowerspins, the Personal Data will be retained all throughout the contract period and ten years after its completion.
2. If the data subject has no existing contract but has existing transaction with skytowerspins, the Personal Data will be retained during the transaction and ten years after its fulfilment.
3. If the data subject has no existing contract and transaction with skytowerspins, the Personal Data will be retained for a period of ten years.

Personal Data are stored in secure facilities and are retained in accordance with the above parameters, industry standards, laws, and regulations, unless you request that your Personal Data be deleted from our systems, databases, and hardcopies within a reasonable time, and subject to limitations stated in relevant laws and rules. Once deleted, your Personal Data will no longer be searchable or included in anonymous searches and will be completely removed from all storage locations. The Data Privacy Officer (DPO) may, however, choose not to grant access or correct information based on the request to comply with relevant laws and regulations. The DPO will give the individual a written notice that sets out the reason for the refusal.

skytowerspins has no control and therefore cannot enforce the same amount of security on any of the devices and applications that you use to access our site or applications, or to send us your Personal Data. We are therefore not responsible for the security and protection of information that may have been intercepted prior to our receipt of your Personal Data. Personal Data are stored in secure facilities and are retained in accordance with the above parameters, industry standards, laws, and regulations, unless you request that your Personal Data be deleted from our systems, databases, and hardcopies within a reasonable time, and subject to limitations stated in relevant laws and rules. Once deleted, your Personal Data will no longer be searchable or included in anonymous searches and will be completely removed from all storage locations. The DPO may, however, choose not to grant access or correct information based on the request to comply with relevant laws and regulations. The DPO will give the individual a written notice that sets out the reason for the refusal.

DISPOSAL AND DESTRUCTION

When the basis for processing has ceased, your Personal Data shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice your interests as a data subjects

UPDATES TO THE PRIVACY POLICY

skytowerspins may revise this Privacy Policy as the need arises or when dictated by issuances of the National Privacy Commission or any amendment to the Data Privacy Act of 2012. Any change to this Privacy Policy shall be duly posted in this website and will take effect immediately. Data subjects are encouraged to periodically check for such updates. Changes shall not be retroactively applied and will not alter how we handle Personal Data previously collected without obtaining your consent, unless required by law.

HOW TO EXERCISE YOUR DATA PRIVACY RIGHTS

Under the Data Privacy Act of 2012, you have the following data privacy rights:

1. Right to be informed;
2. Right to rectify or correct erroneous data;
3. Right to erasure or blocking
4. Right to access;
5. Right to object;
6. Right to data portability;
7. Right to be indemnified for damages; and
8. Right to file a complaint.

As a data subject, you have the right to have reasonable control over the flow of your Personal Data. You may exercise your data subject rights personally or you may authorize another person to exercise them on your behalf, as long as you provide specific authorization that is supported by appropriate documents, i.e. Special Power of Attorney, etc.

Your data subject rights are transmissible. In case of death, or incapacity of the data subject, his or her lawful heirs may exercise said rights.
If you would like information on whether skytowerspins holds any Personal Data about you, and the purpose/s for which they are processed, kindly fill out and submit the Access Request Form.

If you would like to suspend/stop the processing, remove, erase, or correct your Personal Data, kindly fill out and submit the Request for Correction and Erasure Form.

In case you have any other inquiry, concern, complaint, or claim for damages or compensation with respect to your data privacy rights or Personal Data, you may accomplish and submit the Inquiry Complaint Form provided below.

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: privacy.gov.ph/mechanics-for-complaints.

If your Personal Data was:

1. processed on the basis of consent or contract; and
2. processed by electronic means and in a structured and commonly used format

you may request a copy thereof if you intend to move or transfer it to another personal information controller by sending an email to the address provided below.

Should you have any other concern or feedback, you may reach us through (1) our “Contact Us” menu in this website: www.skytowerspinsresort.com, or (2) through written communication or email to our DPO:

Our contact details are as follows:

Jose Maria B. Gajitos
Data Protection Officer

1 Asean Avenue Entertainment City
Tambo, Parañaque City
1701 Manila, Philippine
Office: +63 2 8883 8788