PRIVACY POLICY Section 1. Your Privacy 1.1 General. Schulify Group, Inc. (“Schulify” or “we”, “our” or “us”) takes your right to data privacy very seriously. This Privacy Policy describes how we use the information we obtain when you visit www.Schulify.com (the “Site”) or use the products, services offered through the Site (collectively, the “Services”). Please read this notice carefully and do not hesitate to let us know if you have any questions. 1.2 Acceptance of this Privacy Policy. By clicking “I Agree”, you are acknowledging and accepting the practices described in this Privacy Policy. Please note that we may update this Privacy Policy as we change or develop the Site or Services. We will notify you of any changes made that would substantially affect your data privacy rights and ask for your consent to the changes. 1.3 Personal Information Controller. Schulify is the Personal Information Controller (“PIC”)of your personal data insofar as the processing of your personal data before you register with any of our Merchants’ loyalty programs. The Merchants are considered the PICs with regard to any processing performed pursuant to their loyalty programs. Schulify is merely a Personal Information Processor, providing a platform for our Merchants for such processing. When a merchant terminates its partnership with us, we retain your personal data and we become the PIC of your personal data. Section 2. How We Collect and Use Your Personal Data 2.1 Customer Profile Information. You can access the Schulify platform by submitting only your mobile number. Should you choose to complete your account registration on the Schulify platform, you will be required to submit your Customer Profile Information, which includes: your full name, email address, address, birthday, gender, region, and current city. This information will be used to enroll you with the loyalty programs of the Merchants you transact with. We will also use your information to perform demographic analysis, which will allow us to recommend specific Merchants that you would appreciate. We will also use your Customer Profile Information to contact you as part of the transaction process, to send you periodic emails and SMS messages about merchants whose loyalty programs you have signed up for, or for purposes that are intended to enhance your user experience. We may also occasionally contact you to obtain feedback on a specific merchant deal in which you have participated. Schulify will generally ask you to indicate whether or not you want to receive certain types of email communication from us, and we will adhere to your preferences unless we consider a particular communication to be absolutely necessary. Emails will generally contain a link at the bottom to be removed from our mailing list. 2.2 Facebook Profile. Where you register using your Facebook account, you will be giving Schulify access to certain personal information stored in your Facebook profile. We will not view or store any data available to us from your Facebook profile without first obtaining your consent. You will be able to select what information we obtain from Facebook when registering for your Schulify account. At various times on Schulify.com.ph, you will be able to share our content with your Facebook friends. We do not view or store lists of your friends, nor do we view or store the specific messages that you send to your friends. However, we may record the number of times that particular content has been shared. 2.3 Transactional History. When you start using our Services, we will collect your Transactional History, which includes: the merchant and specific branch with whom you transacted, the transaction date, reference number of the transaction, amount of transaction, and the Schulify points earned and redeemed. This will facilitate the recording and redemption of loyalty program points and allow our Merchants to track the sales performance of each of their branches. 2.4 Financial Information. For certain services, we also request credit card or other payment account information which are maintained by our payment processor in encrypted form on secure servers. We do not share this information with any third party except the companies responsible for processing our credit card transactions. 2.5 Correspondences with You. Any personal data data you disclose when you correspond with us will only be processed to address your concern and for general corporate governance. 2.6 Information from Merchants and other Third Parties. We may combine information you submit under your account with information from other Schulify services or third parties, such as when Merchants submit their current database of loyalty program members to us, in order to provide you with a better experience and to improve the quality of our services. For certain services, we will give you the opportunity to opt out of disclosing such information. 2.7 Cookies. Like most sites, Schulify makes use of browser “cookies.” Cookies are small text files placed on your computer’s hard disk by our server. They allow us to quickly check your status as a subscriber and facilitate access to your preferences. Schulify does not use cookies to retrieve or track information that is unrelated to the Site or services. 2.8 GIF Image Trackers. Schulify may also use transparent GIF images in emails we send to you. We use these images to track the viewership of emails we send. 2.9 Unique URLs. Schulify may also create unique links in emails that enable us to track on which emails you click. 2.10 Sharing Functionality. At various times, you will be able to share content on our site using the share feature. We do not view or store the specific messages that you send through this feature, but we may record the number of times that particular content has been shared. 2.11 IP Addresses. We may occasionally collect and store your IP address. This helps us diagnose problems with our servers, administer our site, gather non-personally identifying information about our users, and detect and prevent fraudulent activity. 2.12 Mobile device information. If you access our website or app on your mobile phone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier, and your location information. 2.13 Anonymized Aggregated Information. Schulify may also collect non-personally identifying, aggregated information about subscribers’ use of our site. This information is not personally identifiable and will only be used to find out how visitors to our site use our service. For example, we may view how much time users spend on our site, from which other sites users came, and which links to external sites have been used, among other things. We may share this data with third parties in an aggregated, non-personally identifying form. Such information does not identify you individually. Section 3. Other Purposes We will also process your personal data for the following purposes: Comply with statutory and regulatory requirements, including directives, issuances by, or obligations of Schulify to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal Enable Schulify to exercise sound corporate governance over its businesses, ensure that risks arising therefrom are duly identified, measured, managed and mitigated, and enhance risk assessment and prevent fraud Conduct company audits or investigate a complaint or security threat Other legitimate business purposes Establish, exercise, or defend legal claims Fulfill any other purposes directly related to the above-stated purposes Section 4. Opt-Out You may inform us of the specific personal information you do not want to be processed beyond the requested purpose. We will respect your request in so far as it is feasible to fulfill the purposes for which the personal information was collected. Section 5. Disclosure to Third Parties 5.1 Merchants. When you sign up for a Merchant’s loyalty program, your Customer Profile Information and Transactional History will be disclosed to them in order to carry out their loyalty program activities. These activities include sending you direct marketing materials through SMS and email, and marketing and business analytics, among others. Please note that once you sign up for a Merchant’s loyalty program, they become the personal information controllers of your personal data. 5.2 Service providers. Schulify makes use of the following service providers. Your personal data will be disclosed to them for processing only for the purpose for which they were contracted: Cloud storage providers Mobile communications providers Legal and auditing services providers Information technology service providers 5.3 Law Enforcement, Regulatory Agencies, and other Legal Bodies. Your information may be disclosed where it is required to satisfy any applicable law, regulation, legal process or enforceable governmental request. 5.4 Collaborations, Mergers, and Acquisitions. We reserve the right to transfer or assign the personally identifying information we have collected from you in the event Schulify enters into product and service collaborations with third parties, is acquired by, or enters into a merger with, a third party, or in the event we undergo any other form of reorganization. In certain limited circumstances, our business partners may have a contractual right to obtain a copy of your contact information and to contact you if Schulify is unable to fulfill our contractual obligations to those parties. 5.5 Other Disclosures. We may share your personally identifying information when we believe in good faith that access, use, preservation or disclosure of such information is reasonably necessary to: enforce applicable Terms of Service, including investigation of potential violations thereof, detect, prevent, or otherwise address fraud, security or technical issues, protect against harm to the rights, property or safety of Schulify, its users or the public as required or permitted by law. 5.6 Schulify only shares your personal data with other entities or individuals outside of the company in limited circumstances. When information is disclosed to third parties or when the processing of personal information is outsourced by Schulify to a third party, the processing will be subject to written agreements between Schulify and the third parties processing the data, in accordance with the requirements of the Data Privacy Act of 2012. These written agreements specify the rights and obligations of each party and will provide that the third party has adequate security measures in place and will only process personal data on the specific written instructions of Schulify. 5.7 We will not sell, rent, share, trade, or disclose any of your personal information to any other party without your prior written consent, with the exception of entities within our company and any third-party service provider which we have engaged whose services necessarily require the processing of your personal information. Section 6. Data Retention and Disposal We will retain your personal data for as long as you maintain an account on the Schulify platform. You may request for the deletion of your personal data by contacting us if you no longer wish to keep your account. We will promptly delete your data from our servers upon receipt of your request. Section 7. Information Security Precautions We use a secure server software, known as an SSL certificate, intended to ensure that sensitive personal and financial information is encrypted. We require all of our third party partners to use similar technology. Section 8. Accessing and Updating Your Personal Information Although we take reasonable steps to ensure that all data we use is accurate, we depend on our users to update or correct their personal information whenever necessary. We make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. Section 9. Links to Other Websites The Site may contain links to other websites. Schulify is not responsible for the privacy practices of third parties or the content of these websites. If you follow these links you are responsible for reviewing the privacy policy of any third party website to determine that your personally identifying information is protected to your satisfaction. Section 10. Your Rights as a Data Subject Please be informed that you have the following rights under the Data Privacy Act of 2012: Access Personal DataYou may request access to any of your personal data held by the company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer. Make Corrections to Personal DataIt is your responsibility to inform us of any changes to the personal data that you have supplied during the course of your engagement. Erasure or Blocking of Personal DataYou shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our systems. Please note that depending on the type of personal information involved, you may be restricted from accessing any of our Services. Be Informed of the Existence of Processing of Personal DataYou have a right to be informed whether personal data pertaining to you shall be, are being or have been processed, including the existence of automated decision-making and profiling. DamagesUpon presentation of a valid decision, you have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject. Lodge a complaint before the National Privacy Commission Section 11. Contact Us In case of complaints, concerns, or questions regarding our privacy policy or if you wish to exercise your data subject rights, you may address them to: Schulify Support Bacolod City, Philippines +63 9173000983 support@Schulify.com Section 12. Changes to This Policy This Privacy Policy may be updated from time to time. Please periodically review this Policy to be appraised of our latest updates. You will be notified whenever there are any updates that will significantly affect you.