DATA PRIVACY POLICY STATEMENT

We encourage you (the reader or visitor of this website), the public, and all planholders of St. Peter Life Plan, Inc., borrowers and clients of St. Peter Chapels, to read this page to be well-informed of the Data Privacy Policy of the ST. PETER GROUP OF COMPANIES (also known as “ST. PETER GROUP” or “St. Peter Life Plan and Chapels”) and all covered corporations of the ST. PETER GROUP OF COMPANIES. In general, the ST. PETER GROUP OF COMPANIES and its member corporations envision to be World-Class Deathcare Experts and are engaged in the delivery of dignified and quality memorial services to the planholders of St. Peter Life Plan, Inc. and the public. In connection with its business operations, the ST. PETER GROUP OF COMPANIES may process the personal information, sensitive personal information and privileged information (collectively, “Personal Data”) of St. Peter Life Plan, Inc.’s planholders, borrowers and the clients of St. Peter Chapels who have transacted and are transacting business with the ST. PETER GROUP OF COMPANIES.

The ST. PETER GROUP OF COMPANIES values the privacy and the confidentiality of the Personal Data of St. Peter Life Plan, Inc.’s planholders, borrowers and the clients of St. Peter Chapels and also undertakes to safekeep and manage the personal data and information of planholders, borrowers and clients of St. Peter Chapels accurately, and secure and protected against manipulation, and unwarranted disclosure. The ST. PETER GROUP OF COMPANIES also undertakes to comply with the Data Privacy Act of 2012 (“DPA”), (Republic Act No. 10173), and its Implementing Rules and Regulations (“IRR”), and all circulars and issuances of the National Privacy Commission and ensures compliance by its staff with strict standards of security and confidentiality.

In this Data Privacy Policy, the ST. PETER GROUP OF COMPANIES explains and provides notice to the reader or visitor of this website, the public, and all planholders of St. Peter Life Plan, Inc, borrowers, and clients of St. Peter Chapels as follows:

1. The nature, purpose, and extent of processing of Personal Data;

2. The parties to whom ST. PETER GROUP OF COMPANIES may disclose and share Personal Data and from whom the ST. PETER GROUP OF COMPANIES may validly obtain Personal Data with consent;

3. The known risks of processing Personal Data and data security measures in place for protection against these risks;

4. The estimated period within which such Personal Data will be processed and retained.

This website is for general information purposes only. The St. Peter Group of Companies does not warrant the absolute accuracy of the information and the website or accept any liability for any loss or damage resulting from any inaccuracy or omission. No information contained on this website may be copied or redistributed without prior permission from the St. Peter Group of Companies.

Covered Corporations (Personal Information Controllers)

The following covered corporations are members of the ST. PETER GROUP OF COMPANIES:

Personal Data

The Personal Data that ST. PETER GROUP OF COMPANIES processes are as follows:

1. Name, age, date of birth, marital status, contact details, employment details and any other related personal information provided in the applicable application or contract forms or surveys and change of status forms or loan forms.

2. Any information about any visit and use of this website, or mobile application, or social media site and other digital platforms. This includes the collection of information through website analytics tools, digital surveys and questionnaires, IP addresses, and cookies and social media behavior for any tag, post, repost or mention of ST. PETER GROUP or ST. PETER GROUP OF COMPANIES and its subsidiaries and partners on any social media account or digital platform.

3. Personal data refers to the Personal Data of planholders of St. Peter Life Plan, Inc., borrowers of loans issued by St. Peter Finance Corporation, and clients of the corporations operating St. Peter Chapels funeral homes.

Consent

If the reader or visitor of this website, or St. Peter Life Plan, Inc.’s planholders, borrowers and clients of St. Peter Chapels provide the ST. PETER GROUP OF COMPANIES with Personal Data in the course of availment of any of the services or programs or offers or promos of any of the covered corporations of the ST. PETER GROUP OF COMPANIES, all St. Peter Life Plan, Inc.’s planholders, borrowers and customers of St. Peter Chapels confirm each one’s agreement to the terms and conditions in this Data Privacy Policy, and have explicitly authorized and consented to the lawful and necessary processing of his/her Personal Data. By using this website, the reader or visitor hereby accepts the practices and policies in this Data Privacy Policy Statement. If there is any objection or disagreement or contrary opinion to any practices and policies in this statement, please do not use this website to submit any personal information or data to St. Peter Life Plan, Inc., St. Peter Chapels or any member Company of the St. Peter Group of Companies. The provision of Personal Data is voluntary and the reader or visitor or planholders, borrowers or clients of St. Peter Chapels may choose not to provide the Personal Data. However, failure to do so may limit the capability of the St. Peter Group of Companies to properly transact business and/or provide services.

The St. Peter Group of Companies will not collect any information that identifies one personally through this website unless and until one buys products or avails of services, registers as a member, or submits personal information for job application purposes or similar purposes. By providing personal information to the St. Peter Group of Companies, one accepts that the St. Peter Group of Companies may retain one’s information for as long as necessary, to fulfill the purpose(s) for which it is collected in compliance with applicable laws and regulations.

When another person’s Personal Data (e.g. one’s spouse, dependent, children, parents), are submitted to the ST. PETER GROUP OF COMPANIES, this means that the one sharing or submitting that other person’s Personal Data attests that consent has been obtained by such person to process his or her Personal Data in accordance with this Data Privacy Policy.

Withdrawal of Consent

For any withdrawal of consent intended for ST. PETER GROUP OF COMPANIES or its members/covered corporations please send any request to St. Peter Group of Companies’ website www.stpeter.com.ph or to its official email address at lifeplanchapels@stpeter.com.ph. Depending on the nature and extent of the consent to be withdrawn, the ST. PETER GROUP OF COMPANIES or its members/covered corporations may not be in a position to continue to extend or properly deliver its services in such a case.

The St. Peter Group of Companies has the right to charge costs which are directly related to and necessary for the processing of any personal data access request.

The Collection of Personal Data

The ST. PETER GROUP OF COMPANIES may collect and store Personal Data through the following ways and for the following purposes:

1. In cases wherein Personal Data is submitted through the accomplishment of standard business forms (e.g. application form, contract form, etc.), through this website, or via digital surveys, social media (such as the St. Peter Group Facebook Page), or when making any comment or feedback, and via mobile applications. The St. Peter Group of Companies may also collect some information about the computer or other devices used by the visitor when visiting this website.

In using any social media features or platforms, either on this website, an application, or otherwise through a social media provider, the St. Peter Group of Companies may access and collect information via those social media features or platforms, or via this website or via the said social media provider in accordance with its policies. When using a social media feature, the St. Peter Group of Companies may access and collect information which was made available and included in one’s social media profile or account, including but not limited to the name, gender, birthday, email address, address, location etc. The access of the St. Peter Group of Companies to these information may be limited or blocked based on one’s privacy settings with the relevant social media provider, social media feature or application.

2. Through interaction with our Sales agents, branch office or chapel staff and duly authorized representatives through phone, email, chat and social media (e.g. Facebook, Twitter, Instagram, etc.).

3. The St. Peter Group of Companies may also obtain lawfully collected Personal or non-personal data about the reader, visitor, planholders of St. Peter Life Plan, Inc., borrowers and clients of St. Peter Chapels from affiliated entities, business partners and other independent third parties sources.

4. For statistical research, actuarial research or other forms of research and studies undertaken by St. Peter Life Plan, Inc., the financial services industry, the pre-need industry, or the respective regulators of the St. Peter Group of Companies.

5. For purposes of designing or creating new or enhancing existing products and services provided by the St. Peter Group of Companies. For purposes of data matching and for internal, business and administrative purposes.

6. Through availment of the offers, promos, benefits, services from partner merchants and other third-person service providers and ST. PETER GROUP OF COMPANIES subsidiaries. Where permitted by law, the St. Peter Group of Companies may access names and contact details for promotional or marketing purposes including the communication of promotional materials and conducting direct marketing in relation to products and services, promos, offers and research (surveys, etc.). In relation to any Personal Data collected by the St. Peter Group of Companies, such Personal Data would only be used for promoting or marketing any products or services.

For the purposes of direct marketing, the St. Peter Group of Companies may, where permitted by law, provide one’s personal information (with the exception of any Personal Data collected by the St. Peter Group of Companies while providing any services) to providers (whether within or outside of the St. Peter Group of Companies) of any of the purposes described herein and marketing or research services to enable the sending of promotional materials and for the conduct of direct marketing in relation to the products and services offered (these materials may be sent by postal mail, email, short message service [SMS] or other means). Where permitted by law, the St. Peter Group of Companies may provide Personal Data to providers (whether within or outside of the St. Peter Group of Companies) related to any of the above purposes.

7. Through responses and information submitted through surveys sent out during ST. PETER GROUP OF COMPANIES’ events or via digital channels or media (through email or mobile application) or through services.

8. When information is provided in relation to requests, comments, complaints, and inquiries.

9. For the communication of administrative notices or advisories about any account or data with the St. Peter Group of Companies or about future changes to this privacy statement.

10. For all other lawful purposes necessarily related to or in connection with the foregoing purposes.

The Use and Disclosure of Personal Data

The ST. PETER GROUP OF COMPANIES uses and processes Personal Data for its Pre-need business operations, memorial services, updates of planholders’ accounts, marketing, communication, analysis and research objectives for purposes of providing information, updates, advisories, promotional offers and as maybe necessary in the performance and delivery of memorial services.

Towards these purposes, the ST. PETER GROUP OF COMPANIES may disclose Personal Data to its employees, duly authorized representatives, related companies (including member-companies of the St. Peter Group of Companies), assignees and third-party service providers.

Where permitted by law and where such disclosure is necessary to satisfy the purpose or a directly related purpose for which the Personal Data was collected, the St. Peter Group of Companies may provide such Personal Data to the following parties:

1.) Any person authorized to act as an agent of the St. Peter Group of Companies in relation to the distribution or implementation of products and services offered by the St. Peter Group of Companies and any member company (or covered Corporations) of the St. Peter Group of Companies in relation to the provision or marketing of products and services.

2.) Any agent, contractor or third party service provider (within or outside the St. Peter Group of Companies) which provides administration, data processing, data management, telecommunications, computer services, payment services, debt collection or securities clearing services, technology outsourcing, call center services, mailing and printing services in connection with the operation of St. Peter Group of Companies’ businesses and provision of services.

3.) Any agent, contractor or third party service provider (within or outside St. Peter Group of Companies) including companies that help deliver services, such as insurance companies, investment management companies, appraisers, claims investigation companies, industry associations or federations.

4.) Other companies that help gather information or data or which communicate with planholders of St. Peter Life Plan, Inc., borrowers, clients of St. Peter Chapels, such as research companies and ratings agencies, in order to enhance the services provided; and

5.) Government or regulatory bodies or any person to whom St. Peter Group of Companies must disclose data: (a) under a legal and/or regulatory obligation in that jurisdiction applicable to that particular St. Peter Group of Companies; or (b) pursuant to an agreement between the St. Peter Group of Companies and the relevant government, regulatory body or other person.

6.) From time to time, the St. Peter Group of Companies may purchase a business or sell one or more of its businesses (or portions thereof) and, where permitted by law, Personal Data may be transferred or disclosed as a part of the purchase or sale or a proposed purchase or sale. In the event of such purchase of a business, the Personal Data received with that business would be treated in accordance with this Data Privacy Policy, insofar it is practicable and permissible to do so.

In relation to the foregoing, where permitted by law, Personal Data may be provided to any of the above parties who may be located in the Philippines or outside of Philippines. Personal Data may be transferred to, stored, and processed in Philippines or any other jurisdictions where any member of St. Peter Group of Companies is located, or jurisdictions where a third party contractor is located or from which the third party contractor provides services. By providing the St. Peter Group of Companies with Personal Data or availing of services using this website or applications, one gives consent to the transfer of such Personal Data outside one’s jurisdiction to St. Peter Group of Companies facilities or to those third parties with whom the St. Peter Group of Companies share it as described above even outside the Philippines.

Personal Data submitted or published (e.g. Profile page) in the ST. PETER GROUP OF COMPANIES website or other social media such as Facebook, Twitter, and Instagram may be available around the world through the internet. The St. Peter Group of Companies has no control over the use and misuse of such information by others. If any part of this website contains links to other websites, those sites may not operate under this Data Privacy Policy Statement. Everyone is advised to check the privacy statements on those websites to understand their policies on the collection, usage, transfer, and disclosure of Personal Data.

Rights of Data Subjects (Planholders and Customers)

The data subjects can exercise the following rights:

1. Right to be informed

The Planholder or Customer shall be informed if his/her Personal Data shall be, is being or has been processed. The data subject should always be informed prior to processing the following:

2. Right to access Personal Data

The Planholder or Customer shall have the right to request access of the following:

3. Right to correct

The Planholder or Customer has the right to dispute and demand the correction, updating, or completion of Personal Data if the data collected or processed and stored is erroneous, incorrect, inaccurate, incomplete, or needs updating.

4. Right to object

The Planholder or Customer has the right to object to, or order the blocking or removal of his/her Personal Data if used for purposes other than it was actually intended for (i.e. advertising, market research, and opinion research).

5. Right to data portability

The Planholder or Customer has the right to obtain a copy of his/her Personal Data collected or processed in an electronic or structured format for legitimate use.

6. Right to block, remove or delete

The Planholder or Customer has the right to suspend, withdraw, or order the blocking, removal, or destruction of his/her personal data from ST. PETER GROUP OF COMPANIES' systems, provided that such Personal Data is not critical and not required by applicable laws and regulations in relation to the products and services that the Planholder or Customer availed of.

7. Right to file a complaint

The Planholder or Customer has the right to file a complaint with the National Privacy Commission in case of violation of his/her data privacy rights under the relevant laws.

8. Right to be indemnified

The Planholder or Customer has the right to be indemnified in case of damages sustained due to inaccurate, incomplete, false, outdated, unlawfully obtained, or unauthorized use of his/her Personal Data.

For a complete reference of the rights of data subjects under the Data Privacy Act, the Planholder or Customer may access the National Privacy Commission website at www.privacy.gov.ph.

The Protection of Personal Data

The ST. PETER GROUP OF COMPANIES values the protection of the privacy of all Personal Data submitted and provided by St. Peter Life Plan, Inc. planholders, borrowers, and customers of St. Peter Chapels, including the information necessarily transferred or shared to third parties performing services on behalf of or for the ST. PETER GROUP OF COMPANIES and its members/covered corporations.

Any information provided (for example, by filling out the application form, contract form, and online registration form or survey, or via e-mail) shall be used only for the declared purpose of its collection or processing. Any activity on this website will not result in being added to a mailing list unless there is a specific request to do so. The ST. PETER GROUP OF COMPANIES and its members/covered corporations will not provide or sell any information from any business forms, surveys, e-mail lists, or electronic forms to any third party.

All such persons or service providers that Personal Data are shared with as discussed herein are required to protect the confidentiality and privacy of all Personal Data in line with the Data Privacy Policy of the ST. PETER GROUP OF COMPANIES. Safety measures shall be maintained to ensure protection of the Personal Data against disclosure, loss, theft, unauthorized access, modification or usage, such as password encryption of files, restricted file access to a limited number of employees, restricted access to data center/server room, firewall security, regular audit trails, and similar measures.

The ST. PETER GROUP OF COMPANIES has taken realistic, sufficient, and reasonable measures to prevent unauthorized access to, improper processing, or usage of Personal Data through these measures. The ST. PETER GROUP OF COMPANIES has procedural and electronic safeguards and security tools, such as password encryption of files, restricted file access to a limited number of employees, firewall security, and regular audit trails in place to help secure online Personal Data from unauthorized use. Although these procedures and electronic safeguards and systems are in place to adequately protect data, realistically speaking, these may still be subject to unforeseeable system errors and human and operational errors and are not completely infallible.

The Manner of Storage and Retention Period for Personal Data Processed

The collection of Personal Data is stored in a secured environment within the St. Peter premises. This secured environment has a server room and server computers that store the Information Systems and database containing Personal Data. All other manually recorded Personal Data will be retained and securely stored in accordance with the policies and procedures of the Administration Department. The appropriate physical, organizational, and technical controls in the storage of Personal Data have been established and developed for the purposes of maintaining the security, confidentiality, integrity, and availability of the Personal data of Planholders and Customers.

Personal Data may be transferred to, stored, and processed in the Philippines or any other jurisdictions where any member of St. Peter Group of Companies is located, or jurisdictions where a third-party contractor is located or from which the third-party contractor provides services. The ST. PETER GROUP OF COMPANIES has a data protection solution engineered to manage and protect back-up data across cloud, data center, and endpoint workloads. This data protection solution is built on the Azure cloud platform which is delivered as a service.

ST. PETER GROUP OF COMPANIES developed security measures to ensure the confidentiality, integrity, and availability of Personal Data that is collected. In order to secure and safeguard the collected Personal data against any loss, misuse, unauthorized access, disclosure, alteration, and destruction, the ST. PETER GROUP OF COMPANIES implemented organizational, physical, and technical security measures. These security measures in place are constantly being reviewed, monitored, and enhanced. The ST. PETER GROUP OF COMPANIES has taken realistic, sufficient, and reasonable measures to prevent unauthorized access to, improper processing, or usage of Personal Data through these measures.

Only the authorized employees of the company shall be allowed to access such personal data, for official and authorized purposes. All employees of ST. PETER GROUP OF COMPANIES shall ensure that every time they are not at their workstations, it is their responsibility to log out their computers and devices, keep drawers under lock and key and secure all documents or devices containing Personal Data to prevent unauthorized access.

The Information Technology (IT) Department is responsible for monitoring software and information systems on computers and electronic devices to ensure that the software and information systems installed and stored are compatible and secured and to prevent unauthorized access.

As a rule, personal and unofficial/unauthorized USB and external storage devices are not allowed within the premises of ST. PETER GROUP OF COMPANIES. However, in case of need, any employee who will bring and use USB and external storage devices must register the same with the IT Department. The unauthorized use of USB and external storage devices is not allowed. The IT Department shall keep, maintain, and update a logbook of a list of external storage devices together with the names of the pertinent Departments/Divisions to whom the external storage devices were assigned.

The employees are discouraged from downloading media or attachments containing personal data to non-office and unauthorized computers or devices. When working on non-office-issued and unauthorized devices, it is the responsibility of the concerned employee to completely delete any electronic media or document containing personal data and erase any trace of the document once it is no longer needed.

Safeguards are developed to protect the Company’s computer network and systems against accidental, unlawful, or unauthorized usage, any interference which will affect data integrity or hinder the functioning or availability of the system, and unauthorized access.

Measures are developed to ensure and maintain the confidentiality, integrity, availability, and resilience of the Company’s data processing systems and services.

Processes are developed for regularly testing, assessing, and evaluating the effectiveness of security measures, and also an authentication process, and other technical security measures that control and limit access thereto.

For St. Peter Life Plan, Inc., the personal data will be stored for the required amount of time during which the plans and the contractual obligations and services have not yet fully been used or performed (since Pre-Need benefits and services will be delivered in the future upon need, specifically death).

For St. Peter Chapels (At-Need memorial services), and Finance and Lending units, the Personal Data will be stored for no longer than ten (10) years either from the last transaction with any member company of the ST. PETER GROUP OF COMPANIES or until the expiration of the retention or storage limits set by applicable laws, whichever comes later. After this duration, both physical and digital files or records will be disposed of unless otherwise required by applicable laws or regulations.

Manner of Disposal and Destruction of Obsolete Personal Information

All Personal Data will be destroyed when no longer needed for the specific purpose for which it was provided, including any copies that may reside in the system backups, temporary files, or other storage media. In such cases, authorized Personal Data collectors and processors of the ST. PETER GROUP OF COMPANIES are required to properly dispose of all documents, physical or digital documents, or media containing Personal Data.

1. Papers or other physical documents containing Personal Data shall be completely shredded and not be otherwise reused for any purposes.

2. Hard drives, CDs, DVDs, tapes, or other magnetic media shall be fully disintegrated and disposed of through authorized hard drive shredding, grinding, melting, burning, and pulverization to render the physical storage media unusable and unreadable.

3. Electronic or digital files containing Personal Data will be deleted by either of the following methods:

1. By deleting and moving such to the trash or the recycle bin of the device when no longer necessary.
2. By anonymizing the Personal Data through data masking, pseudonymization, data swapping, or other similar methods, etc.
3. By overwriting old and unnecessary Personal Data to have free space storage for new Personal Data.
4. By degaussing or demagnetizing hard drive tapes or storage to neutralize devices and destroy the Personal Data thereof.
5. By data purging to permanently delete inactive or obsolete records from the database quickly and effectively.

In all instances, our manner of disposal shall ensure that the Personal Data shall no longer be retrieved, processed, or accessed by unauthorized persons.

Third-Party Websites

If there are sites accessed by hypertext links which appear in the ST. PETER GROUP OF COMPANIES’ website, these may have been independently developed by others. The St. Peter Group of Companies has no control over, and is not responsible for the privacy policies and the practices of others or of third parties. This Data Privacy Policy only applies to ST. PETER GROUP OF COMPANIES’ website, so when linking to other websites is done, it is advised that those who link to other websites should study their privacy policies.

The use of Cookies and Similar Technologies

The ST. PETER GROUP OF COMPANIES website may use cookies (small amount of data which may include an anonymous unique identifier which are stored in the memory of a user’s or visitor’s computer or device which contains information that can later be read by the web server that issued the cookie) when visiting the ST. PETER GROUP OF COMPANIES website. The St. Peter Group of Companies may use cookies on various websites maintained. These allow the ST. PETER GROUP OF COMPANIES website to recognize a particular device to improve the user experience and make the website work more efficiently as well as to provide information to the owners of the site, browser software, types and configurations of the affected browser, language settings, geo-locations, operating systems, referring website, pages and content viewed, and durations of visit) will be used for compiling aggregate statistics on how visitors reach and browse websites to help the St. Peter Group of Companies understand how the St. Peter Group of Companies can improve the experience on it. These cookies are encrypted and do not save any Personal Data. Such information is collected anonymously and cannot be identified unless one has logged on as a member. Such data is used only for website enhancement and optimization purposes. The cookies also enable the website to remember the visitor and preferences and tailor the website to one’s needs. Advertising cookies will allow the St. Peter Group of Companies to provide advertisements on websites that are as relevant as possible, e.g. by selecting interest-based advertisements or preventing the same advisement from constantly reappearing.

Most web browsers are initially set up to accept cookies. If one does not want to receive cookies, he/she can disable this function in his/her browser settings. If these cookies are blocked or disabled, the full features of the ST. PETER GROUP OF COMPANIES website may not be accessed. However, by doing so one may not be able to fully enjoy the benefits of the websites and certain features may not work properly.

Amendments to this Privacy Statement

The St. Peter Group of Companies reserves the right, at any time and without notice, to add to, change, update or modify this Data Privacy Policy Statement, simply by notification of such change, update, or modification on this website. Any such change, update or modification will be effective immediately upon posting.

Contact Us

For any questions about this ST. PETER GROUP OF COMPANIES’ Data Privacy Policy Statement, or data privacy, concerns or requests, kindly contact us through our Data Protection Officer (DPO) at ST. PETER CORPORATE CENTER 999 EDSA, QUEZON CITY, 1105 (Across SM North EDSA Annex) by sending us an email at lifeplanchapels@stpeter.com.ph or by filling-out the appropriate form on the St. Peter Group of Companies’ website at www.stpeter.com.ph.

For Data Privacy concerns, you may contact:

The Data Protection Officer

MS. JOYCE BASILIO-RAMOS

ST. PETER CORPORATE CENTER

999 EDSA, QUEZON CITY, 1105

(Across SM North EDSA Annex)

(02) 371-7757

The St. Peter Group of Companies has the right to charge costs which are directly related to and necessary for the processing of any personal data access request.