PRIVACY POLICY

Last Updated: November 2, 2025

1. INTRODUCTION

Welcome to Neo Network of Technologies (“we,” “our,” or “us”). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our multi-vendor ecommerce platform (the “Platform”).

This Privacy Policy complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as relevant issuances of the National Privacy Commission of the Philippines.

By using our Platform, you consent to the collection and use of your information as described in this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

We collect information that you voluntarily provide when you:

Create an Account: Name, email address, phone number, date of birth, gender, and password
Make a Purchase: Billing and shipping addresses, payment information (credit/debit card details, e-wallet information)
Become a Vendor: Business name, business registration details, tax identification number (TIN), bank account information, business address, and contact information
Contact Us: Name, email address, phone number, and message content
Complete Surveys or Promotions: Responses to surveys, feedback, reviews, and contest entries

2.2 Information Automatically Collected

When you access our Platform, we automatically collect:

Device Information: IP address, browser type, operating system, device identifiers
Usage Data: Pages visited, time spent on pages, links clicked, search queries, products viewed
Location Information: Approximate location based on IP address (with your consent, precise location data)
Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies

2.3 Information from Third Parties

We may receive information from:

Payment Processors: Transaction confirmation and payment status
Shipping Partners: Delivery status and tracking information
Social Media Platforms: If you connect your social media accounts, we may receive profile information
Credit Reference Agencies: For fraud prevention purposes (with your consent)

3. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

3.1 Service Provision

Process and fulfill your orders
Facilitate communication between buyers and vendors
Manage your account and provide customer support
Process payments and prevent fraudulent transactions
Arrange for shipping and delivery of products

3.2 Platform Improvement

Analyze usage patterns to improve our Platform
Develop new features and services
Conduct research and analytics
Test and troubleshoot technical issues

3.3 Marketing and Communication

Send promotional emails, newsletters, and special offers (with your consent)
Provide personalized product recommendations
Notify you about changes to our services
Send transactional emails (order confirmations, shipping updates)

3.4 Legal and Security

Comply with legal obligations and respond to legal requests
Enforce our Terms of Service and other policies
Detect, prevent, and address fraud and security issues
Protect the rights and safety of our users and the public

4. LEGAL BASIS FOR PROCESSING

We process your personal information based on:

Consent: When you have given explicit consent for specific purposes
Contract: When processing is necessary to fulfill our contract with you
Legal Obligation: When we must comply with Philippine laws and regulations
Legitimate Interests: When we have legitimate business interests that do not override your rights

5. INFORMATION SHARING AND DISCLOSURE

5.1 Vendors on Our Platform

When you make a purchase, we share necessary information (name, shipping address, contact details, order details) with the relevant vendor to fulfill your order.

5.2 Service Providers

We share information with trusted third-party service providers who assist us with:

Payment processing (banks, payment gateways, e-wallet providers)
Shipping and delivery services
Cloud storage and hosting services
Marketing and analytics services
Customer service and communication tools

All service providers are contractually obligated to protect your information and use it only for specified purposes.

5.3 Business Transfers

If we undergo a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change.

5.4 Legal Requirements

We may disclose your information when required by law, court order, or government authority, or when necessary to:

Comply with legal processes
Enforce our policies
Protect our rights, property, or safety
Prevent fraud or illegal activities

5.5 With Your Consent

We may share your information for other purposes with your explicit consent.

6. DATA RETENTION

We retain your personal information for as long as necessary to:

Provide our services to you
Comply with legal obligations (e.g., tax records for 10 years as required by Philippine law)
Resolve disputes and enforce agreements
For legitimate business purposes

When information is no longer needed, we will securely delete or anonymize it.

Specific Retention Periods:

Account information: Duration of account plus 5 years after closure
Transaction records: 10 years (as required by BIR regulations)
Marketing communications: Until you unsubscribe
Cookies and tracking data: As specified in our Cookie Policy

7. YOUR RIGHTS UNDER THE DATA PRIVACY ACT

As a data subject in the Philippines, you have the following rights:

7.1 Right to Information

You have the right to be informed about the collection and processing of your personal data.

7.2 Right to Access

You can request access to your personal information and obtain a copy of the data we hold about you.

7.3 Right to Rectification

You can request correction of inaccurate or incomplete personal information.

7.4 Right to Erasure or Blocking

You can request deletion or blocking of your personal data when:

It is no longer necessary for the purpose it was collected
You withdraw consent
The data is unlawfully processed
Required by law

7.5 Right to Object

You can object to the processing of your personal data for direct marketing, automated processing, or profiling.

7.6 Right to Data Portability

You can request your data in a structured, commonly used, and machine-readable format.

7.7 Right to File a Complaint

You have the right to file a complaint with the National Privacy Commission if you believe your rights have been violated.

To Exercise Your Rights: Contact our Data Protection Officer at [DPO Email] or [DPO Phone Number]

8. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal information, including:

Encryption of data in transit and at rest (SSL/TLS)
Secure payment processing compliant with PCI DSS standards
Regular security assessments and audits
Access controls and authentication mechanisms
Employee training on data protection
Incident response procedures

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. INTERNATIONAL DATA TRANSFERS

Your personal information is primarily stored and processed in the Philippines. If we transfer data outside the Philippines, we ensure appropriate safeguards are in place, such as:

Standard contractual clauses
Adequacy decisions by the National Privacy Commission
Your explicit consent

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

Remember your preferences and settings
Analyze Platform usage and performance
Provide personalized content and advertisements
Enable social media features

You can control cookies through your browser settings. However, disabling cookies may affect Platform functionality.

For more information, please refer to our Cookie Policy.

11. THIRD-PARTY LINKS

Our Platform may contain links to third-party websites and services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

12. CHILDREN’S PRIVACY

Our Platform is not intended for children under 18 years of age. We do not knowingly collect personal information from minors. If we discover that a child has provided personal information, we will promptly delete it.

Parents or guardians who believe their child has provided information should contact us immediately.

13. MARKETING COMMUNICATIONS

With your consent, we may send you marketing communications about:

New products and services
Special promotions and offers
Platform updates and news

You can opt out at any time by:

Clicking the “unsubscribe” link in our emails
Adjusting your account settings
Contacting us at [Contact Email]

Even if you opt out of marketing communications, we may still send transactional emails related to your orders and account.

14. VENDOR RESPONSIBILITIES

Vendors on our Platform are independent data controllers for the personal information they collect and process. Vendors are responsible for:

Complying with the Data Privacy Act
Implementing appropriate security measures
Respecting customer rights
Maintaining their own privacy policies

We require vendors to agree to our Vendor Terms and Conditions, which include data protection obligations.

15. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.

We will notify you of material changes by:

Posting the updated policy on our Platform with a new “Last Updated” date
Sending an email notification to registered users
Displaying a prominent notice on our Platform

Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

16. CONTACT INFORMATION

Data Protection Officer

Name: [DPO Name]
Email: [DPO Email Address]
Phone: [DPO Phone Number]
Address: 73 Road 2, Bagong Pag-asa, Quezon City, Metro Manila, Philippines

General Inquiries

Email: [General Contact Email]
Phone: [Customer Service Number]
Business Hours: Monday to Friday, 9:00 AM – 6:00 PM (Philippine Time)

National Privacy Commission

If you have concerns about our data practices or wish to file a complaint:

National Privacy Commission
5th Floor, Philippine International Convention Center (PICC)
Vicente Sotto St., Pasay City 1307
Website: https://www.privacy.gov.ph
Email: info@privacy.gov.ph
Hotline: (02) 8234-2228

17. CONSENT

By using our Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Platform.

For specific processing activities that require explicit consent, we will obtain your consent separately through appropriate mechanisms (checkboxes, opt-in forms, etc.).