THREAD Privacy Policy

We, at Transnational E-Business Solutions Inc. (“TESI”) know the importance of your personal data privacy. We adhere with the requirements of all relevant privacy and data protection laws, particularly the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations. To this end, we are committed to ensure that any Personal Data you share with us is secured and protected. This Privacy Policy is designed to help you understand how we collect, use, store, share, manage, and protect the Personal Data that you will provide in our website and mobile application (the “Site”). The terms of this Privacy Policy apply to all users of this Site. 

Minors' Privacy

We take the privacy of minors seriously. If you are under 18 years of age, please do not submit any Personal Data through our Site without the express consent and participation of a parent or guardian. If you are a parent or guardian, please make every effort to guard your children's privacy.
What We Collect

When you register to and access TESI’s Human Resources Management platform, THREAD, through the Thread Mobile Application or through the Thread Web Portal (the “THREAD App”), we will collect your Personal Data that are necessary to prove your identity and access the services we deliver through the THREAD App. Any information we collect is used to provide and improve the delivery of our services. In particular, we may collect the following Personal Data:

a.    User Registration
•    Personal Information and/or Sensitive Personal Information from which the identity of an individual is apparent or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as your name, gender, civil status, date and place of birth, personal telephone and/or mobile numbers, email address, present and permanent addresses, family background, photo, and any other information relating to your identity;
•    Employment information such as your occupation, employer’s name, position/rank, date hired, and employment history; and
•    Income information such as your basic salary and other income.

b.    Device Information. We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number), when you use the THREAD App.

c.    Log information. When you use the THREAD App, we may also collect non-personal information such as but not limited to web page from which you came to our Site, your web page request, Internet Protocol (IP) address, geolocation, browser type, browser language, the date and time of your request and your registration data.
d.    Cookies. We may use cookies in analyzing and evaluating performance to provide you better experience when using our Site. Cookies are small files that a Site or its service provider transfers to your computer's hard drive through your web browser (you can disable this) that allows the Site's or service provider's systems to recognize your browser and capture and remember certain information.
Why We Collect Your Personal Data

We collect your Personal Data and other information to facilitate your transaction needs and to effectively provide our products and services to you. In particular, we are using your information to:
a.    provide, maintain, and improve our services, including the specific features or functions of the THREAD App;
b.    administer a content, promotion, survey or other Site feature;
c.    send periodic emails regarding your account or other products and services;
d.    effectively respond to your customer service requests and support needs;
e.    develop new products, services, functions and features related to the THREAD App;
f.    abide by any safety, security, public service or legal requirements and processes; and
g.    generate statistical and analytical data for research and development purposes.
We also collect your Personal Information and/or Sensitive Personal Information for HR Management purposes of your employer that is enrolled to the THREAD App.

How We Collect Your Personal Data

We collect your Personal Data through forms fillable by print, online, and/or submissions through our THREAD App. We may also collect and verify your employment and/or income information from our partners, subsidiaries, affiliates, and/or your employer enrolled to the THREAD App.

Who Do We Share Your Personal Data With

Your Personal Data may at times be viewed or accessed for the purpose of resolving a problem, address support-issues, check suspected violation of TESI’s Terms of Service, or as may be required by law. You are responsible for maintaining the confidentiality and security of your user registration and password.

TESI may share your Personal Data to our affiliates, subsidiaries and/or third party service providers. We will ensure that the parties who will have access to your Personal Data are obligated to maintain its security and confidentiality, and will use the same only in accordance with our instructions and under the terms of a Data Sharing Agreement that can demonstrate reasonable and appropriate safety measures to ensure the privacy and protection of your Personal Data.

We may also disclose your Personal Data to comply with legal requirements, such as submission of regulatory compliances and requirements to appropriate government agencies, compliance with a subpoena or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We may also use the information in the aggregate to understand how our users as a group, use the services and resources provided on our Site. Aggregated information may be used to analyze performance or otherwise improve our services, but it will be aggregated and anonymized to prevent public disclosure of your Personal Data. We may therefore, share aggregated, non-personally identifiable information publicly and with our business partners.

Changes in our corporate structure: If all or part of TESI is sold, merged or otherwise transferred to another entity, the Personal Data you have provided to us may be transferred as part of that transaction. We will take steps to ensure that, without your consent, any Personal Data that is transferred will not be used or shared in a manner inconsistent with this Privacy Policy.
How We Store And Protect Your Personal Data

We take reasonable precautions to keep your stored Personal Data secure and protected. We employ organizational, managerial, electronic, technical, and physical security measures in order to protect your Personal Data from breaches that may result in accidental or unlawful destruction, or accidental loss, alteration, or unauthorized disclosure or access.

Accuracy and Access. TESI will keep your Personal Data as accurate, complete and up-to-date as is necessary for the purpose for which it is processed.  In case you need to access, correct, amend, delete inaccurate Personal Data, or withdraw your consent, please immediately inform us. (see Contact Us section below)
Security. We take reasonable precautions to keep your stored Personal Data secure and protected. We employ adequate organizational, physical and technical security measures such as password protection, encryption, firewalls and other controls, to ensure and preserve the confidentiality, integrity and availability of your Personal Data. We work to protect the security of your information by using secure cloud hosted servers. Only authorized persons from TESI will have access to your Personal Data. Employees who misuse any information are subject to disciplinary action, including termination.

Third Party Links

TESI may offer links to sites that is run by third parties. If you visit other sites, you should read the site's privacy policy, terms and conditions, and their other policies. We are not responsible for the policies and practices of third parties. Any information you give to those organizations is dealt with under their privacy statement, terms and conditions, and other policies.
How Long Do We Retain Your Personal Data

We will retain your Personal Data for as long as your account in the THREAD App remains active and retention is necessary to support the delivery of our services, or as may be required by law, whichever comes later. In case that the Site is no longer functional or decommissioned, all of your Personal Data in digital or hard copies will be disposed or erased.

We also retain log files for internal analysis purposes. These log files are generally stored for a brief period of time, except in cases where they are used to improve service functionality or security, or where we are legally obligated to retain them for a longer period of time.

In case you are subscribed to email/SMS marketing, you will still receive email/SMS notifications. If you want to cancel your subscription, you may click the unsubscribe link at the bottom of any email message from TESI, or follow the SMS cancellation instructions.
Your Rights Under the Data Privacy Act

As a data subject, or a person from whom TESI collects, processes and stores information, you have certain rights under applicable laws. We feel it is important that you are aware of and understand these rights as they apply to you. In particular, you have the following rights under the Data Privacy Act:

a.    Right to be informed. You have the right to be informed whether your Personal Data shall be, are being, or have been processed, including the existence of automated decision-making and profiling.

b.    Right to access. Upon demand, you have the right to reasonable access to the contents of your Personal Data that were processed, sources from which those were obtained, and names of recipients of your Personal Data, among others.

c.    Right to object. You have the right to shall have the right to object to the processing of your Personal Data, including processing for direct marketing, automated processing or profiling.

d.    Right to blocking or erasure. You have the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data from our system.

e.    Right to rectify. You have the right to dispute the inaccuracy or error in your Personal Data and have it corrected immediately and accordingly, unless the request is vexatious or otherwise unreasonable.

f.    Right to data portability. You have the right to obtain a copy of your Personal Data in an electronic or structured format.

g.    Right to file a complaint. You have the right to file a complaint for any inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your Personal Data.

Changes to Privacy Policy

TESI reserves the right to amend this Privacy Policy at any time, consistent with applicable law. In such case, an updated version will be posted in our Site. If we are going to process your Personal Data in a manner different from that stated at the time of collection, we will notify you, and you will have a choice as to whether or not we can use your Personal Data in such a way.

Access and Change of Personal Data

If you wish to update any personal information you have previously provided, or to exercise any your rights to the processing of your personal information that you may have under the Data Privacy Act of 2012, please contact our Data Protection Officer at or you may write to:

Transnational E-Business Solutions, Inc.
Attention: Data Protection Officer
3rd Floor, TDG InHub Building, AFP-RSBS
Industrial Park, Km. 12 East Service Road
Corner C-5, Western Bicutan, Taguig 1630

Updated as of September 2020.
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