We appreciate your interest in our Privacy Policy. At Sasi Digital Creative, we take the protection of your data very seriously, and below we explain what data we collect when you use our website and services and how it is used.

General Information

a. What law applies?

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the Philippines Republic Act No. 10173 (Data Privacy Act) (“DPA”) and the EU`s General Data Protection Regulation (“GDPR”).

b. What is Personal Information?

Personal Information is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

c. What is Special Category Data?

Special category data is Personal Information that needs more protection because it is sensitive. This includes Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

d. What is processing?

“Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means. The term is broad and covers virtually any handling of data.

e. Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Sasi Digital Creative, Aprille Sasi, Manila, Philippines. (“Sasi Digital Creative”, “we”, “us” or “our”). If you have any questions or if you wish to exercise your rights, you can contact us using info@sasidigitalcreative.com, or our Contact Form.

f. What are the legal bases of processing?

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Information:

    • For the fulfillment of contractual obligations
      • The purposes of the data processing are primarily based on the service we provide.
    • Within the framework of our legitimate interests

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:

      • Ensuring IT security and IT operations,
      • Measures for business management and further development of our services,
      • Defense against third-party claims and enforcement of own claims.
      • Based on your consent
        • Insofar as you have given us your consent to process personal data for certain purposes.

g. Is there an obligation for me to provide data?

Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.

Data we collect automatically

a. Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

b. Content Management System (CMS)

We also use the Content Management System (CMS) of WordPress a service provided by Automattic Inc to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.

c. Hosting

To provide our website, we use the services of Bluehost a service operated by Newfold Digital Inc, who process the above-mentioned data and all data to be processed in connection with the operation of this website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

d. Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies are generally categorized in different types and can broadly be considered as essential or non-essential. In accordance with the DPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential Cookies. Doing so you will be prompted to make a selection on our use of cookies when you first visit our website by means a Cookie Consent Management Tool. For further information on the Cookies we use, please refer to our Cookie Policy.

Data we collect directly

a. Contacting us

In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Information. The Personal Information collected when contacting us is to handle your request and the legal basis is both your consent and contract.

We are present on social media (currently Facebook, Instagram, Pinterest,) on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

b. When using our services

We process the Personal Information involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

c. Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

Marketing

a. General Marketing

Insofar as you have given us your consent to process your Personal Information for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

b. Affiliate Marketing

We also participate in Affiliate Programs. Affiliate programs are designed to provide a means for website owners to earn advertising fees by advertising and linking. As such our Blog may contain affiliate marketing links, which means we may get paid commission on sales of those products or services we write about. You will never be charged a fee through one of my affiliate links, however you may get a discounted rate of the relevant affiliates services and we will make a small commission. Our editorial content is not influenced by advertisers or affiliate partnerships.

General Principles

a. Who receives my data?

Within Sasi Digital Creative, those that need your data to fulfill our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.

b. How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and the Bureau of Internal Revenue, among others. The retention and documentation periods specified there are up to 10 years.

c. How do we secure your data?

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Information processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised as expeditiously as possible after which the breach was discovered.

d. Are data transferred to a third country or to an international organization?

We may transfer your Personal Information to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Information when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Information we transfer.

e. Special Category Data

Unless specifically required and explicit consent is obtained, we do not process special category data.

f. Minors

We do not request Personal Information from minors and children and do not knowingly collect such data or pass it on to third parties.

g. Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

h. Do Not Sell

We do not sell your Personal Information.

Your Rights and Privileges

a. Privacy rights

Under the DPA and GDPR, you can exercise the following rights:

    • Right to information
    • Right to rectification
    • Right to object to processing
    • Right to deletion
    • Right to data portability
    • Right of objection
    • Right to withdraw consent
    • Right to complain to a supervisory authority
    • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Information we hold about you, or if you wish to exercise any of your rights, please contact us.

b. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

c. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we will tell you why.

e. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Information to a supervisory authority responsible for data protection. The competent data protection authority in the Philippines is: National Privacy Commission (NPC), 5th Floor Delegation Building, PICC Complex, Roxas Blvd, Pasay, Metro Manila, Philippines (http://www.privacy.gov.ph)

Validity and questions

This Privacy Policy was last updated on Thursday, 13 April 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.