The purpose of this document (“Data Protection Policy”) is to inform you how the Philippine National Bank (“PNB”) and its related companies and entities (the “Companies”) as well as their respective representatives and / or agents (“Representatives”) [PNB, the Companies and Representatives collectively referred to herein as “PNB,” “us,” “we” or “our”] manage Personal Data (as defined below) which is subject to the Data Privacy Act of 2012 (R.A. No. 10173) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to PNB collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to PNB’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to PNB in respect of your Personal Data, and your consents herein are additional to any rights which PNB may have at law to collect, use or disclose your Personal Data.

PNB may, from time to time, update this Data Protection Policy to ensure that this Data Protection Policy is consistent with future developments, industry trends and / or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website: www.pnb.com.ph. Please check regularly for updated information on the handling of your Personal Data.

In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your transaction with us) your name, valid identification documents, contact number(s), mailing address, email address, transactional data and any other information which you have provided us in any forms you may have submitted to us (including biometric data), or via other forms of interaction with you.

Ways of Collecting Personal Data

Generally, we collect Personal Data in the following ways:

1. When you submit any form, including but not limited to application forms or other forms relating to any of our products or services or any investments which you avail through PNB;
2. When you enter into any agreement or provide other documentation or information in respect of your transactions with us, or when you avail of our products and services;
3. When you interact with our personnel, including relationship managers, branch managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
4. When your images are captured by us via closed-circuit television cameras (“CCTVs”) or other equipment or devices while you are within our premises;
5. When you use some of our products and services provided through online and other technology platforms, such as websites and apps;
6. When you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, promotional campaigns and other marketing activities;
7. When you are contacted by, and respond to, our marketing representatives, agents and other service providers;
8. When we seek information about you and receive your Personal Data from third parties in connection with your relationship and transactions with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
9. In connection with any investigation, litigation, or inquiry which may relate to you or any Connected Person; and / or
10. When you submit your Personal Data to us for any other reason.

Personal Data Relating to a Third Party

If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his / her Personal Data for the respective purposes. “Connected Person” may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and / or employee, payee of designated payment, representatives, agents or nominees.

Completeness, Accuracy of Personal Data

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You agree to inform PNB immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as PNB may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

Collection, Use and Disclosure of Personal Data

Generally, PNB collects, uses and discloses your Personal Data for the following purposes:

1. Responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
2. Verifying your identity and customer due diligence;
3. Managing the administrative and business operations of PNB and complying with internal policies and procedures (including but not limited to facilitating business continuity planning);
4. Audit purposes;
5. Verifying or confirming trade orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);
6. Matching any Personal Data held which relates to you for any of the purposes listed herein;
7. Resolving complaints and handling requests and enquiries;
8. Preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of PNB’s proprietary and sensitive information);
9. Providing media announcements and responses, for example, in relation to complaints or lawsuits;
10. Requesting feedback or participation in surveys, as well as conducting market research and / or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
11. Managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
12. Managing and preparing reports on incidents and accidents.
13. These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

Compliance to Applicable Rules, Laws and Regulations

1. Complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to PNB or that it is expected to comply, according to:
   • any law binding or applying to it within or outside the Philippines existing currently and in the future;
   • any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations within or outside the Philippines existing currently and in the future;
   • Any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations that are assumed by or imposed on PNB by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
2. To assist in law enforcement and investigations by relevant authorities;
3. In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and / or protecting and enforcing our contractual and legal rights and obligations;
4. Any other purpose relating to any of the above.

Archival Management

Archival management (including but not limited to warehouse storage and retrievals).

Collecting, Processing and Disclosing Personal Data Depending on the Nature of Our Relationship

In addition, PNB collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

1. If you are a prospective customer:
   • Evaluating your eligibility to open an account with us and your financial and banking needs and providing recommendations to you as to the type of products and services suited to your needs;
   • Assessing and processing any applications or requests made by you for products and services offered by PNB; and / or
   • Any other purpose relating to any of the above.
2. If you are a customer holding an account with PNB or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager or other similar official who has been so appointed pursuant to bankruptcy or insolvency proceedings instituted in the Philippines or elsewhere in respect of a PNB customer or any security provider:
   • Opening, maintaining or closing of accounts and our establishing or providing banking and trust services to you;
   • Processing fund transfers or any other instructions on your account;
   • Where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and / or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;
   • Processing applications for and facilitating the daily operation of services and credit facilities provided to you or other persons or corporations for whom you act as surety or third party service provider;
   • Conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;
   • Facilitating or processing your application for insurance products and / or trust services offered by PNB and its business partners;
   • Carrying out client reviews, for example, annual reviews of your portfolio;
   • To establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
   • Providing internet banking services (including but not limited to carrying out special handling requests for PIN mailers and tokens);
   • Networking to maintain customer relationship;
   • Providing client servicing (including but not limited to responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction);
   • Facilitating the transfer of funds within PNB bank accounts or from PNB accounts to external bank accounts and vice versa;
   • Administering exceptional approvals, fee adjustments or waivers;
   • Dealing with and designing investment products (for example, bonds, derivatives, equities, funds);
   • Administering credit, debit, prepaid or cash cards (including but not limited to processing card applications, transactions and credit limit approvals);
   • Providing cheque deposits, issuance clearing services;
   • Determining and collecting amounts owed by you or the borrower for whom you act as surety or third party security provider or those providing security or acting as surety for your liabilities and obligations;
   • Enabling any Company or third party to perform the functions that PNB may have outsourced to it in relation to the management of your account or transactions;
   • Enabling an actual or proposed assignee of PNB, or participant or sub-participant or transferee of PNB’s rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer.

If you are an Employee or Agent of a Referrer or Other Intermediary

• Marketing services and products;
• Processing commission remuneration;
• Performing due diligence and reference checks; and / or
• Any other purpose relating to any of the above.

If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by PNB:

• Managing project tenders or the supply of goods and services;
• Processing and payment of vendor invoices;
• Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and / or
• Any other purpose relating to any of the above.

If you are a Party or Counterparty to a Transaction

• Providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and / or clearing of the relevant transaction); and / or
• Any other purpose relating to any of the above.

Additional Purposes

1. In addition, where permitted under the Act, PNB may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
   • Providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
   • Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by PNB or other third parties;
   • Sending you details of products, services, special offers and rewards, investment or research reports or guides, either to our customers generally, or which we have identified may be of interest to you; and / or
   • Conducting market research, understanding and analysing customer behaviour, location, preferences and demographics.
2. If you have provided your Philippine telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Philippine telephone number(s), then from time to time, PNB may contact you using such Philippine telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).
3. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

PNB will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, only to the extent necessary, and through secure means, for the purposes listed above (where applicable), to the following entities or parties, whether located overseas or in the Philippines

1. PNB’s related corporations, subsidiaries and affiliates and overseas branches and offices;
2. Counterparties and their respective banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;
3. Third party recipients of reference letters;
4. Companies providing services relating to insurance and / or reinsurance to PNB;
5. Insurers or brokers in relation to the insurance products or services that you have applied for or availed;
6. Trustees, attorneys and asset managers appointed by you to manage your account held with PNB;
7. Referrers who have referred you to PNB;
8. Any person (1) who provides security or acts as surety for your liabilities and obligations to PNB or (2) for whom you act as surety or third party security provider;
9. Agents, contractors, vendors, installers, or third party service providers who provide administrative or operational services to PNB, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to PNB;
10. Agents, contractors, vendors or other third party service providers in connection with products and services offered by PNB;
11. Credit reporting agencies;
12. Debt collection agencies;
13. Your employers which are financial institutions, for their internal surveillance or monitoring purposes;
14. Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
15. Credit card companies and their respective service providers in respect of credit cards held by you;
16. Translators;
17. Our professional advisers such as our auditors and lawyers;
18. Third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with PNB;
19. Relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over PNB or any Company or over any transaction entered into by you, such as the Bangko Sentral ng Pilipinas, Securities and Exchange Commission, Bureau of Internal Revenue, as well as to comply with listing and other requirements or directions of the Philippine Stock Exchange and / or any other relevant securities exchange;
20. Any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in the Phlippines or elsewhere, in respect of you or your assets;
21. Third parties who carry out registration of charge or pledge over the assets that you have pledged or charged to PNB;
22. Corporate service providers or lawyers, who are appointed by you;
23. Surveyors or valuers or other third parties in relation to assets which you will be charging or mortgaging to PNB;
24. Financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, the Bangko Sentral ng Pilipinas, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;
25. Collection and repossession agencies in relation to the enforcement of repayment obligations for loans;
26. Third parties who organise promotional or marketing events, seminars or trainings;
27. Any actual or proposed assignee of PNB or participant or sub-participant or transferee of PNB’s rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer;
28. Any person to whom PNB is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to PNB, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which PNB or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of PNB with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside the Philippines and may be existing currently and in the future; and / or
29. Any other party to whom you authorise us to disclose your Personal Data.

• When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
• Cookies are small text files placed / stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
• Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

• PNB will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that, for example, no harmful code will enter our website (for example, viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and take any necessary precautions.
• While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
• If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and / or fraudulent use of your username and password.

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

1. You have the right to be informed whether your Personal Data is being, or have been processed, including the existence of automated decision-making and profiling.
2. You have the right to object to the processing of your Personal Data, including processing for direct marketing, automated processing or profiling , except when processing is (i) required pursuant to a lawful order or process, (ii) necessary to complete your transactions with us, or (iii) arising from a legal obligation.
3. You have the right to reasonable access, upon written request, the contents of your Personal Data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
4. You have the right to correct any error in the Personal Data, and if warranted, request immediate rectification.
5. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data from PNB’s system, without prejudice to the processing of Personal Data for operational, legal and regulatory purposes.
6. Where Personal Data is processed by electronic means and in a structured and commonly used format, you have the right to obtain from PNB a copy of such data in an electronic or structured format that is commonly used and allows your further use.
7. You shall be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Data, taking into account any violation of your rights as data subject.
8. You may file a complaint or exercise your rights above by reaching out to us through the contact details provided below. You may also raise privacy concerns to the National Privacy Commission through their website at www.privacy.gov.ph.

Your Personal Data will be retained by PNB throughout the duration of your deposit account, loans, investments and / or until expiration of the retention limit set by PNB, et al standards, industry standards, laws and regulations from account closure and the period set until destruction, disposal or anonymization of records, unless withdrawn in writing or withheld due to changes in the information supplied by you.

• If you have any questions or feedback relating to your Personal Data or our Data Protection Policy; would like to withdraw your consent to the processing, use and disclosure of your Personal Data as set out in this Data Protection Policy; or would like to obtain access and make corrections to your Personal Data records, please email our Data Privacy Officer at pnbdpo@pnb.com.ph.
• Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback and access and correction requests to PNB on your behalf.
• If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, PNB may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with PNB, and your being in breach of your contractual obligations or undertakings, and PNB’s legal rights and remedies in such event are expressly reserved.

This Data Protection Policy and your use of this website shall be governed in all respects by the laws of the Philippines.