PRIVACY POLICY

Effective: October 10, 2025

1. IDENTITY OF SONAK

1.1. "SONAK" or "we" refers to SONAK ASIA PTE. LTD. , a company incorporated and registered in Singapore. We have our branch office address here in the Philippines at the 30th Floor, Parkway Corporate Center, Corporate Ave. corner Parkway Place, Filinvest City, Alabang, Muntinlupa City 1781.

1.2. Under the terms of the Master Service Agreement that we entered into with ABC-Mart Sonak Philippines Inc. (“ASP”), we are vested with the authority to offer and sell ASP Products (“Products”) via digital and e-commerce platforms.

2. APPLICABILITY

2.1. This Privacy Policy details the types of information that SONAK collects, the user or viewer’s options about such information and how SONAK use, share, update and secure such information, in accordance with the Philippine Data Privacy Act of 2012 (the “Data Privacy Act”). This Policy applies to information obtained in connection with SONAK’s operations through its Website, social media presence, emails, marketing campaigns, digital and online advertising.

2.2. All individuals and Customers who use or access this Website, regardless of whether a purchase was made (the “Customer” or “you”), shall be deemed to have accepted and are bound by the provisions of the herein Privacy Policy.

3. CLASSIFICATION OF PERSONAL INFORMATION COLLECTED

3.1. The information that SONAK collects are Personal Information, including the Customer’s name, mailing address, email address, date of birth, credit/debit card information (and related payment information), and/or telephone/cellphone number. SONAK also collect information that identifies you as an individual and other information associated with it.

3.2. SONAK collects these Personal Information through different means, namely:

a. Information Provided by the Customer

SONAK collects the information whenever the Customer:

  • (1) creates an account in the Website
  • (2) makes a purchase;
  • (3) contacts with SONAK as regard regards matters related to customer support
  • (4) participate in Customer research, surveys, sweepstakes or promotions;
  • (5) subscribe for email, text, or other messages from SONAK;
  • (6) download contents of the Website;
  • (7) file a claim or participate in investigations regarding claims or losses; or
  • (8) communicate information to SONAK in any other means.

b. Information that SONAK Receive from Third Parties

SONAK may receive information from third-party sources or sources that help update, improve, and/or analyze records or data, perform marketing and research services or detect online attacks and fraudulent activity.

SONAK also works with third-party service providers for feedbacks about the Website. This includes analytics and general information about browsing patterns to help SONAK improve the Website. Analytics services such as Google Analytics provide services that analyze Customer’s visits to the Website and may use cookies and other tracking mechanisms (to collect personal information).

c. Passively Collected Information

SONAK may collect Customer “User Activity Details” through Cookies and other similar or related technologies. “Cookies” are text files with a limited quantity of data when you visit our Site via your browser.

The collected User Activity Details through the use of these Information Technologies include internet protocol (IP), device information (such as connection type, operating system, your kind of browser & screen resolution), Customer location and Customer user ID. It also collects details on Customer’s other interactions such as webpage visits, keyword searches, and viewed products. It may also include information about the Customer’s mobile device and how Customers search terms and pages that Customer visited within the Website and general Customer use of the Website. SONAK may also associate User Activity Details with the Customer and may identify the Customer’s general location from this information. SONAK will only share Personal Information for the purposes stated in this Privacy Policy, such as service providers. User Information Details collected may be used by SONAK’s marketing department using the personal information collected.

d. Social Media

SONAK engages with its Customers through various social media platforms, including but not limited to Facebook, Instagram, Twitter, and TikTok. When a Customer submits a support request or interacts with SONAK through these platforms, such engagement may result in the collection of the Customer’s Personal Information.

By choosing to access, log in to, or link to any of SONAK’s social media accounts, the Customer grants SONAK permission to access and use information posted or stored on those platforms. This includes, where applicable, the storage of login credentials such as usernames and passwords, in accordance with the Privacy Policy governing the Customer’s account.

Any information shared by the Customer while interacting with SONAK’s social media accounts may also be accessible to the respective platform, and is subject to that platform’s own Privacy Policy. Customers are encouraged to review the applicable Privacy Policies of these social media platforms to understand how their data is managed and to adjust their privacy settings accordingly.

SONAK does not control and shall not be held responsible for the privacy practices of these social media platforms.

4. CUSTOMER OPTIONS

The Customer has several options regarding the collection, use and disclosure of Personal Information through the website:

  • 4.1. Unsubscribe: The Customer may unsubscribe in receiving future marketing or promotional email communications by sending a request to privacy.saph@sonak.com.ph, with the subject line “PERSONAL DATA.” Upon receipt of confirmation that the Customer wishes to withdraw consent for the processing of personal information for marketing or promotional purposes, SONAK shall process the request accordingly. SONAK shall process the request within thirty (30) calendar days. During this period, the Customer may still receive marketing or promotional communications. Even after unsubscribing, SONAK may continue to contact the Customer for purposes related to transactional matters, including but not limited to sales confirmations, shipping notifications, product recalls, product information, service notices, and account maintenance.
  • 4.2. Disabling Cookies: SONAK customizes the Customer’s experience on its Website and social media platforms based on the Customer’s interactions with SONAK and other online activities. Customers may choose to access SONAK’s Website and social media accounts without enabling certain Information Technologies—such as cookies or tracking tools—on their devices. They may also opt to disable or adjust personalized features that are tailored based on browsing history and usage patterns. While Customers may still access the Website and social media accounts with these technologies restricted. However, some Website features or functionalities may be limited. Customers may manage third-party tracking and cookie preferences by adjusting their browser settings or device configurations.
  • 4.3. Location Details: When a Customer visits SONAK’s Website, Information Technologies may collect general location data using the Customer’s IP address, as well as specific location data (such as latitude and longitude) through the Customer’s browser. Customers may choose to restrict the use of specific location data by adjusting their browser settings or declining location access when prompted. However, such restrictions do not prevent SONAK from accessing general location information derived from the Customer’s IP address, which may still be used for operational or analytical purposes.
  • 4.4. Request for Deletion of Personal Records: The Customer has the right to request the deletion or removal of Personal Data by sending an email to privacy.saph@sonak.com.ph, particularly in cases where SONAK no longer has a legitimate reason to continue processing such information.

5. SHARING OF CUSTOMER PERSONAL INFORMATION

  • 5.1. SONAK may, at its discretion, share the Customer’s Personal Information with its affiliates, related entities, business partners, and authorized service providers, provided that such sharing and subsequent processing are undertaken for a legitimate purpose and are aligned with the purposes and use stated in this Privacy Policy, and permitted under applicable law.
  • 5.2. Personal Information of the Customer collected by SONAK shall not be disclosed to unaffiliated third parties or service providers without the Customer’s prior consent, except where such disclosure is authorized or mandated by law.
  • 5.3. SONAK specifically shares the Customer’s Personal Information with the entities identified below, solely in connection with the purposes outlined in the succeeding provisions:
    • a. Providing products or services to our affiliates, subsidiaries, related entities, partners, and service providers for the same purposes as described above;
    • b. Shipping and payment card processors; and
    • c. To comply with legal and regulatory requirements, including law enforcement requests.
  • 5.4. Personal Information collected in connection with SONAK’s Loyalty Program—specifically ABClub, as well as any future loyalty programs—may be disclosed by SONAK to its designated database management providers, namely Sales Force Service Cloud (“SFSC”) and Capillary Technologies (“Capillary”), for secure storage and processing.
  • 5.5. In these cases, SONAK undertakes that Customer’s Personal Information is disclosed on a confidential basis, and always subject to the reasonable disclosure parameters laid down under the Data Privacy Act of 2012, and its implementing rules and regulations.

6. PURPOSE OF COLLECTION AND USE OF CUSTOMER PERSONAL INFORMATION

6.1. The collection of the Customer’s Personal Information by SONAK is intended to support the uses specified hereunder:

  • a. Accomplishing, delivering, and communicating with Customer about requests for details and orders for Products;
  • b. In connection with SONAK’s loyalty programs, including ABCLub;
  • c. Processing payments, returns and other related transactions;
  • d. Conducting surveys, contests or promotions;
  • e. Registering Customer Accounts;
  • f. Providing Customer Service;
  • g. Conducting research and analysis;
  • h. Informing Customer about products and promotional details, including product returns;
  • i. For surveys relative to the enhancement of the products, Website and social media accounts;
  • j. To promote SONAK’s products, as well as those offered by its partners, which may be of interest to the Customer.Protecting the security of our Site; and
  • k. For any other purpose as may otherwise be disclosed at the time of collection.

6.2. SONAK may also process the collected Personal Information of the Customer through the following means:

  • a. Combine the details collected in accordance with the methods previously mentioned;
  • b. Combine certain Personal Information to other details collected online and offline, including information collected from third parties;
  • c. Retain personal information for no longer than two (2) years to offer you products, comply with legal duties, resolve issues, and enforce agreements;
  • d. Collate the information we gather and retain it for no longer than two (2) years within the company and our service providers;
  • e. Process user activity information to relate with your activities on our Site and social media accounts;
  • f. Use your general location information for marketing purposes and monitor our marketing campaigns' effectiveness.

7. SECURITY

SONAK implements a range of security measures to safeguard the Personal Information of its Customers during the processing and maintenance of transactions. The Website utilizes encryption technologies to protect Personal Information transmitted over the internet. In addition, Customer accounts and passwords are secured through restricted access protocols.

8. DATA BREACH

  • 8.1.Customers and potential customers hold SONAK free from liability in case of breach in the database of SFSC or Capillary or any other third party processing the personal information, unless the proximate cause thereof is directly attributable to SONAK due to its gross negligence, willful misconduct, or clear bad faith.
  • 8.2.In case of data breach in SONAK’ s own database, it shall promptly notify the Customers concerned or make an official announcement as regards the fact of the breach. SONAK shall do its best efforts to mitigate the damages resulting from such breach. In relation thereto, customers shall hold SONAK free from liability in case such breach unless the same is due to the gross negligence or evident bad faith of SONAK.
  • 8.3.SSSI shall not be liable for any remote, indirect, incidental, or consequential damages to Customers resulting to the breach.
  • 8.4.In case of actions for damages, Customers agree that the liability of SONAK shall only be limited to the amount that Customers incurred from its transaction with SONAK within the past 12 months.

9. PERSONAL INFORMATION OF PERSONS BELOW 18 OF AGE AND OF INDIVIDUALS INCAPABLE OF GIVING CONSENT

SONAK’s Website is intended for a general audience and is not specifically directed toward children under the age of 18 or individuals who are incapable of giving consent. SONAK does not knowingly collect Personal Information from individuals under 18 years of age or individuals incapable of giving consent without the express consent of a parent or legal guardian. If a parent or guardian believes that SONAK may have collected unauthorized Personal Information from a child under the age of 18, they are encouraged to contact SONAK at privacy.saph@sonak.com.ph to request appropriate action.

10. THIRD-PARTY LINKS

SONAK’s Website and social media accounts may contain links to external websites that are not under SONAK’s control. Customers may also access SONAK’s Website through links or advertisements hosted on third-party sites. In such cases, the originating site may collect information from users who click on those links. These external websites operate under their own privacy policies, which Customers are strongly encouraged to review when visiting such platforms. SONAK does not assume responsibility for the privacy practices or data handling procedures of these third-party sites.

11. CUSTOMER’S ACCESS TO PERSONAL INFORMATION

Under the Data Privacy Act, Customers have the right to be informed, to access and correct their Personal Information, to object to its processing, to data portability, to erasure or blocking, to file a complaint, and to claim damages for any violation of their rights. If the Customer wishes to access their Personal Information held by SONAK, or believes that such information is incomplete, outdated, or inaccurate, or has any questions or concerns regarding SONAK’s Privacy Policy, they may contact privacy.saph@sonak.com.ph for assistance.

12. UPDATES

SONAK may update or revise this Privacy Policy from time to time. Customers are encouraged to review the Policy periodically for any changes. In the event of a material modification that may affect the Customer’s rights or the way Personal Information is used, SONAK will provide notice at least 30 days prior to the effective date of such changes.

If a Customer does not agree with the revised terms, they may discontinue use of the Website and/or request account cancellation by contacting privacy.saph@sonak.com.ph.

 
ABC-MART DPO
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