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Data Protection & Privacy Policy

This privacy statement is effective as of January 18, 2025. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

Introduction

BluChaos Inc. ("BluChaos", "We") values your privacy and is committed to protecting your personal data. This Privacy Statement outlines our approach to handling and safeguarding the personal information we collect, use, and share during our business operations.

How Do We Collect Personal Data?

We collect personal data through multiple channels to deliver our services effectively and to communicate with you. We collect personal data of our employees, potential employees, clients and their current/former/prospective employees/directors, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. Our methods of data collection include:

  • Direct Interactions: This occurs when you voluntarily provide personal data through various means, such as filling out forms on our website, participating in surveys, or communicating with us via email, phone, or in person. Direct interactions may involve providing your contact details, professional information, and any other personal information necessary for us to provide you with our services or respond to your inquiries.

  • Indirect Interactions: We may also collect personal data indirectly through your use of our website and mobile applications. This can include data collected through cookies and similar technologies, which track your browsing behavior, device information, and interactions with our digital platforms. These technologies help us understand how you use our services and allow us to enhance your user experience.

Categories of Personal Data Collected

The personal data we collect can be categorized as follows:

  • Personal details, contact details, and identifiers: Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.

  • Commercial information: History and records of the products and services you have obtained from Accenture. Correspondence between you and us when it is sent to a dedicated mailbox or via other electronic communication means (including communication channels supported by AI that – for example - generates content to assist our personnel when interacting with you), for the purpose of processing account receivable payments and commercial follow-up.

  • Marketing and research information:

  1. Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address

  2. Demographic data - (e.g. income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers)

  3. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system.

  4. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual

  5. Analytics and profiles of the individuals based on the data collected on them

  6. Voice-enabled services (Speech-to-Text engines for search requests) without being recorded or stored by the mobile device.

  • Sensitive data and biometric information: BluChaos may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status/access requirements and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.

  • Audiovisual materials, including transcriptions: Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security/monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions), voice search functionality to enable a voice command feature that allows you to ask a question and see results (functionality enabled for mobile applications only), and/or audio video recording and transcription during meetings.

  • Position and professional or employment-related information: Professional or employment-related information, such as description of current position, job title, employer, location, and Accenture contact(s).

  • System and application access data and Internet and electronic network activity information: Where you are provided with access to BluChaos’ systems, BluChaos may collect information required to access such BluChaos systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using BluChaos systems.

  • Cookies and geolocation data: As described below, we also may collect geolocation data in some circumstances. Please see our Cookies policy for more details regarding our use of cookies.

In addition, for recruitment/employment purposes and to provide assessment and consultancy services to our clients, BluChaos may process the personal information set out below:

  • Additional personal details, contact details and identifiers/demographics: In addition to the personal details listed above, Accenture may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history; professional/personal calendar availability/scheduling information for meeting/communication purposes.

  • Education information and professional or employment-related information: BluChaos may collect information about your education and professional or employment-related information, such as your employment history.

  • Sensitive data for recruitment purposes or for providing assessment/consultancy services: BluChaos may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. Accenture collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.

  • Documentation required under immigration laws: BluChaos may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).

  • Financial information for payroll/benefits purposes: Your banking and other relevant financial details we need for payroll/benefits purposes.

  • Talent management information: Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.

  • Requested recruitment information: Information requested to provide during the recruitment process, to the extent allowed by applicable law.

  • Recruitment information you submit: Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).

  • Information generated by us during recruitment or during assessments: Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.

  • Recruitment information received from third parties: Information related to you provided by third-party placement firms, recruiters, or job-search websites, clients where applicable.

  • Audiovisual materials: Photograph, , and images/audio/footage captured/recorded on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews or during any other virtual and live events (including recordings during virtual workshops or similar events).

  • Recommendations: Recommendations related information provided on your behalf by others.

  • Immigration: Documentation and related information required under immigration laws.

  • Employment history and background checks: Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.

  • Diversity related information: Information about race, ethnicity, religion,  disability, gender (legal and identity) and/or sexual orientation, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the candidate pool and workforce and undertake analytics, subject to legal limits and consent where applicable.

  • Assessment information: Information generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

Except for certain information that is required by law or by BluChaos policies (including management of an employment relationship with BluChaos), your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with BluChaos.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients and vendors. Except where certain information is required by law or by BluChaos policies (including management of an employment relationship with BluChaos), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

Sources of Personal Data

We obtain personal data from various sources:

  • Publicly Available Sources: This includes information available on social media platforms, public records, and other online sources. We may use this information to reach out to potential clients or partners and to ensure our records are up to date.

  • Business Contacts and Interactions: Personal data may be obtained from our business relationships, including clients, partners, and third-party service providers. This data helps us manage and improve our business interactions and service delivery.

Purpose of Data Processing

Your personal data is processed for the following purposes:

  • Service Provision and Management: We use your personal data to provide and manage our services, including account management, customer support, and service customization. This ensures we can deliver the services you have requested and respond to any issues or inquiries.

  • Marketing and Communication: Your data is used to send you promotional materials, updates, and information about our services. We may tailor these communications based on your preferences and interactions with our services.

  • Legal and Regulatory Compliance: We process personal data to comply with legal obligations and regulatory requirements. This includes maintaining accurate records, reporting data breaches, and fulfilling contractual obligations.

  • Internal Analysis and Improvement: Personal data is used to analyze and improve our services, website performance, and overall user experience. This includes conducting research, analyzing trends, and making necessary adjustments to enhance our offerings.

Data Retention

We retain your personal data for the duration necessary to fulfill the purposes for which it was collected, including:

  • Active Account or Relationship: We retain personal data as long as you have an active account or ongoing relationship with us. This allows us to provide continuous service and support.

  • Legal and Contractual Compliance: We keep data to meet legal and contractual obligations, including record-keeping requirements and regulatory compliance.

  • Data Deletion: Once the data is no longer required for the purposes for which it was collected, we will delete or anonymize it in accordance with our data retention policies and procedures.

Rights Regarding Your Personal Data

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in Republic Act 10173 - Data Privacy Act of 2012 and applicable laws) to:

  • Access: You have the right to request access to the personal data we hold about you. This allows you to review the information we have and understand how it is being used.

  • Rectification: You can request correction of any inaccurate or incomplete data. This ensures that the information we hold is accurate and up to date.

  • Erasure: You have the right to request deletion of your personal data when it is no longer necessary for the purposes for which it was collected. This includes cases where you withdraw your consent or object to processing.

  • Restriction: You can request restriction of processing under certain conditions. This allows you to limit the use of your data while disputes or corrections are being addressed.

  • Portability: You have the right to request a copy of your data in a structured, machine-readable format. You can also request that we transfer this data to another data controller if applicable.

Marketing Communications

We may send targeted e-mails and push notifications based on your interests and interactions. You can manage your preferences and opt out of marketing communications at any time by:

  • Adapting Preferences: Updating your contact, content, and data preferences in the Accenture Preference Center or equivalent platform.

  • Opt-Out Mechanisms: Using opt-out options provided in marketing e-mails or notifications to stop receiving further communications.

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website. These technologies collect data about your browsing behavior and device information to:

  • Analyze Website Usage: We use cookies to understand how users interact with our website and to identify areas for improvement.

  • Improve User Experience: Cookies help us tailor our website content and functionality to better meet your needs and preferences.

  • Manage Advertising: Cookies and tracking technologies allow us to deliver relevant advertising and track the effectiveness of our marketing campaigns.

For more details on our use of cookies, please refer to our Cookies Policy, which includes information on your choices regarding advertising and social media cookies.

Data Protection in Offices

When you visit our offices, we process personal data to ensure security and manage visitor information. This includes:

  • Visitor Data: We collect personal data related to your visit for security and administrative purposes.

  • CCTV: We may use CCTV in our offices for security purposes. Specific information about CCTV usage and data protection measures is provided in the reception area.

Content Creation and Production

For content creation and production activities, such as TV, film, and marketing, we may process personal data including:

  • Images and Footage: We may collect and use images and footage of you as part of our content creation activities.

  • Filming Information: If you are a focus of our filming activities, we will collect additional personal details such as your name, contact information, and responses to pre-filming questionnaires.

  • Special Categories of Data: In some cases, we may collect special categories of data, such as health or disability information, to accommodate any necessary adjustments for filming.

If you have any questions about data privacy related to our content creation activities, please contact us for more information.

Contact Us

If you have any questions about how we protect your personal data, wish to exercise your rights, or need to make a complaint, please contact our Data Privacy Officer at:

Data Privacy Officer

dpo@bluchaos.com

 

BluChaos Inc.

Mandaluyong, 1552 PHL

 

For inquiries related to data privacy, please reach out to us electronically or via letter, clearly marked for the attention of the Data Privacy Officer.

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