General Milling Corporation (GMC) is committed to protecting the privacy and confidentiality of your personal data in accordance with the Philippine Data Privacy Act of 2012 (RA 10173) (“DPA”), its implementing rules and regulations, and other applicable data protection laws. This Data Privacy Disclaimer explains how we collect, use, store, protect, and share your personal data when you access and use our Corporate Website (www.genmil.com.ph).

By using the “Contact Us” feature of our website, you agree to the collection and use of your personal data in accordance with this Disclaimer.

1. Personal Data Collection

We collect personal data for the following purposes:

• Inquisition Data: First name, last name, email address, and location provided during registration.
• Document Data: Personal information and metadata contained within documents uploaded, stored, or processed in the website.
• Usage Data: Information on how you interact with the platform, such as IP address, login times, and activities performed within the website.

We will only collect the basic personal data required to conduct business with you.

We may also collect other information with your consent or as required by applicable laws.

2. Purpose of Data Processing

We process your personal data for the following purposes:

• To respond to your inquiry, provide assistance, or deliver relevant information about our products and services.
• To provide, maintain, and improve the website.
• To ensure the security and integrity of the platform.
• To verify your identity and manage your account.
• To comply with legal and regulatory requirements.
• For other legitimate business purposes, as permitted by law.

3. Data Retention

We retain the personal information you provide, including inquisition data submitted through our Contact Us form, only for as long as necessary to fulfil the purpose for which it was collected, comply with legal obligations, resolve disputes, or enforce our agreements.

Once your information is no longer required, we will securely delete or anonymize it in accordance with applicable data privacy laws.

You may also request the deletion or removal of your personal data at any time by contacting our DPO using the contact details in Section 10.

4. Data Security

We implement reasonable technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, firewalls, and regular security audits. However, no method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

5. Sharing and Disclosure of Personal Data

We do not sell, trade, or rent your personal information to third parties. The personal data you provide through our Contact Us form, including your name, contact details, and message content, may only be shared in the following circumstances:

• Service Providers: We may share your data with trusted service providers who perform functions on our behalf, such as IT support, customer service, or email communication. These providers are contractually obligated to keep your data confidential and use it only for the purposes we specify.
• Legal Obligations: We may disclose your personal data if required by law, regulation, legal process, or governmental request.
• Protection of Rights: We may share your information when necessary to protect our rights, property, or safety, or that of our users or others.

We implement reasonable measures to ensure that any sharing of your personal data is secure and limited to what is necessary for the stated purpose.

6. Rights of Data Subjects

Under the Philippine Data Privacy Act, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data.
• Right to Erasure: You may request that we delete your personal data, subject to legal retention requirements.
• Right to Restriction of Processing: You may request the restriction of processing your personal data under certain circumstances.
• Right to Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to the processing of your personal data for legitimate interests, direct marketing, or other specific purposes.

To exercise these rights, please contact us using the contact details in Section 10.

7. Photo and Video Sharing for Company Activities and Events

• Collection and Use of Photos/Videos
  The Company may capture photos and videos during official activities, events, trainings, and gatherings for documentation and communication purposes. These materials may be used for internal communications, official publications, and external platforms such as social media, websites, and other similar channels.

All collection, use, storage, and sharing of photos and videos shall comply with the Data Privacy Act of 2012

(DPA), its Implementing Rules and Regulations, and relevant NPC advisories.

• Consent of Participants
  By participating in Company activities or events, employees, guests, and stakeholders acknowledge that photos or videos may be taken. GMC shall ensure that reasonable notice is given before or during the event.
  Explicit consent shall be obtained for close-up or individual shots, or when featuring a specific employee or guest in a focused manner.
• Respect for Privacy and Opt-Out Requests

Employees and participants who prefer not to appear in photos or videos may inform the event organizer in advance or during the event. GMC will take reasonable steps to accommodate such requests, including designating photo-free zones or excluding individuals from focused shots.

• Responsible Sharing and Posting
  Only authorized personnel may post, upload, or distribute Company-related photos or videos on social media or any external platform. All posts must uphold GMC’s values, confidentiality requirements, and brand guidelines.
  Sharing of photos/videos that reveal confidential information, sensitive operations, restricted areas, or personal data of others without consent is strictly prohibited.

Employees must exercise caution and respect the privacy of others when sharing photos or videos of GMC events on   their personal social media accounts or any external platform.

• Employees shall not upload or share photos/videos that show other employees, guests, or individuals without their consent, especially in cases where the person is clearly identifiable.
• Employees must ensure that posted photos do not inadvertently disclose confidential information, sensitive operations, or proprietary areas of the company.
• Any complaints related to unauthorized posting may be subject to investigation and appropriate disciplinary action.
• Data Protection and Retention
  Captured media will be stored securely by GMC and retained only for as long as necessary for the purposes stated. Access will be limited to authorized personnel.
• Rights of Data Subjects
  Employees and participants may request the removal of their identifiable photos or videos posted on company platforms by submitting a request to the Data Protection Officer (DPO). GMC will act on such requests within a reasonable period, in accordance with applicable data privacy laws.

8. Cookies and Tracking Technologies

Our website may use cookies, web beacons, and other tracking technologies to enhance your browsing experience, analyze website traffic, and improve our services. These technologies may collect information such as your IP address, browser type, operating system, pages visited, and time spent on the site.

You have the option to disable cookies through your browser settings, but please note that some parts of the website may not function properly if cookies are disabled.

9. Updates to This Disclaimer

We may update this Data Privacy Disclaimer from time to time. Any changes will be communicated to you through the website or via email. We encourage you to review this Disclaimer periodically to stay informed about how we are protecting your personal data.

10. Contact Information

If you have any questions, concerns, or requests regarding this Data Privacy Disclaimer, or if you wish to exercise your data privacy rights, please contact our Data Protection Officer (DPO) at:

• Email Address: dpo@genmil.com.ph
• Phone Number: (032) 340-8888
• Address: M.L. Quezon National Highway, Pajo, Lapu-Lapu City, Cebu, Philippines 6015

By using the ‘Contact Us’ feature of our corporate website, you acknowledge that you have read and understood this Data Privacy Disclaimer and consent to the processing of your personal data as described herein.