PRIVACY POLICY

OVERVIEW

Thank you for your interest in registering to MOK Rewards and the MOK and COO products we offer. The protection of personal data and the responsible handling of information that you entrust to us are very important and of special concern to us. 

20 S INC.  ( “20 S”, “we”, “us”) acts as a data controller of the information collected on this website via the MOK Rewards, and processes personal data only in accordance with Republic Act No. 10173 or the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (“IRR”), and other relevant issuances of the National Privacy Commission (collectively “Philippine Privacy Regulations”). We also adhere to the general principles of transparency, legitimate purpose, and proportionality when we process your personal data.  This Privacy Policy explains how we process personal data that we collect during your visit to this website and how it is used.

1. RELEVANT DETAILS OF THE PERSONAL INFORMATION CONTROLLER

20 S controls the personal data collected when you purchase from the MOK website and when you sign up and sign in for MOK Rewards. 20 S is a corporation registered under the laws of the Philippines and is based at Unit 2701, Trade and Financial Tower, 7^th Ave. Corner 32^nd St., Bonifacio Global City, Taguig City, Philippines.

Email: [email protected]
Contact Number: (02)7006-0115

2. TYPES OF INFORMATION COLLECTED ABOUT YOU ON THE WEBSITE

Depending on how you use our offers or this website (registration for the MOK Rewards and subscription for email and SMS blasts, exchange of correspondence with us, purchase of our products through the MOK Webstore, registration for customer surveys, participation in campaigns, etc.), we may collect the following personal data about you:

• First and Last Name
• Email address
• Phone/mobile number and password
• Address
• Date of birth
• When absolutely necessary, a Copy of your identification documents (national voter ID card, and/or passport, and/or social security ID card, and/or driver’s license)
• Gender
•  Shopping information about your request/purchase
• Data from website usage, such as IP address or browser specifications
• Answers to customer surveys
• Product-related information for purchases
• Account details and other bank and payment details
• Information on processing the order

3. PURPOSES OF PROCESSING

We process your personal data input via the MOK Rewards Registration page, to market our products and to process sales, including payment processing, in order to offer you sales-related services, including processing your inquiries and requests and providing guarantees in order to provide you with the relevant information and offers relating to MOK and COO products, as well as to be able to supply other products, and to better understand your wishes and preferences.

Depending on how you use our offers and this website, the justification for processing your personal data results from your consent, from the need to fulfill contractual obligations or from our legitimate interest in the presentation of our company and the products we offer.

For the use of this website, the processing of personal data is necessary, especially in respect of age verification. This website can generally be used without providing any personal data. If you would like to use other functionalities (e.g. ordering products or support inquiries), this may only be possible if you provide us with your personal data. The provision of personal data is then also fundamentally voluntary. However, you may not be able to use the website or individual functions of it if you do not provide the relevant personal data to us.

The following table further explains specific purpose(s) for which we collect your personal data as well as informs you of the scope of processing of such personal data: 

PERSONAL DATA	PURPOSE
First and Last Name	User/ account registration, marketing purposes
Email address and password	User/ account registration, marketing purposes
Phone/mobile number	User/ account registration, marketing purposes
Address	To place and deliver the order, marketing purposes
Date of birth	User/ account registration, Age verification, marketing purposes
Copy of your identification documents (national voter ID card, and/or passport, and/or social security ID card, and/or driver’s license)	User/ account registration, Age verification
Gender	User/ account registration, marketing purposes
Shopping information about your request / purchase	To place and deliver order, marketing purposes
Data from website usage, such as pages viewed, duration	To improve user experience on website, statistical purposes
Answers to customer surveys	For marketing purposes
Account details and other bank and payment detail	To place and confirm order
Information on processing the order	Delivery of order
Third party social network information (Facebook, Google) used for login	User/ account registration

4. SCOPE AND METHOD OF PROCESSING

In general, any personal data collected on this website will be stored in a third-party service provider’s cloud database located in the Philippines. The safety and security of your personal data is of utmost importance to us, it is stored and processed in confidential manner and in compliance with applicable laws by such third-party service provider. More specific processes are described in succeeding sections of this Notice, such as marketing and analytics.

5. AUTOMATED DECISION-MAKING

We may make automated decisions about you based on your personal information to select personalized offers, discounts or recommendations to send you based on your browsing history, website browsing history, purchase order history and other information you provide to us. None of these automated decisions will have a legal or other significant effect on you.

6. AGE VERIFICATION

The contents of this website are for people aged 18 or over. Failing age verification will mean you cannot register/purchase on the website.

In order to enable us to verify your age, we may require you to provide us with your date of birth and a copy of appropriate identification document (national voter ID card, and/or passport, and/or social security ID card, and/or driver’s license). This will then be used by us, or through a third party service provider, to confirm that you are aged 18 years or over, and to guarantee that you are 18 years old and that we do not breach our legal obligations by advertising to minors on our website.

In some cases, we may need to ask for further information in order to verify your age. If this is necessary, we will contact you to explain why.

Copy of your identification documents (national voter ID card, and/or passport, and/or social security ID card, and/or driver’s license) will be automatically deleted as soon as verification process is completed, which usually takes a few minutes to 12 hours, to complete after submission by you of a copy of your identification document unless a query is raised over the authenticity or validity of the identification document submitted by you.

7. USE OF NON-PERSONAL INFORMATION

We may monitor your use of the website and record your email address and/or IP address, operating system, and browser type for system administration and to report aggregated information to our advertising partners. The information we report to our partners is statistical information about our users’ browsing actions and patterns which does not identify any individual.

We collect non-personal aggregated statistics data about visitors to the website and traffic patterns. This information does not identify users in any personal capacity and we do not use this information to build profiles on individual users: it just contains generalized information about the users of the website.

8. COOKIE POLICY

When you visit our website, it may store or retrieve information on your browser, mostly in the form of cookies. Some are essential, while others are used to enhance your experience, and to operate and improve the website. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can configure the browser settings and deactivate the setting of cookies, accordingly, in whole or in part. In addition, you can install a plug-in in your browser to protect your privacy, which offers the possibility of preventing web analysis – e.g. AdBlock, Ghostery or NoScript (see the data protection information of the respective plug-in provider). Furthermore, some web analysis providers are members of industry associations, through whose websites you can centrally prevent usage-based online advertising and web analysis by the respective members. Below you will find the websites of these associations for a convenient cross-provider prevention of web analysis. You can also prevent the creation of pseudonymous user profiles in this way:

• “Digital Advertising Alliance” (DAA): info / choices /
• “Network Advertising Initiative” (NAI): http://www.networkadvertising.org/choices/

Cookies can be differentiated according to the following characteristics:

• Necessity: Some cookies are required to guarantee the technical functionality of the website (e.g. to save the language setting, for a shopping cart function or to avoid multiple logins during a session). Other cookies are not required for this, but serve other purposes, for example to make the use of the website as pleasant as possible, to design it in line with your interests or to carry out a web analysis.
• Storage period: Some cookies are only stored on your device during your respective visit to our website (session cookies), other cookies are stored for a longer period (persistent cookies).
• First-party cookies and third-party cookies: When you visit a website, cookies can be set by the website operator (first-party cookies), but also by third-party providers (third-party cookies).

10. GOOGLE ANALYTICS

This website uses Google Analytics, a web analysis service provided by Google LLC., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies to enable your use of the website to be analyzed. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thus anonymized. The full IP address is only transmitted to a Google server in the USA and shortened there in exceptional cases. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. 

To prevent the use of Google Analytics and to pass on your data (including your IP address) to Google, you can download a browser plug-in at the following address https://tools.google.com/dlpage/gaoptout?hl=en . Alternatively, you can prevent Google Analytics from collecting data by setting a so-called “anti-tracking cookie” on your computer.

Further information on data protection with Google Analytics can be found at: https://www.google.de/intl/de/policies/.

11. THIRD PARTY SERVICES AND WEBSITES

Our website may provide links to other websites and services (including apps operated by third parties) for your convenience and information. These services and websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review before you use any of their services or conduct any activities on those websites. To the extent that any linked websites you visit are not owned or controlled by us, we will not be responsible for their contents, their privacy practices and the quality of their services.

12. SOCIAL NETWORKS AND EMBEDDED YOUTUBE VIDEOS

Our website contains links to social networks such as but not limited to Facebook and Viber, as well as embedded videos from the streaming services such as but not limited to Vimeo and Youtube. These services are operated exclusively by third parties. If you follow the links or play videos, information may be transmitted to these third parties.  The purpose and scope of the data collection and the further processing and use of the data by the service provider as well as your related rights and setting options to protect your privacy can be found in the data protection information of the respective service provider.

13. DISCLOSURE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

We use third parties for certain data processing activities. Your personal data held by us will be kept confidential but we may provide such information to the following third parties (whether within or outside Philippines):

• United Castle International Co., Ltd.
• China Tobacco Hubei Industrial Co., Ltd. 
• GH – Prime Goods Corp. 
• Truelogic Inc.
• Megamobile Inc.
• Lalamove
• Any agent, contractor, subcontractor or third party service provider that we work with in providing you with our services, including for fraud prevention, bill collection, data entry, database management, promotions, marketing, distribution, customer service, technology services, products and services alerts and payment extension services.
• Merchants and other organizations, such as card associations, payment networks or financial institutions, IT providers, platform operator, or companies to whom or through which payments are made. Where we have an appropriate data processing agreement (or similar protections) in place.
• Third party financial institutions, banks, collection agents, and credit agencies.
• Professional advisers, law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which 20 S is under an obligation to make disclosures under the requirements of any applicable law, regulation or commercial arrangement, including arrangements with any card association or payment network.
• Other third parties which carry out market analysis and processing of data, statistical or targeted, on products for sale, defining promotional activities or offers.

Third parties who deal with such activities have been carefully selected, are experienced, capable and trusted regarding their compliance with current laws and regulations governing the processing of data, including the security profile of such personal information.

We have appointed such third parties as data controllers or have in any case expressly authorized them to the processing described in this Privacy Policy.

We will periodically verify that third parties perform their respective duties and comply with personal information protection measures.

At your request, we will notify you by email of the updated list of persons authorized to process them.   

Please note that the countries where your personal data may be processed may not have the same data protection laws as the laws of your country of residence (i.e. Philippines).

14. RETENTION AND DELETION

We will keep your information relating to orders you have placed with us as required by law or other regulation (for example, because of a request by a tax authority or in connection with any anticipated litigation).

We delete your personal data as soon as they are no longer required for the purposes for which they were processed and provided that there are no statutory retention requirements.

15. YOUR RIGHTS

You can request information about the data stored about you by 20 S at any time free of charge. You can request us to correct any inaccuracy or error in your personal data, except when your request becomes vexatious or is unreasonable.

You can also object to our processing of your personal data, including processing for direct marketing or automated processing by emailing us at [email protected]. When you object to processing of your data, we will no longer process your personal data, unless: (a) the personal data is needed pursuant to a subpoena; (b) it remains necessary to allow us to perform a contract or service we have agreed with you; (c) or when the information is being collected and processed as a result of a legal obligation. Whether and to what extent these rights exist in individual cases and what conditions apply to them is determined by the law. Philippine Privacy Regulations also grant you the right to data portability under certain circumstances.  You also have the right to lodge a complaint with the responsible data protection supervisory authority. However, if you have any questions or complaints about data protection at 20 S, we recommend that you first contact our Data Protection Officer (contact details provided in section 1 of this Privacy Policy).

To exercise these rights and for other questions about data protection, please contact our company Data Protection Officer. In order to process your request quickly, we recommend that you provide us with your surname, first name, date of birth and, if available, your email address and, if you object, send a copy of the advertising material after receiving advertising.

16. CONTACT OPTIONS

You can find our contact details as the responsible body under section 1 of this Privacy Policy.

17. CONTACT THE DATA PROTECTION OFFICER TO EXERCISE YOUR RIGHTS

If you would like to exercise your data subject rights or have questions about data protection with us or this policy, you can also  contact us directly by email at [email protected]  or by phone at (02)7006-0115

18. CHANGES TO THE PRIVACY POLICY

New legal requirements, business decisions or technical developments may require changes to our Privacy Policy. This Privacy Policy will then be adapted accordingly. We will notify you in case there are changes to the Privacy Policy which affects the consent you have provided. We will, in such case, give you the opportunity to renew or withhold your consent. You can always find the latest version on our website.