1. Introduction
UtangSmartPH ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website utangsmartph.com (the "Site") and use our services.
This policy complies with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and other applicable privacy laws.
2. Information We Collect
2.1 Personal Information
We may collect the following personal information:
- Contact Information: Name, email address
- Communication Data: Messages, comments, or inquiries you send to us
- Newsletter Subscription: Email address when you subscribe to our newsletter
- Download Requests: Name and email when you download free resources
2.2 Automatically Collected Information
We automatically collect certain information when you visit our Site:
- Technical Information: IP address, browser type, device information
- Usage Data: Pages visited, time spent on pages, referring websites
- Cookies and Tracking: Information collected through cookies and similar technologies
3. How We Use Your Information
We use your personal information for the following purposes:
Email Communication
To send you newsletters, updates, and educational content about debt management
Resource Delivery
To provide you with requested free resources like our Debt Management Checklist
Site Improvement
To analyze website usage and improve our content and user experience
Legal Compliance
To comply with applicable laws and respond to legal requests
4. Legal Basis for Processing (Philippines DPA Compliance)
Under the Philippine Data Privacy Act, we process your personal information based on:
- Consent: When you voluntarily provide information (newsletter signup, downloads)
- Legitimate Interest: For website analytics and improvement
- Legal Obligation: When required by Philippine law
- Performance of Contract: To provide requested services and information
5. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:
5.1 Service Providers
- ConvertKit: For email marketing and newsletter management
- Website Hosting: For website hosting and maintenance
- Analytics Services: For website performance analysis (anonymized data)
5.2 Legal Requirements
We may disclose your information when required by:
- Philippine courts or government authorities
- Legal processes, subpoenas, or court orders
- National Privacy Commission (NPC) investigations
- Protection of our rights, property, or safety
6. International Data Transfers
Some of our service providers may be located outside the Philippines. When we transfer your data internationally, we ensure:
- Adequate protection measures are in place
- Service providers comply with data protection standards
- Contractual safeguards protect your information
- Compliance with NPC guidelines on international transfers
7. Your Rights Under Philippine Law
Under the Data Privacy Act of 2012, you have the following rights:
Right to Access
Request information about your personal data we process
Right to Rectification
Request correction of inaccurate or incomplete data
Right to Erasure
Request deletion of your personal data under certain circumstances
Right to Object
Object to processing of your data for specific purposes
Right to Portability
Receive your data in a structured, machine-readable format
Right to Lodge Complaints
File complaints with the National Privacy Commission
To exercise your rights, contact us at: privacy@utangsmartph.com
8. Data Security
We implement appropriate technical and organizational security measures to protect your personal information:
- Encryption: Data transmission is encrypted using SSL/TLS technology
- Access Controls: Limited access to personal data on a need-to-know basis
- Regular Updates: Security measures are regularly reviewed and updated
- Incident Response: Procedures in place for data breach notification as required by law
9. Data Retention
We retain your personal information only as long as necessary for:
- Providing our services and communications
- Complying with legal obligations
- Resolving disputes and enforcing agreements
- Legitimate business purposes
Email subscribers: Data retained until you unsubscribe or request deletion
Website analytics: Anonymized data retained for statistical purposes
10. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to:
- Remember your preferences and settings
- Analyze website traffic and user behavior
- Improve website functionality and performance
- Provide personalized content and advertisements
You can control cookies through your browser settings. For more information, see our Cookie Policy.
11. Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit.
12. Children's Privacy
Our services are intended for adults dealing with financial matters. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make changes:
- We will update the "Last updated" date at the top of this policy
- Significant changes will be communicated via email or website notice
- Continued use of our services constitutes acceptance of changes
14. Data Protection Officer
For data protection matters and privacy concerns, you may contact our Data Protection Officer:
Email: dpo@utangsmartph.com
Response Time: We will respond to your inquiries within 30 days as required by Philippine law
15. Regulatory Information
National Privacy Commission (Philippines)
If you have concerns about our data processing practices, you may file a complaint with:
- Website: privacy.gov.ph
- Email: info@privacy.gov.ph
- Hotline: (+632) 8234-2228
16. Contact Information
For questions about this Privacy Policy or our data practices, please contact us: