Privacy Notice

Ayala Land Hospitality comprised of its hotel and resorts entities (collectively referred to as the "Company") respects your privacy and is committed to protecting your personal data. We strive to provide a safe, secure online experience and ensure that we comply with the Data Privacy Act of 2012 ("DPA"). Here's how we protect your personal data and respect your privacy:

Our role in your privacy

When you visit our Company website and use its functionalities, (collectively referred to as "Site"), this notice applies to you. Please read and understand it before providing us with your personal data.

All capitalized terms used herein shall have the meanings ascribed to them under the DPA and its Implementing Rules and Regulations, unless otherwise defined in this Notice.

Milette Asuncion-Arnedo is our Data Protection Officer. You can reach her via dataprivacy@ayalalandhospitality.com.

Your responsibilities

• Read and understand this Privacy Notice.
• Ensure that any information that you provide us is complete, accurate and up-to-date.
• When you provide us with Personal Data about other people, you warrant and confirm that you have the right to authorize us to process it on their behalf in accordance with this Privacy Notice.

When and how we collect data

From the first moment you interact through our website, we are collecting data. Here's when and how we collect data:

• You browse any page of our website or app
• You interact with us through the "Contact Us" form, "Events or MICE Inquiry" form, "Newsletter Subscription" form, "Get a Quote/Travel Inquiry" form.
• You make an online reservation and payment.
• You participate in the Guest Loyalty Program.
• You opt-in to our Marketing communications.

Types of data we collect

When you inquire about our products and service in this website through Contact Us, Events or MICE Inquiry, Newsletter Subscription, Get a Quote/Travel Inquiry form or Check-out your booking, the Company collects and processes the following personal information that you provide:

Contact Details

Your name, telephone number, email address

Financial information

Credit card details

Data that identifies you

Your IP address, browser type and version, time zone setting, browser plug-ins, geolocation information about where you might be, operating system and version, etc.

Data on how you use our website

Your URL clickstreams (the path you take through our site) products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.

What about really sensitive data?

We don't collect any "sensitive data" about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when we have your specific consent, or when we have to comply with the law.

Other data

Any other information that you voluntarily decide to share with the Company

Disclosing Personal Information Other Than Yours

When you disclose to us personal information of another person (e.g., your dependent, spouse, children, and/or parents), you attest that such information is accurate and that consent has been obtained from that person to disclose and process his/her personal information in accordance with this privacy notice. If the Personal Information was provided by a minor or one who is not legally capable of entering into contractual transactions without parental or guardian consent, the parent or legal guardian shall be responsible in providing the consent, and in correcting any information given or informing us that the information should be disregarded or deleted.

How and Why, We Use Your Personal Data

Under the DPA, we can only use your Personal Data for certain specified purposes and where we have a legal basis to do so. Here are the reasons for which we process your data:

To provide you with the following services

• Responding to your inquiries and communicating with you;
• Processing your hotel reservations;
• Managing your bookings;
• Providing you personalized and customized service when you stay with any of our properties;
• Facilitating your payments; and
• Establishing and fulfilling our contract with you

To improve Your Experience when using our site

• Improving the layout and/or content of the Site, and customizing them according to your interests and preferences;
• Traffic optimization and data analysis and research;
• Monitoring and enforcing compliance with our Terms of Use; and
• Notifying you of service issues and unusual account actions when using our Site, should any occur.

Provide Customer Support

• Notifying you of any changes to our service; and
• Answering your queries/feedback as well as resolving issues (including any bug fixing) via email or mobile.
• Communicating with you regarding your online booking

To enable our business and pursue our legitimate interests

• Improving and protecting our products, content, services and websites, both online and offline;
• Monitoring our Services to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable laws; Investigating any complaints that we receive;
• Complying with applicable law and regulations; and
• Inviting you to take part in market research, if any

Marketing Communications

• Sending you emails and notifications about new products and services, and content; and
• Inviting you to participate in surveys, promotions and other marketing initiatives.

You can change your mind!

If you have previously given consent to our processing your data you can freely withdraw such consent at any time. You can do this by emailing us at dataprivacy@ayalalandhospitality.com.

You have the right to access information we hold about you

If the personal information that we hold about your needs to be corrected or updated, the Company shall make all reasonable efforts to ensure that data collected is current, complete and accurate. If you need to access, correct and/or update your personal information, you may send the request to dataprivacy@ayalalandhospitality.com.

As part of our security measures, we will contact you and conduct the necessary verification measures to process your request. Once we have implemented the necessary corrections, we shall then notify you that your request has been processed and completed.

You can object to us using your data for profiling you or making automated decisions about you

You can object to our Company processing your personal information. Such a request is subject to certain conditions.

You have the right to port your data

We will give you a copy of your data in a mutually acceptable format. We will not do so to the extent that this involves disclosing data about any other individual.

You have the right for your data to be erased

You can do this by asking us to suspend, withdraw, remove or destroy your personal data, if it is no longer necessary for us to hold the data for purposes of your use of our products and services. Such a request is subject to certain conditions.

You have the right to file a complaint regarding our use of your data

Our lines of communication are always open, and we continuously strive to do better in protecting your personal data and respecting your privacy. For any concern or complaint, please reach out to us first so we have a chance to address it. If we fail to address your concern, you may seek the assistance of the National Privacy Commission.

You have the right to damages

You have the right to damages arising from inaccurate, incomplete, false, unlawfully obtained or unauthorized use of your personal data by the Company.

How secure is the data we collect?

When you submit information to our Site, whether it is your name or email or other contact information, we do our best to ensure that information is protected against loss, misuse, alteration, destruction or unauthorized access. We have physical, electronic, and managerial procedures to safeguard and secure the information we collect.

We employ the following practices to secure access to your personal information

• Apply security standards on website development and hosting.
• We use of secured servers behind advanced threat protection appliances, firewalls, encryption and other security tools.
• We use standard encryption tools such as SSL (Secure Socket Layer) to help protect personal information and to keep information collected secure.
• Our website undergoes website security testing conducted by a third party prior to it being launched and when major changes has been applied.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

How long do we store your data?

Whenever you provide information through Contact Us, Events MICE Inquiry, Newsletter Subscription or Check-out your booking, we retain said information for one (1) year from the fulfillment of the declared purposes or for such longer period as may be required by applicable law. We may also retain your Personal Information for as long as it remains relevant to any ongoing or prospective legal proceedings, or as necessary to establish, exercise, or defend our legal rights (including sharing information with others for purposes of fraud prevention and credit risk reduction).

Thereafter, your personal information shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public. Specifically, all personal data in electronic form will be deleted from our databases, following the retention period stated above.

Third parties who process your data

In order to fulfill the purposes outlined in this Privacy Notice, we may disclose your personal data to the following parties:

• Our employees and officers;
• Professional advisers such as lawyers and auditors;
• Insurers and credit providers;
• Authorized third-party services providers including administration processors, technology partners, payment processors and courier services; Banks, credit card companies and their respective service providers as covered by our contracts;
• Our joint venture and alliance partners; and
• Such other party whom you authorize us to disclose your Personal information.

And in order to comply with legal and statutory compliance, we may disclose your personal data:

• To the extent that we are required to do so by applicable laws, rules, and regulations;
• In connection with any ongoing or prospective legal proceeding;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of such personal information where, in our reasonable opinion, such court or authority would be reasonably and is likely to order the disclosure of such personal information

Any company with which we share information about you for the above purposes is contractually required to comply with confidentiality standards, undertake to respect any individual's right to privacy, and comply with the Data Privacy Act. We also require that these organizations use this information only for our purposes and follow our reasonable directions with respect to this information. This includes organizations which handle or obtain personal data as service providers for our Company, Seda Hotels, El Nido Resorts or Ayala Land.

Privacy Policies of Third-party Websites and Digital Platforms

Our website/application contains hyperlinks and details of third-party websites or digital platforms. We have no control over and are not responsible for, the privacy policies and practices of third parties. We, therefore, advise you to study their privacy policies and use of cookies. Once you leave our website/application, you should check the third-party website's applicable privacy notice to determine how they will handle any information they collect from you.

Cookies

Like most websites, ours uses cookies and other similar technologies, such as local storage, to provide you with a better and more personal user experience. These cookies are safe and secure, and do not contain sensitive information. Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with our website.

How can I block cookies?

You can block cookies by activating a setting on your browser so that cookies are not accepted. You can also delete cookies through your browser settings. Each browser's website should contain instructions on how you can do this.

If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies, we have no control over how those third parties use those cookies.

How to Contact Us

Thank you for reaching the end of our Privacy Notice! Should you have any suggestions or questions about this Privacy Notice, including any requests to exercise your legal rights regarding data you share with us, please contact:

Full name of legal entities:

AyalaLand Hotels and Resorts Corporation doing business as Ayala Land Hospitality

BONIFACIO HOTEL VENTURES, INC.

Seda BGC

BAY AREA HOTEL VENTURES, INC.

Seda Manila Bay

CAPITOL CENTRAL HOTEL VENTURES, INC.

Seda Capitol Central

CENTRAL BLOC HOTEL VENTURES, INC.

Seda Central Bloc Cebu

CEBU INSULAR HOTEL COMPANY., INC.

Seda Ayala Center Cebu

ECONORTH RESORTS VENTURES, INC.

Seda Lio

ECOSOUTH HOTEL VENTURES INC

Seda Nuvali

MAKATI NORTH HOTEL VENTURES INC.

Seda Residences Makati

NORTHGATE HOTEL VENTURES INC.

Seda Centrio

NORTH TRIANGLE HOTEL VENTURES INC.

Seda Vertis North

SENTERA HOTEL VENTURES INC.

Seda Atria

SOUTHCREST HOTEL VENTURES INC.

Seda Abreeza

TEN KNOTS DEVELOPMENT CORP.

Miniloc and Lagen Island Resorts

PANGULASIAN ISLAND RESORT CORP.

Pangulasian Island Resort

LIO RESORTS VENTURERS, INC.

Huni Lio

Email address:

dataprivacy@ayalalandhospitality.com

Postal address:

11th Avenue corner 30th Street, Bonifacio Global City, 1634 Taguig City, Metro Manila, Philippines

This privacy notice sets out most of your rights under the data privacy laws. It is important that the personal data we hold about you is accurate and current. We ask that you keep us informed if your personal data changes during your relationship with us.

For a full overview of how we collect, use, and safeguard your data, please visit https://ayalaland.com/ali-privacy-statement and https://www.ayalaland.com.ph/privacy-policy/ to view the Ayala Land Group Privacy Statement.