Privacy Policy

1. WHO WE ARE

Personal Information Controller / Data Controller

For purposes of the Philippine Data Privacy Act of 2012, PAMS acts as the Personal Information Controller (PIC) for personal information that it collects and processes for its own purposes.

For purposes of the European Union General Data Protection Regulation (“GDPR”), where the GDPR applies, PAMS acts as the Data Controller for personal data processed for its own purposes.

For privacy-related questions, requests or complaints concerning the processing of your personal information by PAMS, you may contact us using the details above.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information collected:

• through the PAMS website;
• through contact or inquiry forms;
• when you communicate with PAMS by email;
• when you request information concerning our services;
• when you engage PAMS for professional services;
• when you communicate with PAMS in connection with an existing or potential business relationship; and
• through normal website operation, security monitoring, analytics and technical logs.

This Privacy Policy does not apply to third-party websites, applications or services that may be accessible through links from our website. Those third parties are responsible for their own privacy practices.

3. PERSONAL INFORMATION WE MAY COLLECT

Depending on how you interact with PAMS, we may collect the following categories of personal information.

3.1 Information you provide directly

This may include:

• name;
• company or organization name;
• business position or title;
• email address;
• telephone or mobile number;
• business address;
• country or location;
• information contained in your inquiry or correspondence;
• information relating to a requested survey, inspection, audit, consultancy or other professional service;
• information contained in documents that you voluntarily provide to us; and
• other information that you voluntarily submit to PAMS.

We only request information that is reasonably relevant to the purpose for which it is collected.

3.2 Technical and usage information

When you visit our website, certain technical information may be automatically processed, including:

• IP address;
• browser type and version;
• operating system;
• device type;
• referring website;
• requested pages or resources;
• date and time of requests;
• approximate technical location derived from IP address where available;
• HTTP request information;
• response status and error information;
• security and diagnostic information; and
• other information generated by normal operation of web servers, security systems and website infrastructure.

Some of this information may be processed for security, fraud prevention, system administration, troubleshooting, performance monitoring and website improvement.

4. PURPOSES OF PROCESSING

PAMS may process personal information for the following purposes:

4.1 Responding to inquiries

We may use information you provide to:

• respond to inquiries;
• communicate with you;
• provide requested information;
• prepare quotations or proposals;
• arrange meetings or professional services; and
• maintain business communications.

4.2 Providing professional services

Where you engage PAMS, information may be processed as necessary to:

• provide marine surveying services;
• provide technical consultancy;
• conduct inspections, audits or assessments;
• prepare reports and documentation;
• communicate with clients and relevant representatives;
• coordinate professional assignments; and
• fulfill contractual and professional obligations.

4.3 Website operation

We may process technical information to:

• operate and maintain the website;
• monitor availability and performance;
• diagnose technical problems;
• improve website functionality;
• maintain website security; and
• protect the website against malicious or unauthorized activity.

4.4 Security and fraud prevention

Technical information, including IP addresses, request information and security logs, may be processed to:

• detect malicious activity;
• investigate suspicious requests;
• prevent unauthorized access;
• protect our systems and website;
• identify automated attacks, vulnerability scanning or abuse; and
• maintain the integrity and security of our information systems.

4.5 Analytics

Where analytics tools are enabled, we may use aggregated or pseudonymous information to understand:

• website traffic;
• page usage;
• website performance;
• visitor behavior; and
• the effectiveness of website content.

4.6 Legal and regulatory compliance

We may process and retain information where necessary to:

• comply with applicable laws and regulations;
• respond to lawful requests from public authorities;
• establish, exercise or defend legal claims;
• maintain appropriate business records; and
• protect our rights, property and legitimate interests.

5. LEGAL BASIS FOR PROCESSING

Where the GDPR or another law requiring a defined legal basis applies, PAMS may rely on one or more of the following legal bases:

Consent

Where processing is based on consent, you may withdraw your consent at any time, subject to legal limitations and the consequences of withdrawal.

Contract

Processing may be necessary to perform a contract with you or to take steps at your request before entering into a contract.

Legal obligation

Processing may be necessary to comply with a legal or regulatory obligation.

Legitimate interests

PAMS may process information where necessary for legitimate business interests, including:

• website security;
• prevention of fraud and abuse;
• information-security monitoring;
• business administration;
• maintaining client relationships;
• responding to business inquiries;
• improving our services and website; and
• establishing or defending legal claims.

Where legitimate interests are relied upon, PAMS will consider the rights and interests of the individual concerned.

Vital interests or public interest

Where applicable, processing may also be carried out where necessary to protect vital interests or where permitted or required by applicable law for a public-interest purpose.

6. PHILIPPINE DATA PRIVACY ACT

PAMS processes personal information in accordance with applicable provisions of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

PAMS follows the principles of:

• transparency;
• legitimate purpose; and
• proportionality.

We seek to collect only information that is reasonably necessary and relevant for the purposes for which it is processed.

We will not process personal information in a manner incompatible with the purposes communicated to the individual, except where otherwise permitted or required by applicable law.

7. DISCLOSURE OF PERSONAL INFORMATION

PAMS does not sell personal information as a business activity.

Personal information may nevertheless be disclosed where reasonably necessary for the purposes described in this Privacy Policy.

Recipients may include:

• website hosting and infrastructure providers;
• website security and content-delivery providers;
• analytics providers;
• information-technology service providers;
• email and communications service providers;
• professional advisers;
• auditors and consultants;
• legal advisers;
• insurers where relevant;
• government authorities where legally required; and
• other service providers acting on behalf of PAMS.

Where third parties process personal information for PAMS, we seek to require appropriate confidentiality, security and data-protection safeguards consistent with applicable law.

We do not authorize service providers to use personal information for unrelated purposes except where permitted by applicable law or otherwise authorized.

8. WEBSITE SECURITY AND CLOUD INFRASTRUCTURE

PAMS uses technical and organizational measures designed to protect its website and information systems.

These measures may include:

• access controls;
• security monitoring;
• network protection;
• web application security;
• firewall and security controls;
• logging and monitoring;
• malware and abuse detection;
• vulnerability protection; and
• appropriate administrative and technical safeguards.

Website security systems may process technical information such as IP addresses, request paths, HTTP methods, user-agent information, timestamps, response codes and security events.

Security-related information may be retained for as long as reasonably necessary to investigate incidents, protect systems, maintain security records, comply with legal requirements and improve security.

No method of transmission or electronic storage can be guaranteed to be completely secure. However, PAMS takes reasonable measures appropriate to the nature of the information and the risks involved.

9. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies.

Cookies may be used for:

• essential website functions;
• remembering preferences;
• security;
• analytics;
• performance monitoring; and
• understanding website usage.

Cookies may be session cookies, which generally expire when the browser session ends, or persistent cookies, which remain for a defined period.

Where non-essential cookies or similar technologies require consent under applicable law, we will seek consent where required and provide an appropriate mechanism to manage or withdraw that consent.

You may also control cookies through your browser settings. Blocking certain cookies may affect website functionality.

10. GOOGLE ANALYTICS

PAMS may use Google Analytics to understand website traffic and usage.

Google Analytics may collect information concerning interactions with the website, including technical and usage information.

Where Google Analytics is enabled, its processing is subject to Google's applicable privacy terms and settings.

PAMS does not use Google Analytics to intentionally collect special categories of personal information or sensitive personal information through website analytics fields.

PAMS does not intentionally configure Google Analytics to collect information that is unnecessary for website analytics.

Where required by applicable law, appropriate consent or privacy controls will be used for analytics technologies.

11. MARKETING COMMUNICATIONS

PAMS does not operate a consumer advertising business.

If PAMS sends business communications or marketing communications, recipients may request that such communications stop.

You may contact us at:

[email protected]

PAMS will respect applicable legal requirements concerning direct marketing and objections to direct marketing.

12. RETENTION OF PERSONAL INFORMATION

PAMS retains personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law. Retention periods may vary according to the type and purpose of information.

As a general approach:

• Website inquiries: retained for as long as reasonably necessary to respond to and administer the inquiry and related business communications.
• Client and contractual records: retained for the duration of the business relationship and thereafter for the period necessary for legal, regulatory, accounting, professional and dispute-resolution purposes.
• Technical and security logs: retained for a limited period appropriate to security, troubleshooting, monitoring and legal requirements.
• Consent and privacy records: retained for as long as necessary to demonstrate compliance with applicable privacy requirements.
• Marketing preferences: retained as necessary to respect opt-out and suppression requests.

When information is no longer required, PAMS will take reasonable steps to securely delete, anonymize or otherwise dispose of it, subject to applicable legal or regulatory retention requirements.

13. INTERNATIONAL DATA TRANSFERS

Some service providers used by PAMS may process information in countries other than the Philippines.

Where personal information is transferred internationally, PAMS will take reasonable measures required by applicable law to protect the information and ensure that appropriate safeguards are in place.

Where the GDPR applies, international transfers will be made using an applicable lawful transfer mechanism, where required.

Your personal information will not be transferred merely because it is technically possible to do so; transfers are made in connection with legitimate business, technical, security or service-provider requirements.

14. AUTOMATED DECISION-MAKING AND PROFILING

PAMS does not currently use personal information for automated decision-making that produces legal or similarly significant effects on individuals.

PAMS also does not currently use website personal information to create profiles for decisions concerning individuals.

If this practice changes, PAMS will update this Privacy Policy and provide any additional information or rights required by applicable law.

15. SENSITIVE PERSONAL INFORMATION

PAMS does not intentionally request sensitive personal information through its public website unless such information is reasonably necessary for a specific legitimate purpose and processing is permitted by applicable law.

You should not submit sensitive personal information through ordinary website forms unless PAMS specifically requests it for a legitimate professional or legal purpose.

Where sensitive personal information is processed, PAMS will apply appropriate safeguards and processing restrictions required by applicable law.

16. YOUR RIGHTS UNDER PHILIPPINE LAW

Subject to applicable law and any lawful limitations, data subjects may have rights including:

• the right to be informed;
• the right to access personal information;
• the right to correct inaccurate or incomplete information;
• the right to object to certain processing;
• the right to request erasure or blocking where legally applicable;
• the right to data portability where applicable;
• the right to withdraw consent where processing is based on consent;
• the right to damages where provided by law; and
• the right to lodge a complaint with the National Privacy Commission.

The National Privacy Commission recognizes these rights under the Data Privacy Act framework.

To exercise a privacy right, contact:

[email protected]

PAMS may need to verify the identity of the requester before providing personal information or processing certain requests.

17. YOUR RIGHTS UNDER THE GDPR

Where the GDPR applies, you may have the following rights, subject to applicable legal conditions and limitations:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to data portability;
• right to object to processing;
• right to object to direct marketing;
• right to withdraw consent where consent is the legal basis;
• rights relating to automated decision-making where applicable; and
• right to lodge a complaint with a competent supervisory authority.

The GDPR requires organizations to provide clear information about purposes, categories of data, legal bases, recipients, retention, international transfers and data-subject rights.

Requests may be submitted to:

[email protected]

18. CALIFORNIA PRIVACY RIGHTS

This section applies only to the extent that PAMS is subject to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and its implementing regulations.

The CCPA applies only to businesses meeting the applicable statutory requirements. The existence of this section does not mean that PAMS necessarily meets the CCPA's applicability thresholds in every circumstance.

California residents may have rights including:

• the right to know/access personal information;
• the right to correct inaccurate personal information;
• the right to delete personal information, subject to exceptions;
• the right to opt out of the sale or sharing of personal information, where applicable;
• the right to limit certain uses and disclosures of sensitive personal information, where applicable;
• the right not to receive discriminatory treatment for exercising privacy rights; and
• other rights provided under applicable California law.

California's current privacy framework also recognizes opt-out preference signals, including Global Privacy Control (“GPC”), where applicable.

PAMS does not sell personal information for monetary consideration as part of its ordinary business operations.

PAMS does not knowingly share personal information for cross-context behavioral advertising.

If PAMS becomes subject to a CCPA requirement concerning sale, sharing, sensitive personal information, or another regulated processing activity, PAMS will provide the applicable notices and mechanisms required by law.

19. CALIFORNIA NOTICE AT COLLECTION

Where required by California law, information provided through a PAMS website form may include:

Categories of information collected:

• identifiers, such as name and email address;
• professional or business information;
• contact information;
• information voluntarily included in communications;
• internet or network activity information;
• device and technical information; and
• information necessary to provide requested services.

Purposes:

• responding to inquiries;
• providing requested information;
• providing professional services;
• maintaining business relationships;
• website operation and security;
• analytics and performance monitoring;
• legal and regulatory compliance; and
• protecting our rights and systems.

PAMS does not sell personal information as an ordinary business practice.

Where a California-specific notice at collection is legally required, the notice will be presented at or before collection as required by applicable law.

California's current framework requires covered businesses to provide appropriate notice at collection and information about applicable consumer rights.

20. CALIFORNIA PRIVACY REQUESTS

California residents who believe the CCPA applies to their information may contact PAMS:

We may need to verify requests before providing personal information or taking action.

Where the CCPA applies, PAMS will process verified consumer requests within the periods required by applicable California law.

The current California framework generally provides a 45-day response period for applicable requests, with a possible additional 45-day extension where legally permitted and properly notified.

PAMS will not discriminate against an individual for exercising a privacy right where prohibited by applicable law.

21. CHILDREN'S PRIVACY

PAMS' website and professional services are not directed to children.

PAMS does not knowingly seek to collect personal information from children through the website.

If a parent or legal guardian believes that a child has provided personal information to PAMS without appropriate authorization, please contact:

[email protected]

If PAMS determines that information was collected contrary to applicable law, reasonable steps will be taken to address the matter.

22. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites.

PAMS does not control the privacy practices, security, content or policies of third-party websites.

We recommend reviewing the privacy policy of each third-party website before providing personal information.

23. DATA SECURITY INCIDENTS

If PAMS becomes aware of a personal-data security incident, we will assess and respond to it in accordance with applicable law and our information-security procedures.

Where notification to affected individuals, regulatory authorities or other parties is required by law, PAMS will provide the required notification within the applicable timeframes.

24. DATA SHARING AND SERVICE PROVIDERS

PAMS may use specialized third-party providers for website hosting, security, analytics, email, information technology and related technical services.

Such providers may process technical or personal information on behalf of PAMS.

PAMS seeks to ensure that appropriate contractual, technical and organizational safeguards are applied to personal information processed by service providers.

25. NO SALE OF PERSONAL INFORMATION

PAMS does not operate by selling personal information.

We do not sell names, email addresses, telephone numbers, client inquiries or other personal information to data brokers or advertising companies.

Information may be disclosed to service providers where reasonably necessary to operate our website, communicate with you, provide professional services, maintain security or comply with legal requirements.

26. PROPORTIONALITY AND DATA MINIMIZATION

PAMS seeks to collect and process only information that is reasonably necessary for a specified and legitimate purpose.

We do not seek to collect personal information merely because it is technically available.

Where information is no longer necessary for the purpose for which it was collected, PAMS will consider whether it should be deleted, anonymized or securely disposed of, subject to legal and legitimate retention requirements.

27. CHANGES TO THIS PRIVACY POLICY

PAMS may update this Privacy Policy from time to time to reflect:

• changes in our services;
• changes in website technology;
• changes in third-party service providers;
• changes in applicable laws or regulatory requirements;
• changes in security practices; or
• other legitimate business or privacy considerations.

The updated version will be published on this page with a revised Last Updated date.

Where required by law, PAMS will provide additional notice concerning material changes.

28. CONTACT US

If you have questions, concerns or requests concerning this Privacy Policy or the processing of your personal information, please contact PAMS:

For Philippine privacy complaints, individuals may also contact the National Privacy Commission (NPC) in accordance with applicable procedures.