Crown Privacy Policy  |  Crown Lift Trucks Philippines Corp.

 

1. Introduction

In the course of Crown’s business in the Philippines, Crown collects personal information and the Crown Privacy Policy has been developed to ensure that such information is handled appropriately.

Crown is committed to complying with the Republic Act 10173 – Data Privacy Act of 2012, its implementing rules and regulations, and issuances of the National Privacy Commission (collectively, "Local Privacy Laws"), in relation to all personal information it collects. This commitment is demonstrated in this Policy. Personal information held by Crown will be treated in accordance with Local Privacy Laws.

This Policy sets out the controls which Crown has adopted to govern the way it collects and uses personal information, the circumstances in which it might disclose personal information to third parties, how persons can access their personal information held by Crown and what they can do if they are unhappy with Crown’s treatment of their personal information.

 

2. Who is Crown?

In this Policy, “Crown” refers to Crown Lift Trucks Philippines Corp.

 
3. Who does the Crown Privacy Policy apply to?

This Policy applies to any individual in respect of whom Crown currently holds, or may in the future collect, personal information.

 
4. What information does the Crown Privacy Policy apply to?

This Policy applies to personal information, which may refer to non-sensitive personal information or sensitive personal information. “Personal information” which is non-sensitive refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Meanwhile, "sensitive personal information" refers to information (i) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (ii) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings; (iii) issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (iv) specifically established by an executive order or an act of Congress to be kept classified.

 
5. What information is not personal information?

Information where Crown has permanently removed any reference to a person, so that the person cannot be reasonably identified from the information, is not personal data.

Crown may use this anonymized information for its own purposes and commercial gain. For example, the fact that “x” users aged 30-35 have accessed a Crown website is not personal information.

 
6. How and when does Crown collect personal information?

Crown collects personal information in a variety of ways in the course of conducting its businesses, including:

  • in agreements it enters into with customers, suppliers, contractors and other personnel;
  • when providing equipment and services and related information to customers, and administering customer accounts;
  • when engaging suppliers, contractors and other personnel;
  • when responding to questions regarding our products and our business;
  • by interacting with people via our websites, email and telephone;
  • when conducting trade promotions and competitions; and
  • by security video surveillance at Crown sites.

The kinds of personal information collected and held by Crown include (depending on the circumstances) names, addresses and other contact details, details about a person’s work experience and other qualifications, date of birth, driver’s licence details, bank account details, photographs and video footage.

Where reasonable and practicable, Crown will collect personal information directly from the person. Where it may not be clear that this is being done, Crown will seek to identify that this is being done.

However, in some circumstances, it may be necessary for Crown to collect personal information through third party service providers or agents (e.g. Crown customer information received from Crown branches) or from a source of publicly available information (e.g. a telephone book). In all these cases, Crown will ensure that the personal information is or was collected pursuant to any of the recognized lawful bases for processing under Local Privacy Laws.

At or soon after the time when Crown collects personal information, Crown will take reasonable steps to ensure that the person is aware that Crown has collected the information, the purpose(s) of the collection, the main consequences (if any) if the information is not collected, the types of organisation (if any) to which the information may be disclosed (including those located overseas), any law that required the particular information to be collected, and the fact that this Privacy Policy contains details on access, correction and complaints.

Personal information collected by Crown may be held in a variety of formats, including hard copy format and on Crown’s computer systems.

If Crown receives personal information that Crown has not requested (unsolicited information) and Crown determines that Crown could not have collected that information under the Local Privacy Laws if Crown had requested it, then Crown will destroy or de-identify the information if it is lawful and reasonable to do so.

 
7. Basis for processing

Crown will collect, use or disclose your personal information when you have provided Crown with express consent, and/or for the purposes permitted under applicable laws, such as: to comply with legal or regulatory obligations, for the performance of a contract to which you are a party, or pursuant to Crown's legitimate interests.

Crown will process, store, collect and/or disclose sensitive personal information when you have given express consent, or when it is expressly authorized by applicable laws.

 

8. How does Crown use personal information

The use to which we can put personal information depends on the reason for which it was collected. Crown may use personal information for its primary purposes of collection, such as to provide our products and services, the delivery of equipment to the person, and to process an application for credit, or for secondary purposes which are reasonably related to such primary purposes.

In certain circumstances, Crown may use personal information for promotional or direct marketing purposes where consented to by the person or when otherwise supported by a recognized legal basis for processing. However, a person may at any time request Crown not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting Crown by contacting Crown via our contact details provided under the “Contact Crown” heading below. There is no fee for making such a request.

 

9. Disclosure of personal information

Crown respects the privacy of personal information and we will take reasonable steps to keep it strictly confidential.

Crown does not disclose or transfer personal data to third parties unless Crown asked for and obtained the person's consent to do so, or if the disclosure or transfer is supported by a recognized lawful basis for processing or is otherwise permitted or authorized by law. In such cases, Crown will disclose personal information to third parties only to the extent necessary for the abovementioned primary and secondary purposes, if the disclosure could be reasonably expected (e.g. disclosure to a customer for the purpose of delivering equipment ordered from Crown). Where such a disclosure is necessary, Crown will require that the third party contractually undertake to treat the personal information in accordance with Local Privacy Laws.

Where appropriate and to the extent necessary for the abovementioned primary and secondary purposes, and where consented by the person or otherwise permitted under Local Privacy Laws, Crown may also disclose personal data to Crown's affiliated companies. In these cases, Crown will provide its affiliated companies with only the personal data they need for such purposes, and Crown will require that they protect such personal data in accordance with Local Privacy Laws.

Otherwise, Crown will only disclose personal information to third parties without the consent of the person to whom it relates if the disclosure is:

(a) necessary to protect or enforce Crown’s legal rights or interests or to defend any claims;
(b) necessary to prevent or lessen a serious threat to a person’s health or safety;
(c) required or authorised by law; or
(d) permitted by another exception in local legislation.

Under no circumstances will Crown sell personal information without the consent of the person to whom it relates. Crown does not normally disclose a customer’s personal information to overseas recipients. If it does, it will contractually ensure that such recipients provide a comparable level of protection to the personal data.

 

10. Information Security

Crown will take all reasonable steps to ensure that all personal information held by Crown is secure from any unauthorised access or disclosure. However, despite such reasonable steps, Crown would not be able to completely guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.

 

11. Data Retention

Crown may retain the personal information only for as long as is necessary to fulfill the purposes for which it was collected, for the establishment, exercise or defense of legal claims, for legitimate business purposes, or as required or permitted by applicable law. After this period of time, Crown will take reasonable steps to destroy or permanently de-identify personal information in a safe and secure manner.

 

12. Accessing personal information

A person has the right to request to access personal information about them held by Crown. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below.

Crown will grant a person access to their personal information as soon as possible, subject to the circumstances of the request.

A request to access personal information will be rejected if:

(a) the request is frivolous or vexatious (i.e., repeated requests) or if the request will entail disproportionate effort;
(b) the request involves the personal information of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.

Crown may charge a fee for reasonable costs incurred in giving access to an individual’s personal information. The fee (if any) will be disclosed prior to it being levied.

 

13. Correcting personal information

Crown will take reasonable steps to ensure the accuracy and completeness of the personal information we hold. However, if a person believes that any personal information that we hold about them is inaccurate or out of date, they have the right, subject to the limitations set out under Local Privacy Laws, to have the same corrected or rectified. In such cases, they should contact Crown via our contact details provided under the “Contact Crown” heading below.

 

14. Objecting to processing

Where the processing of personal information is based on consent or legitimate interest, a person has the right to object to the processing of their personal information, as well as to the processing of their personal information for direct marketing, profiling, or in cases of automated processes where the personal data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you. In case of any significant change or amendment to the information provided in this Privacy Policy, the person will be notified and be given an opportunity to object and/or withdraw consent.

 

15. Erasure or blocking

A person has the right to request for the suspension, withdrawal, blocking, removal or destruction of the personal information Crown holds about them in the following cases:

(a) personal information is: incomplete, outdated, false, or unlawfully obtained; used for an unauthorized purpose; no longer necessary for the purpose/s for which they were collected; concerns private information that is prejudicial to you (unless otherwise authorized by law);
(b) the person objects to the processing of their personal information and there are no other applicable lawful bases for the processing of personal information;
(c) the processing of personal information is conducted in an unlawful manner; or
(d) when the person's rights as a data subject have been violated.

 

16. Data Portability

When the processing of personal information is based on consent or contract, and is performed by electronic means in a structured and commonly used format, the person has the right to obtain from Crown a copy of the personal information and/or have the same transmitted to another data controller in an electronic or structured format.

 

17. Complaints

If a person wishes to complain about a breach by Crown of the Crown Privacy Policy or relevant Local Privacy Laws, a complaint may be lodged with the National Privacy Commission. However, we encourage the person to first escalate the matter to Crown via our contact details provided under the “Contact Crown” heading below so that Crown may address the same.

Crown deals with complaints via our internal data privacy complaint process, under which a Crown contact officer will be allocated to assess your complaint or grievance and respond to you within a reasonable timeframe. Crown takes all complaints seriously and any further action after our initial response to you will vary depending on the nature of your complaint.

 

18. Additional information regarding Credit Information

This Privacy Policy also applies in relation to Crown’s collection and use of credit information of individuals, in connection with commercial credit provided through Crown.

The types of credit information that Crown collects and uses for the purpose of assessing an application for commercial credit typically include:

  • names, addresses and other contact details of accountholders and guarantors (both prospective and current);
  • bank account details;
  • driver’s licence details;
  • financial information;
  • information on the assets held by an individual.

Where appropriate and in cases allowed by law, such information is collected from the relevant individual and from credit reporting bodies, as well as from publicly available information. Crown uses the information collected to create an internal credit assessment report. Crown discloses credit information to credit reporting bodies:

  • to obtain a credit report from the credit reporting body; and
  • for the purposes of lodging a default listing against the individual.

When lodging a default listing, we may do this ourselves or by our agents.

 

19. Google Analytics

Crown’s website also uses Google Analytics which is a web analytics tool offered by Google Inc. that generates detailed statistics about a website's traffic and traffic sources. Crown uses Google Analytics for statistical reasons, e.g. to measure how many users have clicked at a certain product information. Google Analytics uses Cookies to obtain information about your use of Crown’s website including your IP-address. As your IP-address is an individual element that would allow identifying you, Crown has implemented a specific code to ensure that your IP-address will only be collected in a shortened and anonymised form. Thus, Google will not be able to identify you from the IP-address that is collected from you when using this website. The information collected by this Cookie will be transferred to Google Inc. in the United States of America.  

You may opt out of Google Analytics by using the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

Most browsers are initially set to accept Cookies. However, you have the ability to modify the usage of or disable Cookies if you wish, generally through changing your internet software browsing settings. 

Note: if Cookies are disabled, it may mean that you experience reduced functionality or you may be prevented from using elements of the Crown website altogether.

 

20. Contact Crown

If there are any questions regarding the Crown Privacy Policy or the way that Crown manages personal information or if there are any concerns about Crown’s treatment of personal information, then Crown may be contacted by post, telephone or email:

Crown Privacy Officer
Warehouse 12 Compound, Bicutan Road, 
Brgy Barandal, Calamba City, Laguna 4027
Telephone: (63) 49 540 9700
Email: privacy.ph@crown.com