This notice explains how SinagTech Labs handles personal data under the Philippine Data Privacy Act of 2012 and its implementing rules.
Summary
- You give us your name, email address and the type of customer you are when you join the SmartParol early-bird list. We do not collect payment details on this website.
- We use them to run the early-bird offer: confirm your sign-up, message you the launch price and a payment link before any payment is due, and tell you about SmartParol availability and shipping.
- Our legal basis is your consent (the checkbox on the form). You can withdraw it at any time.
- We do not sell your data. We share it only with service providers who help us run the website and email, under written agreements.
- You can ask to access, correct, delete or move your data, or object to its use, by emailing info@sinagtechlabs.com.
1. Who we are
This website is operated by SinagTech Labs, Inc. (“SinagTech Labs”, “we”, “us”), a company organized in the Philippines. We are the personal information controller for the personal data described in this notice.
Our privacy office handles all privacy questions and requests. You can reach it at info@sinagtechlabs.com.
2. What we collect
Information you give us
- Full name and email address (waitlist form, contact messages).
- Your interest type: Consumer or Corporate.
- Optionally, your answer to “What would you expect to pay?” (a price range), used only to understand pricing expectations in aggregate.
- Your consent to be contacted about the offer and to this notice, with the date and time and the version of this notice you agreed to.
- Anything you write to us by email.
Information collected automatically
- The campaign or link you came from (for example UTM source, medium and campaign tags) and the website you were referred from.
- Your browser and device type (user agent).
- A one-way hashed version of your IP address, used only to prevent spam and repeated sign-ups. We do not store your raw IP address in our waitlist records.
This website does not currently ask for payment, government ID, financial account or other sensitive personal information. When we send you a payment link, payment will be handled by a third-party payment provider. We will name the payment provider and our delivery partner, and update this notice, before we ask you for any payment or delivery details such as an address or phone number.
3. Why we use it, and our legal basis
| Purpose | Legal basis (RA 10173) |
|---|---|
| Register you for the SmartParol early-bird list and send your confirmation email. | Your consent (Sec. 12(a)) |
| Message you about the offer: list closing on Oct 30, the launch price and payment link before any payment is due, and shipping from Nov 15. | Your consent; steps at your request before a purchase (Sec. 12(b)) |
| Reply to your enquiries, and follow up on Corporate interest. | Your consent; our legitimate interests (Sec. 12(f)) |
| Prevent spam, abuse and duplicate sign-ups; keep the website secure. | Legitimate interests (Sec. 12(f)) |
| Understand which channels bring people to the list, in aggregate. | Legitimate interests (Sec. 12(f)) |
| Comply with law, tax, accounting and consumer-protection obligations once orders are placed. | Legal obligation (Sec. 12(c)) |
We will not use your data for a different purpose without telling you and, where required, asking for your consent again. Joining the list is free and is not a purchase. Your place and any discount are confirmed only as explained in our message to you before any payment.
Marketing messages. We will email you only about SmartParol and SinagTech Labs. Every message can be stopped by replying “unsubscribe” or emailing us; we will stop within 5 business days.
4. Who we share it with
We do not sell or rent your personal data. We share it only with personal information processors that act on our instructions, under data sharing or processing agreements, and only as needed:
- Hostinger — website hosting and database storage, on servers located in Indonesia.
- Google Workspace — sending and receiving our email.
- Payment provider and courier — to be named in this notice before we collect payment or delivery details.
We may also disclose data when required by law, a court order or a lawful request from a government agency, or to protect our rights, subject to Philippine law.
5. Transfers outside the Philippines
Our website is hosted on servers in Indonesia, and some other service providers, such as Google Workspace, also process data outside the Philippines. When this happens we remain responsible for your data and require our providers to protect it with safeguards comparable to those in the Data Privacy Act, through contracts and the providers’ security commitments.
6. How long we keep it
We keep personal data only as long as needed for the purposes above, or as required by law:
- Early-bird list records: until the offer is fulfilled or closed, then up to 12 months, unless you ask us to delete them sooner or you keep receiving updates from us.
- Order, payment and tax records (once orders are placed): for the period required by Philippine tax and accounting law.
- Email correspondence: 24 months after the last message.
When data is no longer needed we securely delete or anonymize it.
7. How we protect it
We apply organizational, physical and technical measures, including encrypted connections (HTTPS), restricted password-protected administration access, storing only a hashed IP address, limiting access to staff who need it, and requiring our processors to protect data.
If a personal data breach occurs that is likely to put your rights and freedoms at real risk, we will notify the National Privacy Commission and affected people within 72 hours of knowledge or reasonable belief of the breach, as required by NPC rules.
8. Your rights
Under Section 16 of the Data Privacy Act and its Implementing Rules and Regulations, you have the right to:
- Be informed how your data is processed (this notice).
- Access the personal data we hold about you and how we use it.
- Object to processing, including withdrawing your consent at any time. Withdrawal does not affect processing done before; it may mean we can no longer keep your early-bird slot.
- Rectify inaccurate or incomplete data.
- Erase or block your data when it is incomplete, outdated, false, unlawfully obtained or no longer needed.
- Data portability (Sec. 18): get a copy of your data in a commonly used electronic format.
- Damages for inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your data.
- Complain to the National Privacy Commission (see section 12).
To exercise any right, email info@sinagtechlabs.com with the subject “Privacy request” from the email address you signed up with. We may ask you to verify your identity, and we aim to respond within 15 days. There is no charge for ordinary requests.
9. Cookies and tracking
This website does not currently use advertising or analytics cookies. To remember which campaign brought you to the site, we briefly store campaign tags in your browser’s session storage; it is cleared when you close the tab. Our hosting provider may keep standard server logs for security. Fonts are loaded from Google Fonts, which may receive your IP address when the page loads.
10. Children
Our offer is for adults. If you are under 18, please ask a parent or guardian to join on your behalf. We do not knowingly collect data from minors; if we learn we have, we will delete it.
11. Changes to this notice
We may update this notice, for example when we add payment, delivery or analytics services. The version and date at the top will change, and for material changes we will notify you by email or ask for your consent again where required.
12. Contact and complaints
SinagTech Labs, Inc. — Privacy Office
Email: info@sinagtechlabs.com
If you believe your rights were violated, please contact us first so we can fix it. You may also file a complaint with the National Privacy Commission: privacy.gov.ph, email complaints@privacy.gov.ph.
Legal references: Data Privacy Act of 2012 (RA 10173); its Implementing Rules and Regulations; NPC Circular 16-03 (personal data breach management); NPC Circular 16-01 and 2023 issuances as applicable.