SM Investments Corporation (“we,” “us,” or “our”) values your privacy and is committed to protecting your personal data. This Privacy Notice explains how we collect, use, store, share, and protect your personal information when you access and use the SM Sustainability School website (www.smsustainabilityschool.com) and learning platform (the “Website”), in accordance with Republic Act No. 10173 (Data Privacy Act of 2012).
1. Scope
This Privacy Notice applies to all users of the Website, including employees, learners, instructors, administrators, and other users (“Data Subjects”). It covers personal data collected directly or generated through use of the Website.
2. Personal Information We Collect
a. Identifying and Contact Information
- Full name
- Company or business unit
- Email address
- Employee ID or username
b. Account and Learning Information
- Login credentials (encrypted)
- Course enrollments, progress, results, certifications
- Forum posts and submitted content
c. Technical and Usage Information
- IP address
- Browser type, device info, OS
- Usage data, logs, cookies
3. Purposes of Processing
- Provide and manage access to the Website
- Manage accounts, enrollments, and certifications
- Facilitate communication and updates
- Improve functionality and security
- Comply with legal obligations
We do not knowingly collect data from individuals below 18 without parental or guardian consent. If such data is identified, it will be securely deleted.
4. Legal Bases for Processing
- User consent
- Contractual necessity
- Legal obligations
- Legitimate interests
5. Sharing and Disclosure
- Authorized SM group entities
- Third-party service providers (under strict agreements)
- Government authorities when required
- Affiliates and subsidiaries
Service providers are contractually required to protect and only use data for intended purposes.
6. Data Retention
Personal data is retained only as long as necessary or required by law. Data is securely disposed of through deletion, shredding, or anonymization after the retention period.
7. Data Protection and Security
We implement organizational, technical, and physical safeguards including:
- Access controls
- Encryption
- Firewalls and monitoring
- Regular system scanning
While we take strong precautions, risks such as cyberattacks may still occur. We are prepared to respond accordingly.
8. Your Rights
- Access your data
- Request corrections
- Request deletion
- Object to processing
- Request data portability
- File complaints
To exercise your rights, contact the Data Protection Officer.
9. Cookies
The Website may use cookies to enhance functionality. You may disable cookies via browser settings, though some features may be affected.
10. Changes to This Privacy Notice
We may update this Privacy Notice periodically. Updates take effect upon posting on the Website.
11. Contact
Data Protection Officer
SM Investments Corporation
10th Floor One Ecom Center, SM MOA Complex, Pasay City
Email: Dataprivacy@sminvestments.com
Phone: 02-8857-0100