Privacy policy

(version 31 January 2020)

This Privacy Policy sets out the manner in which the GoBear group of companies (collectively “we”) collect, use, manage and protect the data that is capable of identifying you as an individual whether on its own or in conjunction with other data accessible by us (“Personal Data”) in compliance with the Data Privacy Act of 2012 of Philippines, as may be amended from time to time. Before you submit any Personal Data to us through www.gobear.com/ph (“Website”) or continue to view or use our Website or any services rendered by us through our Website, please read this Privacy Policy carefully. Please note that this Privacy Policy should be read in conjunction with the Terms and Conditions of the use of our Website and capitalised words and expressions shall, unless otherwise specified or the context otherwise requires, have the corresponding meaning assigned to them in the Terms and Conditions of the use of our Website.

 

I. YOUR DATA (THAT WE COLLECT)

 

1. We believe we provide a great service aimed at making your life easier when you search for insurance, banking and other financial products (“products”). In order for you to us to make the desired comparisons between the various products, it is, however, necessary for us to collect and use certain Personal Data.

 

2. While the specific types of Personal Data you submit through our Website may vary depending on the product you require a comparison for and whether you maintain an account with us, there are 8 broad categories of Personal Data which are collected by us:

a. Name.

b. Identity Data, which includes your nationality, country of residence, identification document image and details, photos, age, date of birth, marital status, gender and photos.

c. Contact Data, which includes your home/mailing address, email address and/or telephone number.

d. Social Media Data, which includes your profile details, name, profile picture, age range, account language.

e. Search Parameter Data, which, depending on the type of product you select, may include your (or the persons’ related to you):

• car insurance requirements (driving experience, age, address and car’s year of manufacture, make, and model);
• travel insurance requirements (destination and period of travel);
• health insurance requirements (Identity Data of yourself, spouse and dependents, and type of insurance required);
• credit card requirements (type of credit card and annual income range); and
• loan requirements (desired loan amount, desired loan period, salary details, credit report and type of loan).

f. Transactional Data, which includes details of the chosen product, payment method, transaction reference number, policy number, policy details as well as any extra information required by us or your provider of your selected product (“Selected Financial Services Provider”).

g. Usage Data, which includes information about how you use our Website (such as the number of times and duration you visit our Website, the types of products and services searched for and how you search for the products and services).

h. Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control (MAC) address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website

 

3. We collect your Personal Data:

a. When you create an account through our Website. We will collect your Name, Identity Data, Contact Data and all other information you agree to provide us at the time of creating your account or subsequently. If you create an account with us through your Facebook account, we will also collect your Social Media Data. In order for you to easily repeat your searches and desired comparisons we will also collect your Usage Data and Search Parameter Data.

b. When you perform an ad-hoc search or request for an ad-hoc price comparison through our Website without creating an account with us. We will collect your Usage Data, Search Parameter Data and Technical Data.

c. When you have selected a product. We may collect your Name, Identity Data, Contact Data and also Transactional Data if you transact through the Website or in cases where your Selected Financial Services Provider requires extra information from you (if any) to facilitate the purchase, application or provision of the product and/or to verify your identity.

 

II. GOBEAR + YOUR DATA = PRICE COMPARISON

 

1. For the purpose of making the product comparison that you are searching for, it is necessary for us to collect and use your Search Parameter Data.

 

2. When you select a product our Website, we may provide your Name, Identity Data, Contact Data, Search Parameter Data and Transactional Data to the Selected Financial Services Provider and their (marketing) representatives for the purposes of: facilitating your purchase, application or the provision of the product from the Selected Financial Services Provider or sending you relevant information and recommendations about the products and services offered by the Selected Financial Services Provider.

 

3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered Personal Data in law as this data does not identify you as an individual, whether on its own or in conjunction with other data accessible by us. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can identify you as an individual, whether on its own or in conjunction with other data accessible by us, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

 

III. CONVENIENCE IS KING

 

1. We try to make the use of our Website and services as easy and convenient as possible. We may use your Personal Data:

a. to improve the user-experience of our Website (such as to help our services deliver more useful, customized content, including more relevant search results);

b. to manage, optimize, monitor and research the usage, performance and operation of our Website and the services provided through our Website;

c. to conduct analytics and measurements;

d. to fix problems with our Website (and its software);

e. to develop new services;

f. to conduct investigations, audits, or carry out crime and fraud prevention and risk management activities;

g. to comply with legal and regulatory requirements;

h. to comply with any court orders or directions from government or regulatory authorities;

i. in connection with any claims made by, against or otherwise involving you in respect of any services provided by us;

j. enforcement of our legal rights and obligations; and

k. for any other purpose for which we have obtained your consent.

 

2. With your consent, we may also use your Search Parameter Data, Usage Data and Technical Data for marketing and promotional purposes, including:

a. delivering advertisements based on your interests or previous searches that you have performed; and

b. sending you promotional materials.

 

IV. CONSENT IS CRUCIAL

 

The use of our Website and our services is entirely voluntary but if you decide to visit, access, use or obtain any content or data from our Website, or by obtaining or using any of the services rendered by us through our Website, or by ticking the checkbox or clicking the submission button, you:

a. consent to the collection and use of your Personal Data; and

b. in order to provide our services, we may be required to disclose and forward your Personal Data to the Selected Financial Services Provider and the parties mentioned in Section V, for which you understand and hereby authorize us to do so,

in accordance with this Privacy Policy.

 

V. IT’S STILL YOUR KINGDOM

 

1. We will not provide your Personal Data to any party unless such party agrees and/or undertakes to be bound by provisions that subject the Personal Data to a level of protection that is comparable to what is required under the Data Privacy Act of 2012. You hereby agree to such transfer and transmission.

 

2. Examples of such transfer/transmission include sharing your Personal Data with certain suppliers, agents, service providers (who may be located in other territories) and Financial Services Providers or their (marketing) representatives whom we have a business relationship with or that we use for optimizing, monitoring or researching the usage, performance and operation of our Website as well as the services we provide through our Website, and you hereby agree to such sharing.

 

3. We may also share your Personal Data with the following parties:

a. the GoBear group of companies, our parent company, subsidiaries, associated or affiliated companies, our head office and any branches and representative offices, whether located within or outside of Philippines. For the latest list of our locations, please click here www.gobear.com;

b. our insurers and advisors, including without limitation consultants, auditors, accountants and lawyers;

c. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business;

d. any relevant governmental or regulatory authorities, courts or law enforcement agencies;

e. any person in connection with any claims made by or against or otherwise involving you in respect of any services provided by us;

f. any other person to whom disclosure is necessary for any of the purposes described in this Privacy Policy; and

g. any other party to whom you have consented for us to disclose your Personal Data.

 

VI. MANAGE YOUR KINGDOM

 

1. Since it is your Personal Data it is only fair that you have control of what happens to it. These are your rights and powers:

a. You are entitled to withdraw your consent to any use or disclosure of your Personal Data by contacting us here. However, notwithstanding objection or withdrawal of consent, we may continue to process your Personal Data on the following grounds:

(i) processing of Personal Data is necessary and is related to the fulfilment of our contract with you, or in order to take steps at your request prior to entering into a contract;

(ii) processing is necessary for compliance with a legal obligation;

(iii) processing is necessary to protect your vitally important interests, including life and health;

(iv) processing is necessary in order to respond to national emergency, to comply with the requirements of public order and safety, or to fulfil functions of public authority which necessarily includes the processing of personal data for the fulfilment of its mandate; or

(v) processing is necessary for the purposes of the legitimate interests and that of third parties to whom data was shared, except where such interests are overridden by your fundamental rights and freedoms under the Philippine Constitution.

b. You have access to the Personal Data we hold and you can ask us about the ways in which your Personal Data is used or disclosed by contacting us here; and

c. You have the right to update, rectify or make corrections to your Personal Data using the ‘my account’ page or by contacting us directly here.

d. You have the right to request for the suspension or withdrawal, or order the blocking, removal, or destruction of, personal data from our filing system, in the absence of any other legal ground or overriding legitimate interest for the lawful processing of personal data, or when there is substantial proof that personal data is incomplete, outdated, false, or has been unlawfully obtained;

e. You have the right to be indemnified for any actual and direct damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, taking into account any violation of you rights and freedoms as a data subject;

f. In case your personal data is processed in a structured and commonly used format, you have the right to obtain a copy of your personal data in such electronic or structured format; and

g. you have the right to lodge a complaint before the National Privacy Commission if you feel that your Personal Data were misused, maliciously disclosed, or improperly disposed, or if any of your rights discussed here have been violated.

 

VII. PROTECTION IS KEY

 

1. We take the protection of your Personal Data from unauthorised access by others seriously. We shall make reasonable security arrangements to prevent the unauthorised access, use, collection, disclosure or copying of your Personal Data.

 

2. The parties to whom we may share your Personal Data may be situated within or outside Philippines and your Personal Data may be transferred outside Philippines. We may also store your data outside Philippines. In some of these countries, there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Data Privacy Act 2012. That means your Personal Data may not be protected to the same or similar level as in Philippines. In such cases, we will nevertheless make reasonable measures to ensure that your Personal Data is stored and processed securely and in accordance with this Privacy Policy.

 

3. However, you acknowledge that no data transmission over the internet is completely secure. While we will have in place reasonable security arrangements to protect your Personal Data as outlined above, we cannot guarantee or warrant the security of any data, including Personal Data, that you provide to us and you transmit such data, including Personal Data, to us at your own risk.

 

VIII. COOKIE POLICY

 

(A) GOBEAR COOKIES

 

Our Website is our business and we use all kind of tools to operate it as efficiently and optimally as possible. One of the ways we do that is by using cookies when you browse our Website. A cookie is a small data file that is stored on your computer or on your mobile device (“Cookie” or “Cookies”). There are different kinds of Cookies that we use for different kinds of purposes:

a. Technical Cookies: are necessary to provide you with our services, help our Website function properly and to manage your account and login through social media platforms.

b. Functional Cookies: are aimed to make your next visit to our Website less time-consuming. We will recognise your browser and remember your preferences such as data provided for product searches, login information to your account, language, the version of the Website you use and any other preferences.

c. Analytical, Targeting and Tracking Cookies: are used to track the online behaviour of our visitors and allow us to help improve the way our Website works, for example, by ensuring that our visitors easily find what they are looking for and that we can continue to provide our visitors with relevant content. We also use these Cookies to understand your online preferences for online advertisement purposes. This allows us to present you with tailor made offers based on your online behaviour.

 

(B) TO COOKIE OR NOT TO COOKIE

 

In so far as your Personal Data is being collected by our Cookies, you have the personal option to disable the use of such Cookies in your browser settings when accessing our Website. Please note that disabling such Cookies may however result in loss of functionality of our Website and/or delay or affect the way our Website operates and/or (partially) restrict your use of the Website.

 

IX. WE’D LIKE TO STAY IN TOUCH

 

1. If you create an account with us, sign-up through Facebook, or if you don’t create an account but you do submit your email address we can send you: news updates, account information updates and other Website announcements.

 

2. If you want to hear more from us you can opt to receive more information which will include messages and content we think would be interesting for you including targeted advertisements and marketing messages from us.

 

3. As soon as you’re no longer interested in these extra mailings, you can choose to unsubscribe from our mailing list by following the instructions in the email you received or through the settings in your account.

 

X. HOW TO CONTACT US

 

If you have any questions about this Privacy Policy, you can direct your question to our Data Protection Officer at [email protected].