1902 Software Development Corporation (“1902”) is committed to protect and respect your personal data privacy. We comply with the EU General Data Protection Regulation (GDPR), the Philippine Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations (IRR), as well as other data privacy laws as may be applicable (collectively, “applicable data privacy laws”).

This Privacy Policy (“policy”) has been compiled by 1902 to inform you of our privacy practices and responsibilities as the data controller concerning personal data that we collect from you when:

  • You visit our websites (1902software.com and 1902software.dk).
  • You submit any kind of information through any of the contact forms and subscription channels within our websites.
  • You call or email us.
  • You apply for employment with 1902.
  • You submit any kind of information through our lead generation ads on Facebook or LinkedIn.

If you are a customer, you may learn more about the types of information we collect from you and the purposes for which we collect them in our Terms and Conditions.

This policy does not apply to personal data that we receive and process on behalf of our customers. Such personal data is covered by the applicable Data Processing Agreement and any other contract that we have with our customer, and not by this policy. For more information about this, see our Terms and Conditions.

1. Data controller information

1902 Software Development Corporation
15F Asian Star Building, Asean Drive corner Singapura Lane
Filinvest Corporate City, Alabang, Muntinlupa 1781 Philippines
Phone: (+632) 550-1902
Fax: (+632) 846-1902
Email: privacy@1902software.com

2. Collection and use of your personal data

A. When you visit our websites

We collect the following information when you visit any of our websites:

  • Your IP address
  • The website page(s) you have visited
  • How you accessed our website (i.e., through Google, Facebook, or other third-party sites)
  • Your browsing behavior within our website (e.g., clicks and time spent)

We collect these information in order for us to improve our website and better serve you, to personalize your experience by delivering the type of content and product offerings that you are most interested in, and to show you retargeting ads based on the pages you visited on our website.

We use cookies to collect these information and remember your settings for your next visit. You may disable cookies but note that you may not be able to experience some of our website functionalities by doing so. Learn more

We also use a third-party service to view your browsing behavior. This data is anonymous and not personally identifiable. You may view our list of third-party suppliers here.

B. When you submit an inquiry through our contact form

We collect the following information from you when you use our contact form to send us a message or inquiry:

  • Name
  • Email address
  • Your IP address
  • The website page(s) you have visited
  • How you accessed our website (i.e., through Google, Facebook, or other third-party sites)
  • Contact number (optional)
  • Time of your submission, including the time zone
  • Your message, which may contain personal data depending on the content

We collect these information:

  • to be able to respond to your inquiries and customer service requests;
  • to allow us to properly address a complaint, forward them to appropriate internal units for action and response, and provide you with appropriate updates and advisories in a legitimate format and in an orderly and timely manner;
  • to document the details surrounding your submission; and
  • to send you emails that further explain 1902’s services (i.e., we will add you to a mailing list to send you ten emails over the course of one month that introduce you to our services. After such emails, we will also, from time to time, send you a few emails on 1902 information that you may be interested in, such as information about new technologies, services, etc.)

C. When you request for our price list

We collect the following information from you when you request to view our price list :

  • Email address
  • Your IP address
  • The website page(s) you have visited
  • How you accessed our website (i.e., through Google, Facebook, or other third-party sites)
  • Time of your submission, including the time zone

We ask for your email address in order for us to send you a validation link that will allow you to access our price list for the services that we offer, and to send you emails that further explain 1902’s services (i.e., we will add you to a mailing list to send you ten emails over the course of one month that introduce you to our services. After such emails, we will also, from time to time, send you a few emails on 1902 information that you may be interested in, such as information about new technologies, services, etc.).

D. When you subscribe to our blog and newsletter

We collect the following information from you when you subscribe to our blog and newsletter :

  • Name
  • Email address
  • Your IP address
  • The website page(s) you have visited
  • How you accessed our website (i.e., through Google, Facebook, or other third-party sites)
  • Time of your submission, including the time zone

We collect these information in order for us to add you to our mailing list and send you ten emails over the course of one month that introduce you to our services, the newsletter emails that you have subscribed to and general announcements or other information about 1902.

E. When you apply for a job

We collect the following information from you when you apply for a job at 1902:

  • Full name
  • Contact details (i.e., email address and contact numbers)
  • Relevant documents, such as your resume, CV, or work portfolio
  • Name of the 1902 employee who may have referred you to the position
  • Details about your educational background, skills set, experience, and employment history
  • Any other information that you provide us in the course of your job application

These information may be collected when you voluntarily submit an application through: (1) our website’s Careers portal; (2) third-party online job portals or posting boards; (3) email at job@1902software.com; (4) giving a hard copy or electronic copy of your resume and/or portfolio to an employee of 1902 for submission to HR; or (5) walk-in applications.

If you applied through our website Careers portal, we also collect the following information in addition to the ones specified above:

  • Your IP address
  • The website page(s) you have visited
  • How you accessed our website (i.e., through Google, Facebook, or other third-party sites)
  • Time of your submission, including the time zone.

We may also collect your information through referrals from our current employees or from online job portals when you make your personal data searchable or available to prospective employers.

We collect these information in order to facilitate your application, including assess your qualifications, contact you for interview and examination, and provide you status or result of your application. We may also collect additional information during your application process, such as during your interview, assessment, or email exchanges between you and our HR personnel, in order to further assess your eligibility for the position for which you applied.

F. When you call or email us

We collect the following information when you contact us through the phone or any of our public email addresses:

  • Phone number or email address
  • Name associated with your email address
  • Other information that you provide us during the phone conversation or in your email

We collect these information for us to be able to follow up with you after your initial correspondence and to properly address your inquiry or complaint and forward them to appropriate internal units.

G. When you respond to our ads

When you click on our ads displayed on third-party sites, you will be redirected to our website, where we will then collect information from you as previously specified above.

We collect the following information from you when you respond to our ads on Facebook or LinkedIn using lead generation forms:

  • Name
  • Email address
  • Contact number
  • Your message, which may contain personal data depending on the content

We collect these information to be able to respond to your inquiry or process your request.

3. Storage of your personal data

We store the personal data that we collect from you in our site database and CRM system (Bitrix).

If you are a customer, your personal data may also be stored in our project management system (ProjectBizz) and local network servers (including our internal accounting system) which are physically located in our office in the Philippines. Your emails are stored in our email systems which are hosted by Microsoft Office 365 and Intermedia.net (both of which are physically located in the USA), and may also be saved as pdf files and stored in our local network servers for documentation purposes.

If you are an applicant, your personal data may also be stored electronically in our local network servers, at the local computer drive of our HR personnel, and physically in our HR director’s office.

Our websites (site and database) are hosted by Hetzner Online GmbH in Germany and backed up to Amazon S3 and/or Amazon Glacier, also in Germany. Our CRM system (Bitrix) and project management system (ProjectBizz) are both hosted with Amazon Web Services in Singapore and backed up using Amazon S3 and/or Amazon Glacier, also in Singapore.

Our local network servers are backed up using Amazon S3 and/or Amazon Glacier in Singapore and Dropbox Business in the USA.

4. Retention and erasure of your personal data

We store your personal data for as long as they are necessary for us to process your inquiry or request, facilitate your application, or to provide our service(s) to you. We may also continue to store them even after such time according to our legal obligations under the Philippine laws.

We ensure that your personal data are completely and securely erased or anonymized upon the end of its required retention period.

If you are an applicant, electronic copies of your personal data are deleted from our systems, and physical copies are shredded at the beginning of the calendar year following your application. If you passed the job examination at 1902 but was not ultimately selected for the position, you will be informed by our HR personnel that your application details, including your personal data, will be kept in our systems for an indefinite period for future consideration to relevant job openings in the company.

5. Disclosure to third-parties

We sometimes engage third-party suppliers who may be able to access and/or process the personal data that we collect from you. These suppliers are bound by contractual obligations, i.e., Data Processing Agreements, to protect and process your personal data according to our instructions. You can learn more about our suppliers here .

6. Protecting your personal data

We implement the following security measures in protecting the personal data that we collect from you:

  • All information you submit through our websites are encrypted via Secure Socket Layer (SSL) technology.
  • We only give our personnel access to your personal data on a need-to-know basis.
  • We restrict access to your personal data to authorized personnel who are under contractual obligation to keep your information in strict confidentiality.
  • We prohibit the transfer or disclosure of your information to unauthorized locations or through unsecured means.
  • Our office, where our local network servers are housed and where physical files are stored, is located in a secure area and can only be entered by employees using biometric access.
  • We have business-grade firewall, anti-virus, and anti-phishing systems to protect against malware and other external attacks.
  • We have an established internal procedure for handling security incidents involving your personal data.
  • We have a designated Data Protection Officer (DPO) who is responsible for monitoring 1902’s compliance with the applicable data privacy laws.
  • We ensure that all our third-party suppliers who have access to your information commit to a written obligation, such as a Data Processing Agreement or a similar document, to protect your personal data and to comply with applicable data privacy laws.

7. Your rights as a data subject

We respect your rights as a data subject under the applicable data privacy laws. We only collect your personal data when you have provided us your express consent.

We provide a link to our Data Privacy Consent  in all contact forms and other subscription forms where you submit your information through our websites.

As a data subject, you can at any time opt out or unsubscribe to our newsletters or other emails that we send you, withdraw your consent, or revoke your permission for our processing of your personal data.  Please note that if you are a customer and you unsubscribe to our newsletter mailing list, we will still contact you regarding the service(s) that we provide for you (i.e., the project that we are doing for you).

Below are resources that you can utilize in exercising your rights:

A. Data subject request page

If you want to view or delete your site visit history and other information you have submitted through our website, you can do so by accessing this page . We will ask for your email address in order to send you a code that will verify your identity.

Through this page, you have the option to:

  • View what data 1902 has about you in relation to the email address you entered and your use of our website;
  • Read the exact version of the legal terms (i.e., Privacy policy, Data privacy consent, Cookie policy, list of suppliers, and terms and conditions) that you agreed to when you submitted your information to us;
  • Export your data into an excel file; or
  • Delete all data that we have associated with the email address you entered.

Note that these options only apply to personal data we have collected from you through our website, such as site visit history and submitted information through contact and subscription forms.

B. Data subject request through privacy email

If you have interacted with us apart from our websites, such as through direct calls, emails, or ad responses, or if you are a previous or current customer:

  • You can request for more information on how we handle your personal data.
  • You can request to see all personal data that we hold about you. We will compile your records and send it to you in any of the following formats: (a) XML file; (b) Excel spreadsheet; (c) PDF file; (d) Word document; or (e) email.
  • You can correct, change, or update your personal data that we have on our records.
  • You can object to how we use or process your personal data.
  • You can request to be “forgotten”, i.e., have all your personal data deleted from our systems.

Write to us at privacy@1902software.com and we will process your request within thirty (30) days. We reserve the right to deny your request if we think that they are unlawful or against our legal obligations as a data controller. If you object to our response to your request, you may file a complaint to the Philippine National Privacy Commission (NPC).

8. Updating this Privacy Policy

We reserve the right to amend, revise, or update this policy. We will inform you of any significant changes through the email you have provided.

Last updated October 19, 2018