Last update: March 21, 2025
I. Purpose
PharmaServ Express (“Company,” “we,” “us,” or “our”) is committed to protecting the privacy and personal data of our users, customers, and stakeholders. This Privacy Policy outlines how we collect, use, store, and protect personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC).
Through this Privacy Policy, we aim to:
II. Scope
This Data Privacy Policy applies to all resources involved in the collection, use, storage, sharing, retention and disposal of personal data within PharmaServ Express in the course of its business operations, including freight forwarding services, storage and warehousing, logistics services, business brokerage activities, and wholesale trade. Specifically, this policy protects the following resources:
This policy applies to all company personnel and third parties authorized to access or process personal data. It governs data processing activities conducted within company facilities, through its IT systems, and via third-party services.
This policy is established in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC).
III. Applicability
This policy applies to all individuals and entities that collect, use, store, or share personal data on behalf of PharmaServ Express. Specifically, it applies to:
All individuals and entities covered under this policy are expected to comply with its provisions to ensure the protection of personal data in accordance with the Philippine Data Privacy Act of 2012 and other applicable regulations.
IV. Roles and Responsibilities
PharmaServ Express is committed to ensuring that all personnel, contractors, vendors, and other stakeholders comply with this Privacy Policy. Data protection is a shared responsibility across all levels of the organization, and the following roles have specific responsibilities in safeguarding personal data:
Data Protection Officer (DPO) and Compliance Officer for Privacy (COP)
The Data Protection Officer (DPO) with the support of the Compliance Officer for Privacy (COP) is responsible for overseeing the organization’s compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and other applicable data protection regulations. The DPO’s responsibilities include:
a. Monitor the PIC’s or PIP’s compliance with the DPA, its IRR, issuances by the NPC and other applicable laws and policies. For this purpose, he or she may:
1.) collect information to identify the processing operations, activities, measures, projects, programs, or systems of the PIC or PIP, and maintain a record thereof;
2.) analyze and check the compliance of processing activities, including the issuance of security clearances to and compliance by third-party service providers;
3.) inform, advise, and issue recommendations to the PIC or PIP;
4.) ascertain renewal of accreditations or certifications necessary to maintain the required standards in personal data processing; and
5.) advice the PIC or PIP as regards the necessity of executing a Data Sharing Agreement with third parties, and ensure its compliance with the law;
b. Ensure the conduct of Privacy Impact Assessments relative to activities, measures, projects, programs, or systems of the PIC or PIP;
c. Advice the PIC or PIP regarding complaints and/or the exercise by data subjects of their rights (e.g., Requests for information, clarifications, rectification or deletion of personal data);
d. Ensure proper data breach and security incident management by the PIC or PIP, including the latter’s preparation and submission to the NPC of reports and other documentation concerning security incidents or data breaches within the prescribed period;
e. Inform and cultivate awareness on privacy and data protection within the organization of the PIC or PIP, including all relevant laws, rules and regulations and issuances of the NPC;
f. Advocate for the development, review and/or revision of policies, guidelines, projects and/or programs of the PIC or PIP relating to privacy and data protection, by adopting a privacy by design approach;
g. Serve as the contact person of the PIC or PIP vis-à-vis data subjects, the NPC and other authorities in all matters concerning data privacy or security issues or concerns and the PIC or PIP;
h. Cooperate, coordinate and seek advice of the NPC regarding matters concerning data privacy and security; and
i. Perform other duties and tasks that may be assigned by the PIC or PIP that will further the interest of data privacy and security and uphold the rights of the data subjects.
Except for items (a) to (c), a COP shall perform all other functions of a DPO. Where appropriate, he or she shall also assist the supervising DPO in the performance of the latter’s functions.
Senior Management
Senior Management is responsible for integrating data privacy into the organization’s strategic and operational plans. Their responsibilities include:
Department Heads and Managers
Department Heads and Managers play a crucial role in ensuring that their teams comply with data protection policies. Their responsibilities include:
Employees
All Employees must adhere to this Privacy Policy and are responsible for:
Third-Party Vendors and Service Providers
Third-party vendors and service providers who process personal data on behalf of PharmaServ Express must:
Users and Customers
Users and Customers of our software platform are responsible for:
V. Compliance
All individuals and entities covered by this Data Privacy Policy, including employees, third-party vendors and service providers, users, and customers, are expected to comply with the provisions outlined here. Failure to adhere to this policy may result in appropriate consequences, as detailed below:
1. Employees
Employees are required to comply with this Data Privacy Policy and all related Company policies, procedures, and legal requirements concerning data protection. Any violation, including but not limited to unauthorized access, disclosure, or misuse of personal data, may result in disciplinary action, up to and including termination of employment, in accordance with the company’s Code of Conduct and Disciplinary Procedures.
2. Third-Party Vendors and Service Providers
Third-party vendors and service providers that process personal data on behalf of the Company must comply with the terms set forth in their respective contracts, including any data protection agreements or addenda. Non-compliance may result in contract termination, suspension of services, or legal action, as deemed necessary by the Company.
3. Users and Customers
Users and customers are expected to respect the data privacy rights of others when using the company’s services, platforms, or systems. Any misuse of personal data, including unauthorized access, sharing, or fraudulent activities, may lead to the suspension or termination of access to services, as well as possible legal action.
4. Legal and Regulatory Consequences
In cases where non-compliance results in a violation of applicable data protection laws, the Company reserves the right to take legal action against the responsible party. Additionally, violators may be subject to penalties, fines, and other enforcement actions imposed by regulatory authorities.
The Company is committed to enforcing this policy and will take appropriate steps to investigate, address, and mitigate any breaches of compliance.
VI. Organizational Responsibilities
PharmaServ Express as a Personal Information Controller (PIC) has the following obligations:
On the other hand, PharmaServ Express as a Personal Information Processor (PIP) adheres to the following obligations:
VII. Data Subject Rights
a. The right to be informed
Data subjects have the right to be informed about the processing of their personal data, including whether their data shall be, are being, or have been processed. This includes transparency regarding the existence of automated decision-making and profiling.
Before any personal data is processed, or at the next practical opportunity, data subjects must be notified and provided with the following information:
b. The right to damages
Data subjects have the right to seek compensation for any damages incurred as a result of the processing of inaccurate, incomplete, outdated, false, unlawfully obtained, or improperly used personal data. This right applies in cases where such processing leads to a violation of their rights and freedoms under applicable data protection laws.
To exercise the right to seek compensation for damages, data subjects may file a complaint with the National Privacy Commission (NPC) if they believe their rights have been violated. The complaint must be submitted in accordance with the NPC’s established Rules of Procedure governing all cases brought before the Commission.
c. The right to access
Data subjects have the right to obtain confirmation on whether their personal data is being processed and to access specific details regarding such processing. This includes the right to request information about:
d. The right to file a complaint
Data subjects have the right to file a complaint with the National Privacy Commission (NPC) if they believe their personal information has been misused, unlawfully disclosed, improperly disposed of, or if any of their data privacy rights have been violated.
e. The right to object
Data subjects have the right to refuse the processing of their personal data if the processing is based on consent or legitimate interest as the legal basis.
Data subjects have the right to object to the processing of their personal data under the following circumstances:
f. The right to rectify
Data subjects have the right to challenge any inaccuracies or errors in their personal data and request the Personal Information Controller (PIC) to correct them within a reasonable timeframe.
g. The right to erasure or blocking
Data subjects have the right to request the suspension, withdrawal, blocking, removal, or destruction of their personal data from the Personal Information Controller’s (PIC) filing system, including both active and backup systems.
Data subjects may request the erasure or blocking of their personal data upon discovery and presentation of substantial proof of any of the following:
h. The right to data portability
Data subjects have the right to request a copy of their personal data from the Personal Information Controller (PIC) and/or have it transferred to another PIC in an electronic or structured format that is commonly used.
Conditions for Exercising This Right
This right may be exercised when both of the following conditions are met:
Types of Personal Data That May Be Requested for Copy or Transfer
The right to data portability applies only to:
VIII. Data Use Rules
a. What information we collect, directly or indirectly
Types of information collected:
How we collect your personal data
We collect your personal data when you:
Specifically, we collect, use, store, retain, disclose or transfer, and dispose (once they have served their legitimate purpose) the following personal data:
A. Employment, Recruitment, and Selection Process
Personal data for employment pertains to the information collected, processed, and utilized by PharmaServ Express regarding its employees or job applicants. These are the following:
B. Customers who utilize our services
Personal data of customers for delivery pertains to the information collected, processed, and used by PharmaServ Express regarding its customers in connection with the delivery of goods or services.
Users:
Patients:
C. Vendors/suppliers or prospective partners
Personal data of vendors/suppliers or prospective partners refers to the details collected, processed, and utilized by PharmaServ Express about its suppliers, vendors, or potential partners.
Merchants:
Non-Personal Data –
Personal Data –
Doctors:
Non-Personal Data –
Personal Data –
Manner of Collection:
We collect your personal data through the following ways –
Users
Patients
Merchant
Doctor
b. Basis, use and purpose for processing of personal data
PharmaServ Express uses the following lawful criteria for processing personal data:
Processing is justified when it is necessary to fulfill a legal obligation imposed on the Organization.
Processing is justified when it is necessary for the execution or fulfillment of a contract with the data subject.
Processing is justified when it is necessary to safeguard the data subject’s essential interests, particularly those related to life and health.
Processing is justified when it is necessary to fulfill the legitimate interests of the Personal Information Controller (PIC) or Personal Information Processor (PIP), provided that these interests do not override the fundamental rights and freedoms of the data subject.
Processing is justified as the data subject has given his or her consent
In these instances, your personal data is utilized for the following purposes:
Usage
Your personal data is used for the following use cases –
Users:
Patients:
Merchants:
Doctors:
PharmaServ Express uses the following services and tools to run its software application:
Apple, Google and Microsoft Services –
c. Log Management
Log files are records of events, activities, or system states generated by software applications, operating systems, or devices. These files contain time-stamped entries that document important system behaviors, errors, warnings, and other runtime details.
The following log file data shall be collected by PharmaServ Express:
The collection of log data is for the purpose of:
d. Risks involved
Risk refers to the possibility of an incident causing harm or posing a threat to either a data subject or an organization. Such risks may lead to the unauthorized collection, use, disclosure, or access to personal data. This includes threats to the confidentiality, integrity, and availability of personal information, as well as the potential for processing activities to violate general data privacy principles and the rights of data subjects.
To mitigate these risks, we implement appropriate physical, technical, and organizational security measures to safeguard personal data. While these safeguards help maintain confidentiality, integrity, and availability, they do not provide absolute protection against all risks. Certain threats, such as targeted cyberattacks, malware, ransomware, computer viruses, or unauthorized access to physical records, may still pose challenges in securing personal data.
e. How information is protected and processed securely (security measures)
Organizational security measures
They refer to policies, procedures, and controls put in place to ensure the protection of personal data within an organization.
Physical security measures
They refer to safeguards that protect the physical storage and access points of personal data to prevent unauthorized access, destruction, or loss. These measures are aimed at ensuring that physical locations where personal data is processed, stored, or disposed of are secure from both internal and external threats.
Technical security measures
They refer to the technological controls and systems implemented by organizations to protect personal data from unauthorized access, breaches, and other cyber threats. These measures are essential to ensure the confidentiality, integrity, and availability of personal data in electronic formats.
f. Storage and retention
PharmaServ Express stores your personal data in a computer server and through the use of virtual cloud services.
We will retain your personal data for a period of two (2) years from the last triggering event. Such triggering events include last sign-in and last transaction using PharmaServ Express’ software application through a timestamp.
Upon termination of our legitimate purpose behind the processing of your personal data, we will securely dispose of the same data following our data retention and disposal policy.
Some instances may arise when PharmaServ Express will retain your information for historical data, statistical and data analysis purposes, but we will remove personal identifiers to establish and maintain the confidentiality and security of your information.
g. Disclosure and Transfer of Personal Data
PharmaServ Express will share personal data with third-parties within the Philippines, for the purposes and use cases stated in this Privacy Policy, specifically:
Users Data:
Patients Data:
Merchants Data:
Doctors Data:
PharmaServ Express may disclose personal data with third-parties who need access to such information to carry out work on behalf of the Company, provided that similar levels of information security and data protection are in place. To comply with relevant laws and regulations, PharmaServ Express executes Data Sharing Agreements, Outsourcing Agreements, Non-disclosure Agreements and other contractual means with third-parties to protect your personal data.
h. Selling of Personal Data
There may be instances where PharmaServ Express will sell data, but in an aggregated form where personal identifiers that point to a person’s exact identity are deleted, prior to selling, for statistical and research purposes.
i. Disposal
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable laws and regulations. Once the retention period expires or when data is no longer required, we securely dispose of it using industry-standard methods to prevent unauthorized access, retrieval, or reconstruction.
Data Disposal Methods –
To ensure the secure disposal of personal data, we implement the following measures:
1. Data Wiping
We use specialized software tools to permanently erase data from storage devices. This process ensures that the deleted data cannot be recovered or reconstructed.
2. Overwriting
We overwrite existing data with random values multiple times, rendering the original data irretrievable. This method is applied to electronic records stored on hard drives, servers, and other digital storage media.
PharmaServ Express disposes personal data that have served their legitimate purpose through the following secure means according to User Interface –
Users and Patients Data:
Deletion of electronic documents and files –
Merchants and Doctors Data:
Deletion of electronic documents and files –
IX. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact us at:
Data Protection Officer (DPO)
PharmaServ Express
Address:
89 Mayor Gil Fernando Ave.
San Roque, Marikina City
Philippines
Email: dataprotection@pharmaservexpress.com
Phone: (+63) 920 861 6911
X. Policy Review and Updates
This Privacy Policy shall be regularly reviewed and updated to ensure its continued relevance, effectiveness, and compliance with applicable laws, regulations, and industry standards, including the Philippine Data Privacy Act of 2012 (R.A. 10173).
The Data Protection Officer (DPO), in coordination with relevant stakeholders, shall conduct a formal review at least once annually or whenever there are significant changes in:
Any revisions to this Privacy Policy shall be approved by Management and communicated to all affected stakeholders. The latest version of this policy shall be made available through our Company website, internal portal, or other official communication channels.