Privacy Statement

Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

1. Introduction

Axeia Development Corporation (“ADC”), Basic Housing Solutions, Inc.(“BHSI”), and Asiatic Land, Inc. (“ALI”), collectively referred to in this Privacy Statement as the “AXEIA GROUP,” “we,” “us,” or “our,” are committed to protecting the privacy and security of the personal information entrusted to us by our customers, homeowners, buyers, prospective buyers, employees, applicants, suppliers, contractors, business partners, visitors, and other individuals whose personal information we process.

This Privacy Statement explains how the Axeia Group collect, use, disclose, retain, protect, and otherwise process personal information in accordance with Republic Act No. 10173, or the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (“NPC”).

This Privacy Statement provides general information about our personal data processing practices. Depending on the specific transaction, service, project, or processing activity, we may provide additional or more specific privacy notices to data subjects.

2. Companies Covered by this Privacy Statement

This Privacy Statement applies to:

• Axeia Development Corporation (ADC)

• Basic Housing Solutions, Inc. (BHSI)

• Asiatic Land, Inc. (ALI)

Each company is a separate juridical entity and may act as a Personal Information Controller (PIC) in relation to the personal information it collects and processes.

Although these companies are part of the same business group and are engaged in related real-estate activities, each company remains responsible for the personal data processing activities under its respective control.

Where necessary and permitted by law, personal information may be shared among the companies and with authorized third parties, including Equiland Property Management Corporation (EPMC), for legitimate and declared purposes described in this Privacy Statement.

3. Our Commitment to Data Privacy

We recognize that personal information is entrusted to us and must be handled responsibly.

We are committed to observing the principles of transparency, legitimate purpose, and proportionality in the collection and processing of personal information.

We collect and process personal information only when necessary, relevant, and proportionate to a declared, specified, and legitimate purpose and retain personal information only for as long as necessary or as permitted or required by applicable laws and regulations.

4. Personal Information We May Collect

Depending on your relationship or transaction with us, we may collect and process the following categories of personal information:

A. Identification and Contact Information

• Full name

• Date of birth

• Residential or business address

• Telephone/mobile number

• Email address

• Government-issued identification details

• Signature

• Other information necessary to establish or verify identity

B. Property and Transaction Information

• Property, project, unit, and account information

• Reservation and purchase information

• Contract details

• Payment and billing information

• Financing and loan-related information

• Transaction history

• Customer service and communication records

• Requests, inquiries, complaints, and correspondence

C. Employment and Recruitment Information

• Employment and application information

• Educational and professional qualifications

• Employment history

• Government-mandated employment information

• Compensation and benefits information

• Other information reasonably necessary for employment or recruitment purposes

D. Business Partner, Supplier, and Contractor Information

• Contact and business information

• Company information

• Identification and accreditation documents

• Contract and transaction information

• Bank and payment information where necessary

E. Website and Electronic Information

• IP address

• Browser and device information

• Website activity and interaction data

• Cookies and similar technologies

• Information submitted through online forms, inquiries, or other electronic channels

F. Other Information

We may collect other personal information when necessary and appropriate for a specific transaction, service, legal obligation, or legitimate business purpose.

Where sensitive personal information is processed, we shall do so only when permitted by applicable law and with appropriate safeguards.

5. How We Collect Personal Information

We may collect personal information through various means, including:

• Application and registration forms;

• Property reservation and purchase transactions;

• Contracts and other transaction documents;

• Website and online forms;

• Email, telephone, messaging, and other communications;

• Customer service and support channels;

• Recruitment and employment processes;

• Supplier and contractor accreditation;

• Business transactions and engagements;

• Events and activities;

• CCTV and security systems, where applicable;

• Government or authorized third-party sources where legally permitted; and

• Other lawful means.

6. Purposes of Processing

We may process personal information for purposes including:

• Processing property reservations, sales, purchases, and related transactions;

• Preparing and administering contracts and other transaction documents;

• Processing payments, billing, collections, and financial transactions;

• Providing customer service and responding to inquiries, requests, and complaints;

• Communicating with customers, buyers, applicants, suppliers, contractors, and other stakeholders;

• Processing financing, documentation, and other requirements related to property transactions;

• Performing our contractual obligations;

• Complying with legal and regulatory requirements;

• Protecting our properties, personnel, customers, visitors, and assets;

• Preventing fraud, unauthorized transactions, and other unlawful activities;

• Managing suppliers, contractors, and business partners;

• Recruiting, hiring, and managing employees;

• Conducting legitimate business operations and administrative activities;

• Maintaining and improving our systems, services, and processes;

• Conducting internal audits, investigations, risk management, and security activities;

• Sending relevant announcements and communications, subject to applicable privacy requirements;

• Exercising, establishing, or defending legal rights and claims;

• Facilitating property turnover and post-sale activities; and

• Supporting property management and related services provided by authorized property management entities, including EPMC, where applicable.

7. Lawful Basis for Processing

We process personal information only when there is a lawful basis under the DPA and other applicable laws.

Depending on the circumstances, processing may be based on:

• Consent, when required and appropriate;

• Fulfillment of a contract or taking steps at the request of the data subject prior to entering into a contract;

• Compliance with a legal or regulatory obligation;

• Protection of vital interests, where applicable;

• Protection of lawful rights and interests, where permitted by law; or

• Legitimate interests of the company or relevant third parties, provided that such interests are not overridden by the fundamental rights and freedoms of the data subject.

Consent is therefore not necessarily required for every processing activity. Where another lawful basis applies, we will rely on the appropriate lawful basis rather than obtaining consent unnecessarily.

8. Sharing and Disclosure of Personal Information

We may disclose or provide access to personal information when necessary, appropriate, and permitted by law to:

• Other Axeia Group covered by this Privacy Statement;

• Equiland Property Management Corporation (EPMC), where necessary for property management, administration, turnover, and related services;

• Banks, financing institutions, and other financial service providers;

• Government agencies and regulatory authorities;

• Lawyers, auditors, consultants, and professional advisers;

• Contractors, suppliers, and service providers;

• Information technology and cloud service providers;

• Collection and payment service providers;

• Business partners involved in the relevant transaction;

• Courts, law enforcement agencies, or other authorized authorities when legally required; and

• Other persons or organizations where disclosure is necessary for a declared and legitimate purpose and permitted by law.

We limit disclosures to the personal information reasonably necessary for the relevant purpose and implement appropriate safeguards to protect personal information.

9. Sharing of Information with EPMC

Equiland Property Management Corporation (EPMC) is a separate company that provides property management and related services for properties developed, sold, or administered by the Axeia Group.

Where necessary for property turnover, property administration, customer or homeowner assistance, building or community operations, or other legitimate property-management purposes, we may provide EPMC with relevant personal information collected in connection with a property transaction.

Depending on the circumstances, information provided to EPMC may include:

• Name and contact information;

• Property, project, and unit information;

• Buyer or homeowner account information;

• Relevant contract and transaction information;

• Turnover-related information;

• Billing or account information necessary for property management;

• Authorized representative or emergency contact information, where applicable; and

• Other information reasonably necessary for the relevant property-management service.

The information provided to EPMC shall be limited to what is necessary and proportionate to the applicable purpose.

EPMC shall process personal information in accordance with applicable data privacy laws, appropriate security measures, and the terms and conditions governing the relevant processing arrangement.

Depending on the specific processing activity and the respective roles and responsibilities of the parties, EPMC may act as a Personal Information Processor (PIP) on behalf of Axeia Group or as a separate Personal Information Controller (PIC) for processing activities that it independently determines and controls.

Where EPMC acts as a Personal Information Processor, the applicable processing relationship shall be governed by an appropriate contract or other legal arrangement that establishes the obligations and safeguards required under applicable privacy laws.

Where EPMC acts as a separate Personal Information Controller, the applicable data sharing and processing requirements shall likewise be observed.

10. Intra-Group Sharing

Because ADC, BHSI, and ALI are engaged in related real-estate activities, personal information may, where necessary and permitted by law, be shared among these companies for legitimate and declared purposes such as:

• Property sales and administration;

• Customer and transaction management;

• Financing and documentation;

• Customer service;

• Accounting and financial processing;

• Legal and regulatory compliance;

• Information technology and system administration;

• Internal reporting and business administration; and

• Other legitimate business purposes.

Any such sharing shall be limited to information that is necessary and proportionate to the relevant purpose and shall be subject to appropriate organizational, physical, and technical safeguards.

Where the applicable processing arrangement constitutes data sharing between separate personal information controllers, the parties shall observe applicable requirements for data sharing, including appropriate safeguards and transparency to data subjects.

11. Service Providers and Personal Information Processors

We may engage third-party service providers to perform certain functions on our behalf, such as information technology services, cloud hosting, payment processing, document management, customer support, professional services, and other business functions.

Where a third party acts as a Personal Information Processor, we shall use appropriate contractual or other reasonable means to require the processor to implement appropriate safeguards and process personal information only for authorized purposes.

The DPA and its Implementing Rules and Regulations require appropriate contractual arrangements and safeguards when processing is outsourced to a PIP.

12. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with applicable legal and regulatory requirements, to fulfill contractual obligations, to establish, exercise, or defend legal claims, or for legitimate business purposes consistent with applicable laws and regulations.

Different categories of personal information may therefore have different retention periods.

When personal information is no longer required or when its retention is no longer permitted, it shall be securely disposed of, deleted, anonymized, or otherwise processed in accordance with our applicable retention and disposal procedures.

13. Security Measures

We implement reasonable and appropriate organizational, physical, and technical measures designed to protect personal information against accidental or unlawful destruction, alteration, loss, unauthorized disclosure, unauthorized access, and other unlawful processing.

These measures may include, as appropriate:

• Access controls and authorization procedures;

• User authentication;

• Network and system security measures;

• Security monitoring;

• Data backup and recovery procedures;

• Physical security controls;

• Confidentiality obligations;

• Employee privacy and security awareness;

• Policies and procedures governing personal information processing;

• Vendor and service-provider controls; and

• Incident and data breach management procedures.

We continually review and improve our privacy and security measures based on applicable risks, technology, and business requirements.

14. Cookies and Website Technologies

Our websites may use cookies and similar technologies to enable website functionality, improve user experience, analyze website usage, and support relevant website features.

Where required, appropriate information and choices regarding cookies and similar technologies will be provided to website users.

15. Data Subject Rights

Subject to the limitations and conditions provided by applicable law, data subjects have rights under the DPA, including the right to:

• Be informed about the processing of their personal information;

• Access their personal information;

• Correct inaccurate or incomplete information;

• Object to certain processing;

• Request the erasure or blocking of personal information under applicable circumstances;

• Obtain data portability where applicable;

• File a complaint with the National Privacy Commission; and

• Seek damages where provided by law.

16. Exercising Your Data Privacy Rights

If you wish to exercise your rights or raise a concern regarding the processing of your personal information, you may contact our Data Protection Officer using the contact details below.

To protect personal information from unauthorized access or disclosure, we may take reasonable steps to verify the identity and authority of the person making a request before processing the request.

Some requests may be subject to limitations or exceptions provided by law.

If your concern relates specifically to property-management services provided by EPMC, we may coordinate with EPMC or refer the matter to the appropriate privacy contact of EPMC, as applicable.

17. Data Protection Officer

For questions, concerns, requests, or complaints relating to the processing of personal information by the Axeia Real Estate Companies, you may contact:

Data Protection Officer

Axeia Group Real Estate Companies

Email: privacy.axeia@gmail.com / privacy.bhsi@gmail.com / dataprivacy.ali@gmail.com

Address: 6th flr. 611 Westar Bldg., Shaw Blvd., Kapitolyo, Pasig City, MM

Telephone: (02)-8913-3377

For matters specifically relating to EPMC's independent processing activities, the concern may be referred to EPMC's designated privacy contact or Data Protection Officer, where applicable.

18. Complaints

We encourage data subjects to contact us first so that we may properly understand and address their privacy concerns.

If you are not satisfied with our response or believe that your rights under the DPA have been violated, you may also lodge a complaint with the National Privacy Commission, subject to its applicable procedures and requirements.

19. Changes to this Privacy Statement

We may update or amend this Privacy Statement from time to time to reflect changes in our business operations, applicable laws and regulations, technology, or our privacy practices.

The updated version will be made available through our appropriate communication channels or website. The date of the latest revision will be indicated at the beginning of this Privacy Statement.

20. Contact Us

For questions or concerns regarding this Privacy Statement or the processing of personal information by the Axeia Group Real Estate Companies, please contact:

Axeia Development Corporation (ADC)

Basic Housing Solutions, Inc. (BHSI)

Asiatic Land, Inc. (ALI)