PJ Lhuillier Inc. (“PJLI” or “We”) the company behind Cebuana Lhuillier upholds the highest standards of data privacy and is committed to protecting the rights and personal information of all individuals. PJLI ensures that all personal data collected from clients, customers, partners, affiliates, and employees is processed in accordance with the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission.

PURPOSES OF COLLECTING PERSONAL DATA:

We collect only personal information that is voluntarily provided by our clients and customers. This information is obtained when an individual manually or electronically submits inquiries, requests, and transactions and services such as gold and jewelry sales.

Prior to any data collection, we ensure that individuals are clearly informed of the purpose, scope, and intended use of their personal information, in full compliance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable privacy laws.

PERSONAL DATA COLLECTED

To process your registration in the website:

• First Name, Last Name
• Date of birth
• Valid government ID for identity verification
• Contact details (email, mobile number)

To process your gold and jewelry transaction in the website:

• First Name, Last Name
• Email
• Mobile number
• Address

COLLECTION METHOD

Personal data in PJ Lhuillier Inc. (PJLI) is collected digital or online registration allows clients and customers to create accounts via a website, submitting personal details to proceed with your registration and transactions. Additionally, data is gathered through compliance and Know Your Customer (KYC) checks, which may include other personal data.

TIMING OF COLLECTION

Personal information is collected at the time of transaction or registration online. This includes, but is not limited to, the initial submission of details for account creation, gold and jewelry sales, and compliance with Know Your Customer (KYC) requirements.

Additional or updated personal information may be collected periodically, particularly during repeat transactions, system enhancements, or in response to changes in regulatory or security requirements. Data subjects (e.g. clients, customers) will be appropriately notified if further information is required beyond the initial disclosure. Such collection will proceed only with the data subject’s consent and in full compliance with the Data Privacy Act of 2012, its IRR, and related issuances of the NPC.

PURPOSES OF COLLECTED PERSONAL INFORMATION

We collect your personal information to provide secure, lawful, and efficient services, including, but not limited to, the sale of gold, jewelry, and other related offerings. Key data—such as your valid ID, contact details, and transaction information—are essential for verifying your identity, ensuring accurate transaction processing, and complying with applicable laws and regulations, including Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.

Additional information—such as your address, source of funds, and biometric data (e.g., signature, photo, thumbmark)—may be collected to enhance fraud prevention measures and fulfill regulatory requirements. All personal data collected is necessary, relevant, and limited to what is required for the specified purposes, in adherence to the principle of proportionality under the Data Privacy Act of 2012.

STORAGE AND TRANSMISSION OF PERSONAL INFORMATION

We securely store personal data in encrypted databases with strict access controls, allowing only authorized personnel to access it. Data is protected using encryption (e.g., AES-256) and stored on secure servers with regular backups. During transmission—such as online registration or transactions—personal information is encrypted using secure protocols like HTTPS and SSL/TLS. We also use secure file transfer methods (e.g., SFTP, API) for data sharing. To protect data both at rest and in transit, we implement firewalls, intrusion detection systems, regular security audits, and staff training, ensuring all personal data is handled safely and responsibly.

METHOD OF USE

Personal information will only be used for the purposes stated—such as identity verification, transaction processing, gold and jewelry sales, and regulatory compliance—and not for unrelated activities without your consent. In some cases, the data may undergo additional processing like verification, fraud checks, or formatting to ensure accuracy and security, marketing initiatives, and cross selling of products by PJ Lhuillier Inc. and its Affiliates. Throughout its lifecycle, your information is securely collected, processed, stored, retained only as needed, and properly disposed of when no longer required, in full compliance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and related issuances of the NPC.

LOCATION OF PERSONAL INFORMATION

Personal information is stored in secure data centers, which may be either physical or cloud-based, and processed through internal systems or by trusted third-party providers. Backups are encrypted and distributed across multiple locations to ensure data availability and recovery. All data transmissions are secured using encrypted connections.

These practices are designed to comply with applicable data protection regulations, ensuring that personal information is stored and processed safely and responsibly, whether locally or across borders.

DATA SHARING

Your personal information may be shared with authorized employees, affiliates, third-party service providers (e.g., payment processors, collection agents, system providers), regulatory bodies, law enforcement agencies, partners, and for purposes of legal compliance and service fulfillment. We ensure that these transfers are conducted securely and in compliance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and related issuances of the National Privacy Commission (NPC).

RIGHTS TO YOUR PERSONAL DATA

• The right to be informed: ensures individuals are fully aware of how their personal information will be collected, used, stored, shared, and deleted.
• The right to object: ensures that individuals have the right over how their personal information is used, even if the processing is otherwise lawful.
• The right to access: As a data subject, you have the right to request access to the personal information we hold about you. Upon a written and verified request, we will provide you with a summary of the personal data collected, processed, and stored
• The right to correct: it allows individuals to request the rectification of inaccurate or incomplete personal data held by an organization to ensure its accuracy and reliability.
• The right to erase or deletion: allows individuals to request the removal of their personal data from an organization’s records when it is no longer necessary, unlawfully processed, or the individual withdraws consent.
• The right to damages: entitles individuals to seek compensation if they suffer harm or loss due to the unlawful or negligent processing of their personal data by an organization.
• The right to data portability: to obtain and transfer their personal data in a structured, commonly used, and machine-readable format from one organization to another, where technically feasible.
• The right to file a complaint: it allows individuals to lodge a complaint with the National Privacy Commission if they believe their personal data rights have been violated or their data has been unlawfully processed.

Your rights to your personal data are provided in Chapter IV, Section 16 of the Data Privacy Act through the NPC website: https://privacy.gov.ph/data-privacy-act/#w16

SECURITY MEASURES

• Organizational measures: includes mandatory data privacy training programs for employees, the development of privacy policies and manuals, conducting gap assessments, privacy impact assessments of data processing systems, privacy audits, and appointing a Data Protection Officer to ensure compliance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable laws.
• Physical measures: include controlled access points, CCTV surveillance, the presence of security personnel to monitor and manage access, as well as securing computers, laptops, servers, storage devices, and their respective locations.
• Technical measures: should encompass regular data backups, encryption, secure file transfers, robust authentication protocols, frequent software and application updates, restricted access controls, VPN, intrusion detection systems, and implementation of firewalls and antivirus software.

RETENTION AND DELETION

PJ Lhuillier, Inc. ("PJLI", "we", "our", or "us") values your privacy and is committed to protecting your personal data. This Cookie Policy explains how we use cookies and similar technologies on our website, what information they collect, why we use them, and how you can manage your preferences.

By continuing to browse or use our website, you consent to the use of cookies as described in this policy, unless you choose to disable them through your browser.

COOKIE POLICY

I. What Are Cookies

Cookies are small text files stored on your device by websites you visit. These cookies are necessary for the website to function properly and to provide core features such as secure access, session management, and navigation. In addition, we use analytics cookies to collect information about how visitors interact with our website. This data helps us improve overall site performance, content relevance, and user experience.

The types of information collected may include:

• Your IP address
• Browser type and version
• Web pages and time spent on each page
• Approximate geographic location
• Ad impressions and clicks
• Operating systems and device types
• Web browser type

All data collected through these cookies is aggregated and anonymized, and used solely for service improvement and analytical purposes.

II. How We Use Cookies

We use cookies to improve your browsing experience, enhance site functionality, analyze website traffic, and support marketing efforts. These small text files help us remember your preferences, understand how you interact with our content, and deliver relevant information and services. By continuing to browse our site, you consent to our use of cookies in accordance with our Privacy and Cookie Policies.

III. Manage or Disable Cookies

You can manage your cookie preferences at any time. Most web browsers allow you to control or disable cookies through your browser settings. Please note that disabling or blocking certain cookies may impact your experience and limit access to some features of our website.

IV. Third Party Cookies

Our website may allow third-party service providers to place cookies on your device to support features such as analytics, advertising, and social media integration. These cookies are controlled by the third parties and are subject to their own privacy and cookie policies. We do not have direct control over how these third-party cookies operate, but we take steps to ensure that any partners we work with handle your data responsibly and in compliance with applicable data protection laws.

TERMS OF USE

This website is intended to provide general information about our company, services, and offerings. By accessing and using this website, you agree to comply with and be bound by the terms and conditions outlined herein. These Terms of Use govern your access to and use of the website, including any content, functionality, and services offered.

Please read these Terms of Use carefully. If you do not agree with any part of these terms, you must not use this website. PJLI reserves the right to amend or update these terms at any time with effectivity date of 60 days upon publication of the notice.

I. Acceptance of Terms of Use

This website is operated by PJ Lhuillier, Inc. (PJLI). By using this site, you acknowledge that you have read, understood, and agreed to comply with these Terms of Use, as well as our Privacy Policy.

II. Website Content

All content on this site, including text, graphics, logos, images, and other materials, is the property of PJLI or its licensors and is protected by applicable intellectual property laws. You may use the content for personal, non-commercial purposes only. Unauthorized use or reproduction is strictly prohibited.

III. User Conduct

You agree to use the website only for lawful purposes. You must not:

• Engage in any activity that could harm or disrupt the website or its users;
• Attempt to gain unauthorized access to any part of the site;
• Post or transmit any material that is defamatory, offensive, or violates the rights of others.

IV. Intellectual Property

All content, materials, and features available on this website—including, but not limited to, text, graphics, logos, icons, images, audio clips, video, software, and design elements—are the exclusive property of PJ Lhuillier, Inc. (PJLI) or its licensors and are protected by applicable intellectual property laws, including copyright, trademark, and other proprietary rights.

You may view and use the content for personal, non-commercial purposes only. Any unauthorized reproduction, distribution, modification, display, or commercial use of any content from this website without prior written permission from PJLI is strictly prohibited.

All trademarks, trade names, and service marks displayed on this website are the property of PJLI or their respective owners. Nothing on this site should be construed as granting any license or right to use any trademark without the prior written consent of PJLI or the third-party owner.

V. Force Majeure

We shall not be held liable for any failure or delay in the performance of our obligations under these terms due to events beyond our reasonable control. These events may include, but are not limited to, acts of God, natural disasters, war, terrorism, government actions, labor disputes, power outages, internet service interruptions, or other unforeseen circumstances that prevent the normal operation of the website. In such cases, we will make reasonable efforts to resume service as soon as possible.

VI. Third-Party Links

This website may contain links to external websites operated by third parties. PJLI does not control these sites and is not responsible for their content, privacy practices, or any damage or loss that may arise from your use of them.

VII. Disclaimer of Warranties

The information and materials on this website are provided on an “as is” and “as available” basis. PJ Lhuillier, Inc. (PJLI) makes no representations or warranties of any kind, whether express or implied, regarding the accuracy, completeness, reliability, suitability, or availability of the website or the information, products, services, or related graphics contained herein.

To the fullest extent permitted by law, PJLI disclaims all warranties, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted or error-free operation. PJLI does not warrant that this website, its servers, or any email or content sent from the site are free of viruses, malware, or other harmful components.

Your use of the website and any reliance on the materials contained herein is at your own risk.

VIII. Limitation of Liability

To the fullest extent permitted by applicable law, PJ Lhuillier, Inc. (PJLI), its affiliates, directors, officers, employees, agents, and service providers shall not be liable for any direct, indirect, incidental, consequential, special, or exemplary damages arising out of or in connection with your access to or use of this website, including but not limited to damages for loss of profits, data, goodwill, or other intangible losses.

This limitation of liability applies regardless of the legal basis of the claim—whether arising from warranty, contract, tort (including negligence), or any other legal theory—even if PJ Lhuillier, Inc. (PJLI) has been advised of the possibility of such damages. Your sole and exclusive remedy for any dissatisfaction with the website or its content is to stop using the site.

IX. Modifications

PJ Lhuillier, Inc. (PJLI) reserves the right to modify, update, or revise any part of this website, including these Terms of Use, at its sole discretion. Any such changes will be posted on this page and will take effect 60 days after the date of publication, unless otherwise stated.

We encourage users to review the Terms of Use periodically to stay informed of any updates. Continued use of the website after the 60-day notice period shall constitute acceptance of the revised terms.

X. Governing Law

These Terms of Use, including any disputes arising from or related to your use of this website, shall be governed by and construed in accordance with the laws of the Republic of the Philippines. By accessing and using this website, you agree to submit to the exclusive jurisdiction of the proper courts of Makati City, Philippines, waiving any objections to such venue.

XI. Entire Agreement and Severability

These Terms of Use, together with our Privacy Policy and any other legal notices published on this website, constitute the entire agreement between you and PJ Lhuillier, Inc. (PJLI) regarding your use of the website. They supersede any prior agreements, understandings, or representations, whether written or oral, related to such use.

If any provision of these Terms is found to be invalid, illegal, or unenforceable under applicable law, that provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect.

How to contact us:

Feedback, queries and transaction concerns on our products and services: [email protected]

Data Privacy-related queries and concerns:[email protected] , [email protected]