Privacy Notice

Agile Inference Business Support Services ("Agile Inference") recognizes and values your data privacy rights. We seek to uphold them in accordance with the law.

In this Statement…

Personal data refers to any information that identifies you as a person. As defined by the Philippine Data Privacy Act of 2012, this may be “sensitive personal information.”

Data privacy refers to the necessity to preserve and protect any personal data collected by an organization from being accessed by a third party.

This Privacy Policy Statement aims to explain the following:

Your data privacy rights

Your data privacy rights are protected by the Philippine Data Privacy Act of 2012. This law states that you have the right to:

• Be informed. You must be advised if your personal data will be or has been processed. This includes the existence of automated decision-making and profiling in select transactions.
• Access. You have the right to reasonable access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
• Rectify incorrect data. You have the right to correct any error in your personal data and, if warranted, request immediate rectification.
• Erase or block. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from Sun Life's filing system, without prejudice to Sun Life continuing to process personal data for commercial, operational, legal and regulatory purposes.
• Secure data portability. Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of it from Sun Life for your further use.
• Be compensated for damages. You shall be compensated for any damage sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms.
• File a complaint. You may file a complaint or exercise your rights above by reaching out to our Data Protection Officer in the contact details provided below.

What personal data we collect

At Agile Inference, we ask you for your personal data when you:

• Become our subscriber, member, partner, vendor, supplier, employee or contractor
• Contact us via phone, email, contact form, or any social media platform

The personal data we collect from you may include the following:

• Name, age, sex, civil status, date and place of birth, nationality and/or citizenship, address, and contact details
• Employment or business information, and source of funds/property, wealth, and income
• Medical information
• Financial position and objectives, income, and investible assets
• Payment card number or bank account details
• Government-issued identification numbers [e.g., Passport, Tax Identification Number (TIN), Social Security System (SSS) or Government Service Insurance System GSIS) Numbers]
• Beneficiaries’ information
• Other information that you have directly provided us

We may also ask for personal data from other sources whom you have permitted to share your information with us. These sources may include your financial advisor, other insurers, reinsurers or distribution partners, the Medical Information Database, credit bureaus or aggregation agencies, government and other regulatory bodies, and other third parties.

There may be cases where third parties send us personal information even without us requesting. In such cases, we will determine if we can legally keep the information and use it for the declared purpose.

It must be noted that this Statement does not apply to third party websites which have links to our sites. The processing of your personal data in a third party site is subject to their own Data Privacy Policy. Agile Inference will not be responsible for the information collected from such sources, neither will Agile Inference be liable for any loss or damage caused by the use of or reliance on such third party.

Where we use your personal data

We process your personal data based on your consent, legitimate business interest, and lawful processing. We use it only for:

• Processing and underwriting (both medical and financial) applications for financial and insurance products and services;
• Providing, administering, and servicing our products and services to help you meet your needs, including for purposes of improving/upgrading our systems and business processes or appointing third party vendors;
• Assessing your suitability for products and services, including conducting data analytics, market research, and surveys to offer you better products and services;
• Settling claims under your insurance or investment plan with any person or organization, who has relevant information about you, which includes institutions, investigative agencies, insurers, and reinsurers;
• Complying with applicable laws, regulations, directives, issuances by, or agreements and obligations of Sun Life to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
• Identifying, investigating, and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to submitting reports to the Anti-Money Laundering Commission (AMLC) and other regulators;
• Enhancing risk assessment and preventing fraud, including but not limited to uploading medical information in the Medical Information Database, in line with the Insurance Commission's (IC) Circular Letter No. 2016-54 ;
• Enforcing and/or defending the rights of Agile Inference before any agency, court, tribunal, quasi-judicial body;
• Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service in which you are part of
• When necessary or desirable in the context of an employer-employee relationship; and
• Enabling Agile Inference to manage its businesses and ensuring that we are able to identify, measure, manage, and mitigate any risk that may come up.

We may use your information for other purposes necessary to provide insurance, investment, and other incidental services in line with your transactions.

When using your data, we may utilize manual and/or technology-enabled data processing systems to make automated decisions and help us serve you, including underwriting, profiling, orphan policy handling, finance-related functions, letter preparation and printing, email and call validation, document and identity verification, and other processes. For these activities, we will inform you and ask for your consent (if necessary) before proceeding.

Meanwhile, partnerships and corporate entities that Agile Inference works with are expected to:

• Advise concerned people of the purpose/s of collecting personal data, including other relevant information and disclosure of the said data to Agile Inference
• Inform them of their data privacy rights; and
• Obtain the necessary consent and authority to disclose personal data of its directors, officers, employees, members, and other representatives to Sun Life, as mandated by the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable laws and regulations.

How we protect your personal data

Agile Inference keeps your personal data in paper-based files and electronic records. While the processing of your personal data exposes you to financial, legal, regulatory, or reputational risks that may result from its unauthorized processing or disclosure, Agile Inference is committed to protecting your privacy by:

• Maintaining physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use, or modification
• Using a secured server behind a firewall, encryption, and other secured controls
• Limiting access on a need-to-know basis.

Agile Inference takes responsibility for all your personal data in our possession. This includes information transferred to third parties who perform services on our behalf, whom we require to strictly adhere to our privacy policies and practices.

Personal data sharing and disclosure

We may disclose and share your personal data based on your consent, legitimate business interest, and lawful processing, to the following parties:

• Any member of the Agile Inference here and abroad, its directors, officers, employees, duly authorized representatives, related companies, affiliates, financial advisors, and mutual fund representatives;
• Third party service providers and vendors including encoding, printing and courier services; credit card processors; IT software providers; hosting vendors; partner doctors, hospitals and medical facilities; and customer support providers who are obliged to keep your personal data confidential. They will have access to your personal data only as necessary to perform their requested function on your behalf, and only if their security and privacy standards are acceptable to Agile Inference;
• Business partners who help us market and distribute our products and services;
• The Medical Information Database administered by the Philippine Life Insurance Association (PLIA) and accessible to life insurance companies, for purposes allowed under Insurance Commission (IC) Circular Letter No. 2016-54 , loan database administered by the Credit Information Corporation and other databases administered by similar agencies;
• Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
• Reinsurers and professional advisers including accounting, tax, financial or legal counsel; or
• Anyone we consider necessary for purposes of providing you products and services and other lawful purposes mentioned above.

Personal data retention

Your personal data will be retained by Agile Inference throughout the duration of your plan, investment, or account and/or until the expiration of the retention limit set by Agile Inference standards, industry standards, laws and regulations. This period will be counted from account closure and will be set until destruction, disposal or anonymization of records, unless withdrawn in writing or withheld due to changes in the information supplied by the Company.

Privacy policy statement terms

Agile Inference reserves the right to update or change sections of this Privacy Policy Statement any time and without prior notice. We will exert reasonable efforts to reach out to our clients in case there are significant changes, but we highly encourage you to review this Statement every now and then.

If you have questions about this Privacy Policy Statement, our data processing activities, or transactions made via this website, you may contact Agile Inference’s Data Protection Officer at contact@agileinference.com