SINAVEX Earn Privacy Notice

1 About this notice

SINAVEX Earn is a Philippine rewards and insights platform where eligible users answer questions with original written responses and may receive rewards based on response quality. SINAVEX INFORMATION TECHNOLOGY SOLUTIONS determines how and why personal information on SINAVEX Earn is processed and acts as the personal information controller.

This notice should be read together with the SINAVEX Earn Terms and Conditions.

2 Information we collect

Account information

• First and last name;
• email address;
• Philippine mobile number and its verification status; and
• your password, which is stored only as a one-way cryptographic hash and cannot be read by SINAVEX staff.

Profile and demographic information

• Birth date, used to confirm eligibility and to derive a broad age range;
• structured address (address lines, barangay, city or municipality, province, postal code and country);
• optional gender or self-description;
• education level, employment status, occupation or role, industry and work arrangement;
• skills, languages spoken, interests and hobbies;
• technology familiarity, devices commonly used and internet usage frequency;
• shopping or consumer-interest categories; and
• optional household size and an optional broad household-income range (you may choose “Prefer not to say”).

We do not ask for religion, political affiliation, sexual orientation, health conditions, government identification numbers, or banking passwords and credentials as part of your profile.

Questions and responses

• The questions assigned to you, questions you skip, and the written responses you submit;
• evaluation results, reward calculations, review requests and their outcomes; and
• submission metadata such as timing, word and character counts, and basic interaction signals (for example, whether text was pasted) used for quality and fraud prevention.

Technical and security records

• IP address, browser and device user-agent information;
• login records, active sessions and session history;
• security events, such as failed sign-in attempts, verification failures, rate-limit events and account holds; and
• audit records of significant account and administrative actions.

Financial and payout information

• Your rewards ledger, including credits, reserved amounts, payouts, reversals and adjustments;
• payout destination details: the selected bank or e-wallet institution, account holder name and account number; and
• withdrawal and transfer records, including references and statuses reported by payment providers.

Consent records

The versions of the Terms, this Privacy Notice and the data and AI consent you accepted, together with the date and time, IP address, browser user-agent and consent status.

Support and privacy requests

Messages and requests you send through the Privacy Center or other support channels, and our responses.

3 How we use information

We process personal information only for legitimate, declared purposes, including:

• Account creation and management — registering you, verifying your mobile number and keeping your account up to date;
• Eligibility — confirming that you meet the age and other participation requirements and reviewing accounts before activation;
• Personalising questions — generating questions relevant to your non-sensitive profile attributes;
• Answer evaluation and reward calculation — assessing response quality and computing rewards within the applicable limits;
• Withdrawals — validating payout destinations and sending transfers through payment providers;
• Fraud prevention and security — detecting duplicate or automated submissions, account sharing, unusual activity and unauthorised access, and protecting users and the platform;
• Customer support — responding to questions, review requests and privacy requests;
• Analytics, research and system improvement — understanding how the platform is used and improving its features and quality;
• Machine-learning and AI purposes — where permitted by law and covered by your consent, developing, training, testing, evaluating and improving machine-learning and artificial-intelligence systems; and
• Legal and compliance requirements — keeping financial and audit records, responding to lawful requests, and establishing, exercising or defending legal claims.

4 Lawful basis and consent

Depending on the purpose, we process personal information on the basis of your consent, the performance of our agreement with you under the Terms, compliance with legal obligations, and our legitimate interests (such as securing the platform and preventing fraud), as permitted under the Data Privacy Act of 2012.

During registration you are asked to give a separate, specific consent regarding the use of the information you submit. That consent reads:

I specifically acknowledge and consent that SINAVEX INFORMATION TECHNOLOGY SOLUTIONS may collect, store, analyze, and use the information, demographic details, written responses, and other data I voluntarily submit through SINAVEX Earn for operating the platform, research and analytics, product and service improvement, and, where permitted by applicable law and described in the Privacy Notice, the development, training, testing, evaluation, and improvement of machine-learning and artificial-intelligence systems.

This consent is recorded with its version, date and time. Marketing communications, if offered, require a separate optional consent and are never a condition of registration.

You may withdraw consent by submitting a request through the Privacy Center. Withdrawal does not affect processing carried out before the withdrawal, and certain processing may continue where another lawful basis applies (for example, retaining financial records). Because this consent is necessary to operate SINAVEX Earn, withdrawing it may mean you can no longer participate in reward-bearing activities.

5 AI processing and data minimization

SINAVEX Earn uses artificial-intelligence services, operated on our servers and not in your browser, to generate personalised questions and to help evaluate responses. We apply data minimization to this processing:

• For question generation, we send only a limited, non-identifying profile context, such as a broad age range instead of your birth date, and your province instead of your street address, together with attributes such as industry, skills, interests, education level, employment category and technology familiarity.
• For evaluation, we send the question and the text of your response.
• We do not send your name, email address, mobile number, street address, birth date, bank or e-wallet account details, password, one-time codes, session data or IP address to AI services.

Because your written responses are sent for evaluation, please do not include personal details about yourself or others, such as full names, contact numbers, addresses or account information, in your answers.

Automated evaluation contributes to reward decisions. Automated systems can make mistakes; you may request a review of an evaluation through the review process in your answer history while it is available, and suspected policy violations with significant consequences may involve human review.

Account activation may also be assisted by automated review. After you complete your profile, non-identifying profile information (such as your age range, province, employment category, occupation, industry, skills and interests, but not your name, contact details, birth date, address, gender or income) may be checked by an AI service for consistency. Automated review can approve an account; it does not reject accounts, and accounts that are not approved automatically are reviewed by our team.

Withdrawal requests may also be reviewed with automated assistance. An AI service may receive a summary of account activity (such as account age, answer and reward statistics, previous withdrawal counts and security-event counts, but not your name, contact details, bank or e-wallet name, or account number) to help decide whether a withdrawal can be approved automatically. Automated review does not reject withdrawals; requests that are not approved automatically are reviewed by our team.

6 Service providers and disclosures

We do not sell your personal information. Where necessary for the purposes in this notice, personal information may be processed on our behalf by carefully selected service providers, under contractual or other arrangements that require appropriate confidentiality and security. These may include providers of:

• hosting, cloud infrastructure, networking and data storage;
• content delivery, network security and bot or abuse protection;
• artificial-intelligence services used for question generation and response evaluation;
• communications, such as SMS or email delivery;
• payment and payout processing, including banks, e-wallets and payment gateways that receive the information needed to complete a transfer; and
• security, monitoring and customer-support tools.

We may also disclose personal information when required by law, regulation, court order or a lawful request of a government authority; to protect the rights, safety and security of users, SINAVEX or the public; to investigate fraud or security incidents; or in connection with a merger, acquisition or reorganisation, subject to appropriate safeguards.

Research, analytics and machine-learning outputs that we share with others, if any, are provided in aggregated or de-identified form unless you have given specific consent or the law otherwise permits.

7 International processing

Some technology providers, including infrastructure, network security and AI service providers, may store or process information in countries outside the Philippines. Where this occurs, we take reasonable steps so that the information remains protected in a manner consistent with the Data Privacy Act of 2012, including through contractual safeguards and by limiting the information shared to what is necessary.

8 Retention

We keep personal information only for as long as necessary for the purposes described in this notice, or as required or permitted by law. In general:

• Active accounts — account, profile, response and consent information is kept while your account remains open.
• Closed accounts — after an account is closed, personal information that is no longer needed is deleted or anonymised within approximately 24 months, unless it must be retained for the reasons below.
• Financial, payout and audit records — rewards ledger entries, withdrawal and transfer records, and related audit records are retained for up to 10 years to meet accounting, tax, legal and dispute-resolution requirements.
• Security logs — login records and security events are retained for up to 24 months, or longer where needed to investigate an incident or fraud.
• Consent records — retained for as long as needed to demonstrate the consent you gave, including after account closure where required.

Requests to close an account or delete information are handled in line with these retention requirements. Records that must be kept are not deleted immediately, but are restricted to the purposes for which they are retained. Where information is used in de-identified or aggregated form, it may be kept for research and system improvement.

9 Security

We implement organisational, physical and technical measures intended to protect personal information against loss, misuse and unauthorised access, disclosure or alteration. These include:

• encrypted connections (HTTPS) between your browser and SINAVEX Earn;
• one-way hashing of passwords;
• application-level encryption of highly sensitive stored fields, such as payout account details and street address information;
• role-based access for administrators, with masking of payout details by default and audit logging of sensitive access;
• server-side processing of calls to AI and payment services, so that service credentials are never exposed to browsers; and
• rate limiting, session controls and monitoring for suspicious activity.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a personal data breach that requires notification, we will notify affected users and the National Privacy Commission as required by law.

10 Your rights

Subject to the conditions and limitations of the Data Privacy Act of 2012, you have the right to:

• be informed about whether and how your personal information is processed;
• access your personal information;
• object to processing, including processing based on consent or for certain purposes;
• rectify inaccurate or incomplete information;
• erasure or blocking of information where legally applicable;
• data portability, where applicable, to obtain a copy of your information in an electronic, commonly used format;
• withdraw consent, without affecting processing already carried out;
• damages for loss caused by inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of personal information; and
• lodge a complaint with the National Privacy Commission.

To exercise these rights, sign in and use the Privacy Center in your profile, where you can submit requests for access, correction, account closure, withdrawal of consent, or other privacy inquiries.

We may need to verify your identity before acting on a request, and we will respond within the period required by law. Some requests may be limited where we must retain information for legal, security or financial record-keeping reasons.

11 Age requirement

SINAVEX Earn is currently available only to individuals who are at least 18 years old. Age is confirmed from the birth date provided during profile completion. Accounts of users under 18 are not activated. If we learn that we have collected personal information from someone under 18, we will take steps to delete it or limit its retention to what is legally required.

12 Cookies

SINAVEX Earn uses only cookies that are essential for the service to work securely:

• Session cookies that keep you signed in and end when you sign out or your session expires; and
• Security cookies that help protect forms and requests against cross-site request forgery and other attacks.

These cookies are marked so that they are not readable by scripts on the page and, where supported, are sent only over secure connections. We do not use advertising or cross-site tracking cookies. If an optional bot-protection check is shown on sign-up or sign-in, its provider may process technical information needed to perform that check.

13 Changes to this notice

We may update this Privacy Notice from time to time. Each version is identified by a version number. When we make material changes, we will provide appropriate notice, for example through your account, and where required we will ask for renewed acknowledgement or consent.

14 Contact

SINAVEX INFORMATION TECHNOLOGY SOLUTIONS is responsible for personal information processed through SINAVEX Earn.

For privacy questions or requests, please use the contact channel provided in your account’s Privacy Center, available from your Profile page after signing in.