Data Privacy

At TOP.Ph, we take your privacy seriously. This Data Privacy Statement explains how we collect, use, disclose, and safeguard your personal information when you use our e-wallet application and services. All information collected through TOP.Ph is directly submitted to the Asia United Bank “(the “Bank”).” 

The terms “The Orange Platform”, “The Orange Company,” “TOP.PH”, “TOP,” “Platform,” “we,” “us” and “our” as used in these T&C refer to The Orange Company, Inc., as well as its employees, directors, affiliates, successors, and assigns. The Orange Company, Inc., is a Filipino electronic money issuer, remittance company and operator of payment systems. 

As a TOP.PH users and the data subject, you have the following rights under the Data Privacy Act of 2012 or the Republic Act No. 10173:

  1. The right to be informed whether your Personal Data is being or has been processed, what data is being processed, and for what purpose plus how such processing is being or has been conducted;
  2. The right to demand reasonable access to your Personal Data with the Bank and obtain a copy of such Personal Data;

iii. The right to object to the processing of your Personal Data;

  1. The right to dispute and rectify any inaccuracy with or error found within your Personal Data with us and the Bank;
  2. The right to deletion or blocking of your Personal Data with us upon discovery and substantial proof that your Personal Data with us are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which such Personal Data were collected;
  3. The right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Personal Data; and

vii. The right to file a complaint.

Hence, we may collect the following types of information:
Personal Information: This includes your name, contact details (email address, phone number), and other identifying information required for account creation and verification
Transaction Information: TOP.PH collects information about your transactions, including payment details and transaction history.
Device and Usage Information: TOP.PH may gather information about your device, such as its unique device identifier, operating system, and mobile network information. We also collect information about how you use our application, including your interactions with TOP.Ph, IP address, and browser type.

Information Disclosure and Sharing with AUB and Third Parties.
TOP.PH may share your personal information with third parties only for the purposes mentioned in this statement or as required by law. TOP.Ph do not sell your personal information to any third party.  With the consent of Users, TOP.PH uses, stores, and processes discloses personal  information about Users for the following purposes: (i) Provide, improve, and develop the Orange platform; (ii) Create and maintain a trusted and safer environment; (iii) Provide, personalize, measure, and improve Orange’s advertising and marketing; (iv) Enable Users to enter into payment transactions; (v) Comply with legal requirements. TOP.Ph may disclose or allow the disclosure of Personal Data to partner entities it deems fit only when necessary to achieve the said purposes.

In the course of your transaction with us,  we may disclose and share your personal data with the following:

  1. Asia United Bank uses your Personal Data for the purposes of providing you AUB services to conduct due diligence, to maintain and administer your prepaid account with AUB, to provide and facilitate your AUB account, to carry out obligations arising from any contracts entered into between you, TOP.PH and AUB, to secure your account from any fraudulent, unauthorized, and illegal transactions, money laundering, and terrorist financing risks. In addition,  AUB and TOP.Ph collects personal information to validate your account or update the information that was initially submitted with supporting documents. To third-party service providers engaged by us and subject to strict confidentiality requirements and security protocols who process personal data on our behalf to provide us services. These service providers will only process your personal data upon our instructions. By providing your consent, you have carefully reviewed the privacy notice or agreement provided by AUB in their website (https://www.aub.com.ph/privacyPolicy).
  2. Third-party service providers engaged by us and subject to strict confidentiality requirements and security protocols who process personal data on our behalf to provide us services. These service providers will only process your personal data upon our instructions.
  3. To government entities such Bangko Sentral ng Pilipinas, Bureau of Internal Revenue, Anti-Money Laundering Council, Credit Information Corporation as may be required by applicable laws and in compliance with our legal obligations and agreement with AUB.
  4. To law enforcement agencies, government authorities, or other third parties if we believe your actions are inconsistent with our contracts or policies, or if we believe there is a need to protect the rights, property, or safety of TOP.PH and the AUB Group.

In lastly, we comply with the applicable laws, rules, regulations, contractual obligations, or orders of court or quasi-judicial and administrative offices. 

Data Security
We employ industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

Data Retention
Electronic records are securely stored in TOP.PH and AUB onsite data center.  We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected or as may be required by applicable laws, rules, and regulations. Thus, the retention of your personal data shall be in accordance with our documented record retention policies.

TOP.PH and AUB have the right to retain User Personal Data in its facilities unless the User requests that his/her Personal Data to be deleted by TOP. Once deleted, your data will destroyed via deletion or anonymization of electronic data, and through such other means that would prevent further processing.  User Personal Data will no longer be searchable or included in anonymous searches and will be completely removed from all the storage locations. However, TOP.PH reserves the right to retain User Personal Data despite a request for deletion by the User under certain circumstances such as when a User’s Personal Data may be necessary to resolve disputes, or if TOP.PH is required to do so by law or when disclosure is necessary to comply with a legal obligation and/or protect and defend the rights or property of Orange or its affiliates. If TOP.PH is required to retain any portion of a User’s Personal Data for such purposes, it shall use reasonable efforts to limit such data to what is necessary to accomplish the particular purpose.

In some instances (such as data analytics, research, historical and statistical analysis, management reporting), we will anonymize your personal data where you will no longer be identifiable.

Your Consent and Choices.
You hereby acknowledge and consent our and the Bank’s policies and requirements under this Policy and the Bank’s Privacy Policy. The act of engaging us and the Bank, using and accessing TOP.Ph and our Services shall likewise be deemed as your implied consent to such policies and requirements, including the collection, use and/or processing of your personal data.

You have the right to access, correct, or delete your personal information. You can manage your preferences and privacy settings within our application.

Updates to this Privacy Statement
We may update this Data Privacy Statement to reflect changes to our practices or for other operational, legal, or regulatory reasons. The updated statement will be posted on our website and within our application.

Contact Us
If you have any questions, concerns, or requests regarding your personal information or this Data Privacy Statement, please contact our Data Protection Officer at customercare@aub.com.ph.

By using our TOP.PH application, you consent to the practices described in this Data Privacy Statement.