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PRIVACY STATEMENT FOR THE TUTOR GROUP

RAREJOB PHILIPPINES, INC. (the “Company” or “RareJob PH”) adopts this Privacy Statement for the Tutor Group (the “Privacy Statement”) in compliance with Republic Act No. 10173 or An Act Protecting Individual Personal Information in Information and Communications Systems in the Government and the Private Sector, Creating for this Purpose a National Privacy Commission, and for other Purposes (the “Data Privacy Act of 2012” or the “DPA”), its Implementing Rules and Regulations (the “IRR”), and other relevant policies, including issuances of the National Privacy Commission (the “Commission”).

Consistent with the State’s policy of protecting the fundamental human right of privacy while ensuring free flow of information, RareJob PH respects and values your data privacy rights, and makes sure that all Personal Information collected from you are processed in adherence to the general principles of transparency, legitimate purpose, and proportionality.

This Privacy Statement shall inform you of our data protection and security measures, and may serve as your guide in exercising your rights under the DPA.

Our Privacy Statement is more than just protecting the Personal Information you may share by reason of your engagement with RareJob, Inc. (the “RareJob JP”) as an independent contractor offering online tutorial services. Our Privacy Statement is also about our obligation to use and disclose this information only for the purposes we have explained to you.

RareJob PH is committed to protecting your information. Your information allows us to provide you the best possible administration of our organization.

Processing of Personal Information
1. Collection
  RareJob PH collects Personal Information from those individuals who wish to be engaged as a Tutor and for Tutors with valid Online Tutoring Services Agreement (the “Service Agreement”) with RareJob JP.
  
  A Tutor uploads onto the RareJob platform certain information necessary for the proper performance of online tutorial services. The uploaded information may include the Tutor’s name, address, email address, date of birth, and other personal or corporate information, in order to better serve the needs of the Tutor. The Tutor who uploaded this information has a secure and password-protected access to it and exclusively designates which users have access to the information uploaded in the RareJob platform.
  
  The collection of Personal Information is part of the Service Agreement between the Tutor and RareJob JP in order to allow the Tutor access to RareJob tools and services; the absence of the collection of this information will cause RareJob PH’s processes to be inefficient. The Personal Information is stored in a secure manner that is only accessible to authorized personnel with secure credentials.
  
  Section IX of the Online Tutoring Services Agreement reads:
  “IX. PRIVACY POLICY
  
  The TUTOR consents to the processing (including international transfer) of his/her Personal Information by RAREJOB, and its subsidiaries or affiliates, as set out in https://www.rarejob.com.ph/tutor/site/privacy_policy. By signing this Agreement, the TUTOR acknowledges that he or she has read, understood, and agreed to the terms of RAREJOB’s Data Privacy Policy referred to herein.
  
  Each Party shall comply with its obligations under all applicable Data Protection laws, in respect to the Online Tutorial Services to be provided under this Agreement.
  
  Each Party agrees, in respect of any such Personal Information supplied to it by the other Party that it shall:
  1. Act on the written instructions from the other Party regarding the processing of such Personal Information under this Agreement and ensure that appropriate technical and organizational measures shall be taken against unauthorized or unlawful processing and accidental loss or destruction of, or damage to, the Personal Information; and
  2. Comply with any reasonable request made by the other Party to ensure compliance with the measures contained in this Section.”
2. For what purposes do we need your Personal Information
  By providing RareJob PH and RareJob JP with your Personal Information, as part of the application procedure prior to commencing online tutoring services with RareJob JP client, you have explicitly authorized and consented to our collection, use, and processing of said information for varied purposes, including but not limited to:
  1. Confirmation of Applicant’s Identity;
  2. Processing of Application (Contacting the Applicant, Demo Lessons, and Orientations);
  3. Providing of schedule and lesson assistance;
  4. Outbound information releases to Tutors from RareJob JP (Important changes, announcements, and promotions);
  5. Confirmation of identity of Tutors during lesson hours;
  6. Confirmation of identity to update Personal Information;
  7. For investigation purposes;
  8. For Tutor Website and Tutor Account access;
  9. To confirm the identity of the Tutor as a response to a request for the disclosing of his/her Personal Information;
  10. To confirm the identity of a former Tutor as a response to a request for the disclosing of his/her Personal Information;
  11. To send updates and notifications regarding tutorial status;
  12. To ensure that all Tutor information to be used for special purposes are secured with a sufficient disclosure agreement; and
  13. To disclose the Tutor Name, Tutor ID, and uploaded Tutor photograph to the Student.
  The use and processing of Personal Information also depends on the Company transaction involved. It may include the following general purposes, among others:
  - To document and manage Company records;
  - To conduct due diligence prior to executing a contract and to facilitate the fulfillment of the terms of the contract thereafter;
  - To respond to queries, complaints, and requests;
  - To provide information about Company services;
  - To conduct research and analysis to improve customer experience;
  - To maintain security; and
  - To comply with legal, regulatory, and contractual requirements or obligations.
3. How Long We Will Retain Your Personal Information
  
  RareJob PH and RareJob JP will ensure that Personal Information under their custody is protected against any accidental or unlawful destruction, alteration, and disclosure as well as against any other unlawful processing.
  
  RareJob PH and RareJob JP will implement appropriate security measures in storing collected Personal Information depending on the nature of the information. All information gathered shall be retained until the expiration of the retention limit set by RareJob PH and RareJob JP’s standards, industry standards, laws and regulations for account closure, and the period set until the destruction, disposal, or anonymization of records.
  
  Retrieval of information, whether printed or in digital copies, shall require the approval of the authorizing authority.
4. Disposal
  
  Upon expiration of the Retention Period, all physical and electronic copies of the Personal Information shall be destroyed and disposed of using secure means that would render the Personal Information unreadable and irretrievable and prevent the occurrence of any Personal Information breach and other security incidents.
With Whom We May Disclose and Share Your Personal Information
RareJob PH and RareJob JP maintain the confidentiality on all data and information about the Tutor that come to their possession even after termination of the contractual relations. Personal Information under custody shall be disclosed only as permitted by applicable law and pursuant to a lawful purpose. For this reason, we may disclose and share your Personal Information to the following:
- Any member of the Board of Directors, officers, employees, duly authorized representatives, related companies, affiliates or financial advisors, clients, and customers of RareJob PH and RareJob JP;
- Third party service providers and vendors including credit card processors, data analytics and customer support providers, and IT service providers who are bound by an obligation of confidentiality. They will have access to your Personal Information only as necessary to perform their requested function on your behalf, and if they have adequate security and privacy standards acceptable to RareJob PH and RareJob JP;
- Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
- Professional advisers including accounting, tax, financial, or legal counsel; or
- Anyone we consider necessary for purposes of providing you products and services and other purposes mentioned above.
The gathered information from the Tutors shall be disclosed to the following in compliance with the statutory and mandatory documentary requirements by government and quasi-government agencies including their political subdivisions for purposes such as, but not limited to:
1. Periodic submission of tax returns;
2. Submission of loan application to partner banks and other loan institutions upon the Tutor’s authorization; and
3. To the extent not covered by the foregoing, any and all demands, claims, actions or causes of actions, assessments, losses, damages, liabilities, costs and expenses.
RareJob PH, as a subsidiary company, shares Personal Information of the Tutors to RareJob JP for the following purposes:
- Review of Student and Tutor Complaints;
- Review of the performance of Tutors; and
- Checking of Tutor’s compliance within the given basic operations requirements.
Protecting Your Personal Information

RareJob PH and RareJob JP are committed to protecting the privacy of all Personal Information provided to them. RareJob PH and RareJob JP maintain physical, technical, and organizational safeguards to protect your Personal Information against loss, theft, unauthorized access, disclosure, copying, use, or modification.

RareJob PH and RareJob JP limit access to those who have a business need to know. We are responsible for all Personal Information in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your Personal Information in a manner consistent with our privacy policies and practices.
Your Rights as Data Subjects
As Data Subjects, you have the following rights under the DPA:
- Right to be informed. You have the right to be informed whether your Personal Information is being, or have been processed, including the existence of automated decision-making and profiling.
- Right to access. You have the right to reasonable access to, upon written request, the contents of your Personal Information 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; the date when your information was last modified; and information on automated processes where your information will be made as the sole bases for any decision that may significantly affect you.
- Right to rectify erroneous data. You have the right to correct any error in the Personal Information, and if warranted, request immediate rectification.
- Right to erase or block. You have, based on reasonable grounds, the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Information from RareJob PH’s filing system, without prejudice to RareJob PH’s continuing to process Personal Information for commercial, operational, legal, and regulatory purposes.
- Right to secure data portability. Where Personal Information is processed by electronic means and in a structured and commonly used format, you have the right to obtain from RareJob PH, a copy of such information in an electronic or structured format that is commonly used and allows your further use.
- Right to be indemnified for damages. You shall be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of Personal Information, taking into account any violation of your rights and freedom as a Data Subject.
- Right to file a complaint. You may file a complaint or exercise your rights above by reaching out to RareJob PH or to the appropriate tribunal.
Inquiries or requests regarding any matter relating to your Personal Information, including data privacy and security policies of the Company, should be forwarded through email to privacy.policy@rarejob.com.ph.

Complaints may also be sent to privacy.policy@rarejob.com.ph. Any complaint must include the name and contact information of the complainant, including a brief explanation of the complaint and basis thereof. Should there be third parties involved in the complaint, their names and contact information should be provided as well.

The Data Protection Officer or any authorized personnel shall confirm the receipt of the complaint and may require additional information for proper investigation and redress of the complaint.
Limitation on Rights

The rights mentioned under the preceding item are not applicable if the processed personal data are used only for the needs of scientific and statistical research and, on the basis of such, no activities are carried out and no decisions are taken regarding the data subject. These personal data shall be held under strict confidentiality. Also, your rights under this policy statement are subject to other limitations provided by law.

Data Protection Officer

The Company shall have a Data Protection Officer (the “DPO”) who shall oversee the compliance of the organization with the DPA, its Implementing Rules and Regulations, and other related policies, including the conduct of Privacy Impact Assessment (the “PIA”), implementation of security measures, security incident and data breach protocols, and the inquiry and complaints procedure.

The designated DPO of the Company may be reached through the following:

Name:	Ms. Kiara Elluna Tackett
Postal Address:	Unit 1003 10/F Coher Center, 1424 Quezon Avenue, South Triangle, Quezon City, 1103 Metro Manila
Telephone Number:	(02) 8442-3942
E-mail Address:	privacy.policy@rarejob.com.ph

RareJob may outsource any of the functions of the DPO, provided that the DPO shall supervise the PIP/s.

Review of Privacy Statement

This Privacy Statement shall be reviewed and evaluated annually. Privacy and security policies and practices within the organization shall be updated to remain consistent with current data privacy best practices.
Physical Security Measures

RareJob PH and RareJob JP shall implement physical security measures to protect every Tutor’s Personal Information from unauthorized access, use, transfer, removal, or disposal. The Tutors’ Personal Information shall also, as far as practicable, be secured from natural disasters, power disturbances, external access, and other similar threats.

Only authorized personnel shall be allowed access to the Tutor’s Personal Information. Other personnel may be granted access to such data upon filing of a request to that effect with the DPO and the latter’s approval thereof.
How to Contact RareJob

RareJob Philippines, Inc.
Unit 1003 10/F Coher Center,
1424 Quezon Avenue, South Triangle,
Quezon City, 1103 Metro Manila
Attention: Data Protection Officer

You may inquire or request for information regarding any matter relating to the processing of your Personal Information under the custody of the organization, including the data privacy and security policies implemented to ensure the protection of your Personal Information.

If you have questions about this Privacy Statement, our data processing activities, or your dealings with RareJob, you can contact the Data Privacy Officer by email at privacy.policy@rarejob.com.ph.
Amendments

RareJob PH and RareJob, Inc. reserve the right to change the entirety or portions of this Privacy Statement at any time and without notice. It is recommended that you review this Privacy Statement periodically for changes.

Privacy Policy

PRIVACY STATEMENT FOR THE TUTOR GROUP