Draft for review. This document is a draft template and is not legal advice. It must be reviewed and finalized by a qualified Philippine lawyer before publication. Bracketed items like [Company legal name] are placeholders to be completed.

Privacy Policy

Effective date: [effective date]

[Company legal name] ("PASUGO," "we," "us," or "our") operates the PASUGO mobile application and this website, a local food and goods delivery service for Buug, Zamboanga Sibugay. We are committed to protecting your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

This Privacy Policy explains what personal information we collect, how we use and share it, how long we keep it, and the rights available to you as a data subject. By using PASUGO, you acknowledge that you have read and understood this Policy.

1. Information We Collect

We collect the following categories of personal information to provide and improve our services:

Account information — name, mobile number, email address, and role (customer, merchant, or rider).
Delivery information — saved addresses, map pin location, barangay, and delivery notes.
Order information — items ordered, order history, payment method selection, and communications related to an order.
Location data — device location used for delivery, live order tracking, and rider navigation (collected with your permission).
Device and usage data — device identifiers, app version, and diagnostic information used to operate the service and send notifications.
Communications — messages exchanged through in-app chat and inquiries you send to support.

2. How We Use Your Information

We process your personal information for the following purposes:

To create and manage your account and verify your identity.
To process, fulfill, and deliver your orders, including matching orders with merchants and riders.
To enable live order tracking, navigation, and in-app communication between customers, merchants, and riders.
To send service-related notifications such as order status updates.
To provide customer support and handle complaints within the applicable complaint window.
To detect, prevent, and address fraud, duplicate orders, and misuse of the service.
To comply with legal obligations and enforce our Terms & Conditions.

We rely on lawful bases under RA 10173, including the performance of a contract with you, your consent (for example, for location access), our legitimate interests, and compliance with legal obligations.

3. Sharing and Disclosure

We share personal information only as necessary to operate the service:

With merchants and riders involved in fulfilling your order (for example, your name, delivery address, and order details).
With service providers that support our operations, such as hosting, maps, messaging, and analytics, under appropriate data protection terms.
With government authorities or other parties when required by law, legal process, or to protect rights and safety.

We do not sell your personal information.

4. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, to comply with legal, tax, and regulatory requirements, and to resolve disputes. When information is no longer needed, we securely delete or anonymize it. [Specify retention periods]

5. Data Security

We implement reasonable and appropriate organizational, physical, and technical security measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. While we strive to protect your information, no method of transmission or storage is completely secure.

6. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the right to be informed, to access, to object, to rectify, to erasure or blocking, to data portability, to file a complaint, and to be indemnified for damages. To exercise these rights, contact us using the details below.

7. Children's Privacy

PASUGO is not directed to children under the age of majority without the involvement of a parent or guardian. We do not knowingly collect personal information from minors without appropriate consent.

8. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the app or website. Your continued use of PASUGO after changes take effect constitutes acceptance of the updated Policy.

9. Contact Us and Data Protection Officer

For questions about this Policy or to exercise your rights, contact our Data Protection Officer at [DPO name], [support email], [business address]. You may also lodge a complaint with the National Privacy Commission. [NPC registration / seal of registration, if applicable]