Who are we and what does your privacy mean to us?

LG Electronics, Inc., ("LGE"), together with LG Electronics Philippines, Inc. ("LGEPH"), and other LGE-affiliated companies and subsidiaries (collectively, "LG Group", "we", "our", or "us") respect and value your fundamental right of data privacy. LGEPH processes Personal Data collected from our patrons, clients, and customers ("Data Subjects", or "you"), is processed in adherence to the general principles of transparency, legitimate purpose, and proportionality. This Privacy Notice ("Notice") is adopted by LGEPH in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and other relevant policies, including issuances of the National Privacy Commission. This Notice shall inform you of our data protection and security measures and may serve as your guide in exercising your rights under the DPA. If you do not provide the necessary Personal Data to us (we will indicate to you when this is the case, for example, by making this information clear in our registration forms), we may not be able to provide you with our goods and/or services. This Notice can change from time to time. For more information, inquiries, or requests regarding this Privacy Notice and/or your privacy rights, you can contact us at lgeph.dpo@lge.com.

What does this Privacy Notice cover?

This Notice covers both our online and offline Personal Data collection and processing activities, including Personal Data collected through our LGE mobile applications available at the iOS App Store (LG Electronics, Inc. Apps on the App Store) and Google Play Store (Android Apps by LG Electronics, Inc. on Google Play) ("LGE App"), when you use our LG systems, such as LG DualCool Partners Application, and when you access, use, or avail of any services, through any other websites or applications owned and operated by LGE brands or products that direct the viewer or user to this Notice ("LGE Services"). Our services, websites, and mobile applications may offer links to websites and/or other mobile applications that are operated or owned by third parties and not by LGE. If you visit these linked websites or applications, you should read their privacy notice, terms and conditions, and policies. We are not responsible for the policies and practices of third-party Personal Information Controllers (PIC). Any information you give to those organizations is governed by their privacy notice, terms and conditions, and other policies.

• Name and contact details (email, phone number)
• Business details (company name, type, address)
• Login credentials and transaction history
• Device information, location data (with consent), and usage logs

Why do we process your Personal Data?

Consent

To register, access, or use the LG DUALCOOL Partners Application system, your consent is required to proceed, unless there are other criteria for lawful processing. By consenting, LGE automatically collects Personal Data necessary for the use of the LG DUALCOOL Partners Application system. Without this consent, your personal information may not be used or accessed through the LG DUALCOOL Partners Application system.

Provision of services based on your contractual relationship with us

We process your Personal Data when this is necessary to fulfill each party's obligations under our contractual relationship. We also use the collected Personal Data to identify and authenticate you, so you may continue to use the LG DUALCOOL Partners Application system. We further collect your Personal Data to resolve technical issues and send necessary information relating to the LG DUALCOOL Partners Application system.

Compliance with legal obligations

We also process your Personal Data when this is necessary for us to comply with our legal obligations under applicable laws, court orders and subpoenas, and responses to legally binding requests from the government, law enforcement agencies, public authorities and/or regulatory offices.

Legitimate interests of the LG Group and/or third parties

We also process your Personal Data to the extent that it is necessary to fulfill our legitimate interests (or those of third-party providers), which include:

• Improving user experience, including by providing you with tailored functions, such as an autofill function, a quick search function based on your most visited webpages and additional content tailored to your interests;
• Carrying out direct marketing activities composed of marketing communications via email, phone calls, post, text messages, social media channels, or via push notifications through our mobile apps, presenting you with online ads both on our services and on third party websites, creating marketing profiles and personalizing the recommendations and marketing content we and others present to you, and running promotions, competitions and prize draws
• Protecting our business operations against, identifying and preventing fraud and other illegal activities or activities prohibited by our User Agreement:
  • By verifying the identity of the user;
  • By investigating the registration of the user;
• Protecting the security, availability, and integrity of our services and information systems, by using authentication mechanisms and other security measures, monitoring our systems for security threats, keeping back-ups, anonymizing data, and conducting system maintenance services
• Effectively managing our business by generating reports and analyzing the performance of our services through the use of aggregated information, auditing our business processes, and using statistics to make informed business decisions based on:
  • Store and sales management information related to store performance and installation information

Where we rely on our legitimate interests, we have carried out a balancing test to consider what the impact of the processing will be on individuals and to determine whether individuals' interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of this Privacy Policy.

What data do we collect and how do we collect it?

We collect Personal Information and/or Sensitive Personal Information in ways and means as stated below:

• When you access, use, or avail of LG DUALCOOL Partners Application, you will provide us with your Personal Data such as your name, email address, phone number, Tax Identification Number, and TESDA National Certificate number.
• When you access, use, or avail of LG DUALCOOL Partners Application through your mobile phone, you will provide us with your device information, such as your device name, IMEI, UUID, OS version, country, location, language, IP address, mac address, connected modem information, internet router information, mobile ad identifier and/or settings of devices.
• Furthermore, when you access, use, or avail of LG DUALCOOL Partners Application through your mobile phone, you will also provide us with your log information such as your login credentials, usage information, URL, redirected URL, performance timing, referrer, network type, network info, charge status, ad block info, visit history, the apps, services and features you use.

Who can access your Personal Data?

Within the LG Group, we may share and disclose your Personal Data with Our subsidiaries, or to Our affiliates, employees, and agents, to the extent necessary or reasonable to provide the LGE Services to you, to comply lawful Purposes and fulfill Our Legitimate Interests. But rest assured that these personnel are equipped with the proper authorization and measures to safeguard your Personal Data.

In addition to the LG Group and the LGE-affiliated companies and subsidiaries, we share and disclose your Personal Data with the following types of third-party entities:

• Service providers. These are carefully selected external parties, companies or individuals that provide services to us in our operations, such as, operations and software development, IT services, security, hosting, website maintenance, data maintenance and analytics, customer care and communication, order processing and fulfilment, payment processing, fraud detection and identity verification, mailing, billing, marketing and market research, authorized service and repair centers, administrative and back-office support services, and agencies handling contest, sweepstakes, and promotional activities. Service providers, and their selected staff, are only authorized to access and use your Personal Data on our behalf to the extent this is necessary for their provision of services to us, and under their contractual obligations with LGE. As third-party service providers, they are required to keep your Personal Data confidential and secure and are not allowed to process your Personal Data purposes other than what is stated under their contract.
  • TECHSOUTHGATE SOLUTIONS INC. – LGE entrusts this third-party service provider with the collection, storage, processing, use, provision, management, and destruction of your Personal Data related to the LG DUALCOOL Partners Application system service operation, service use analysis, and user information storage.
• Business advisors. These business advisors may be composed of our lawyers, accountants, business consultants, insurers, auditors, and your Personal Data will be shared with them only to the extent it is necessary for them to provide us with their services.
• Government authorities, judicial authorities, regulators, or other third parties where it is required. We will disclose your Personal Data to government authorities, judicial authorities, regulatory bodies, or other third parties where we have a legal requirement to do so or where we believe this is necessary:
• Compliance with the law or response to compulsory legal processes such as but not limited to a search warrant, subpoena, or court order;
• Verification or enforcement of compliance with the terms and policies governing our Services and for investigation and prevention of fraud or other unlawful activity relating to the use of our Services or affecting our business, to the extent such disclosure is permitted by the DPA; and
• Protection of our rights, property, safety, and the security or safety of our business operations and those of any of our respective affiliates, staff, business partners, our customers or members of the public.

How do we keep your Personal Data safe and how long do we retain it?

We have in place organizational, physical, and technical safeguards designed to protect the privacy, integrity, and availability of the Personal Data we collect through our Services. Among the measures we implement are the following:

• Data Privacy awareness and training to employees
• End-to-end encryption for Personal Data
• Data Classification whenever suitable
• Multi-factor authentication for all privileged access or administrator accounts
• Identity and access management, and digital forensics
• Cybersecurity preventive measures, including strict access permissions, secure session handling, real-time data validation, and proper validation and restrictions for files to prevent abuse
• Cybersecurity monitoring through access controls and audit logging, along with structured internal procedures for managing any unauthorized access attempts

However, please note that although we take reasonable steps to protect your information, no website, internet transmission, computer system, or wireless connection is completely secure. The safety measures we have in place also do not apply to information you choose to share in public areas such as third-party social networks.

In accordance with the DPA, we will use and retain your Personal Data for the duration for which the information is used to provide you with our Services or when we are obliged to retain your Personal Data based on specific requirement of law, contract, statutory obligations, and for as long as it is reasonably necessary to do so to manage an actual or impending complaint, investigation or legal dispute, or when we have anonymized your Personal Data for statistical purposes, subject to appropriate safeguards.

Upon any request for account deletion within the LGE service, website, or application, we shall retain your Personal Data up to three (3) months after such request. After the three months have lapsed, we shall delete or dispose of your Personal Data, whether in physical or digital form, in a secure manner from our records or system.

What are your rights over your Personal Data?

To the extent provided by the DPA, you have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data, to whom and why your Personal Data was disclosed, the methods used in processing your Personal Data, and the date when your Personal Data was last accessed and modified.

If applicable, you may also request information on automated processes where your Personal Data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you.

You can also (1) request the deletion, erasure, blocking, portability, transfer, rectification, correction, or revision of your Personal Data; (2) limit the use and disclosure of your Personal Data; (3) revoke consent to any of our data processing activities; and (4) object to the processing of your Personal Data, including the right to file a complaint with the National Privacy Commission, claim compensation and damages, if it is proven by a competent authority that you have suffered due to the inaccurate, incomplete, outdated, false, unlawful or unauthorized use of your personal data or if your rights and freedoms as a data subject is violated.

However, these rights may be limited if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third-party (including our rights) or if you request to delete information which are required by law to be kept for a period of time, or when there is a compelling legitimate interest for storing.

These rights may be transmissible to your lawful heirs and assigns at any time after your death or when you are incapacitated or incapable of exercising your rights under the law.

To exercise and/or make inquiry on any of these rights, you or an authorized representative may contact lgeph.dpo@lge.com. All requests will be processed to the extent permitted by applicable laws.

Cross Border Transfer of Information

Your registration, access, use, or avail of the LG DUALCOOL Application system will involve the transfer, storage, and processing of your Personal Data within and outside of the Philippines, consistent with this Privacy Policy. Specifically, your Personal Data will be transferred to the Republic of Singapore.

Updates to the Privacy Notice

This Notice may at any time be updated to reflect changes in our Personal Data practices with respect to Our LGE Services, or changes in the applicable law.

How do you contact us?

For any Data Privacy-related inquiries and concerns, you may reach out to us through our Data Protection Officer via email lgeph.dpo@lge.com.