Privacy Statement

SMC Stock Transfer Service Corporation ("SMC STSC," "We," “usorour”) respect your privacy and will keep secure and confidential all personal and sensitive information that you may provide to SMC STSC, and/or those that SMC STSC may collect from you (“Personal Data”).

This privacy statement (“Statement”) provides for the Personal Data we obtain, or which you may provide through this website, www.smcstocktransfer.com.ph ("Website"), or through our email address smc_stsc@sanmiguel.com.ph (“Email”), and the standards we observe in using, processing, keeping, securing, and disclosing said Personal Data.

Please read this Statement carefully to understand how We treat Personal Data. We may update this Statement from time to time to reflect change(s) in the law and/or our internal standards. When We do so, We will notify you by posting the updated Statement in this Website for your information and reference. By accessing the Website and submitting your Concerns (defined below), or Personal Data through it, you expressly acknowledge that you have read, understood and hereby agree to all of the terms of this Statement and that you provide consent for us to:

Personal Data We Collect and Process

Our Website allows you to directly reach us and submit inquiries, comments, suggestions and complaints (collectively, “Concerns”) on our services and on information on the shares issued by companies for which we act as stock and transfer agent (the “Issuer”) . When you access our Website and submit your Concerns, We ask you to provide the following Personal Data to identify you, and enable SMC STSC to act on your Concerns:

If you do not provide any or all of the foregoing Personal Data accurately, We may not be in the position to effectively address your Concerns.

Any additional Personal Data that you may provide through your correspondence(s) with SMC STSC in connection with your Concerns shall also be considered and treated as Personal Data.

When you navigate through and interact with the Website, depending on your settings, We may use automatic data collection technologies (e.g., cookies, web beacons, small data text files or similar technologies) to obtain certain information about your equipment, browsing actions, and patterns, such as:

The Collected Data are mostly statistical data but may include other Personal Data, and We may maintain or associate them with the Personal Data that We ask you to provide to SMC STSC in connection with your Concerns.

What We Do with Personal Data and Collected Data

Upon receiving your Concerns and the accompanying Personal Data identifying you, SMC STSC forwards the same to the concerned SMC STSC group. SMC STSC may use your Personal Data to get in touch with you, in order to attend to, further inquire about, and address your Concerns. SMC STSC may also request for additional Personal Data to validate your shareholdings and identity as the shareholder of the Issuer concerned. SMC STSC may separately contact you to confirm that the concerned SMC STSC department has acted on your Concerns, ask you for further feedback, request your participation in surveys and/or provide information on its products and services.

For the Collected Data, We use them to help us improve our Website and to deliver a better and more personalized service by enabling us to:

Retention of Personal Data and Collected Data

SMC STSC and/or its duly authorized third party shall retain the Personal Data and Collected Data for a maximum period of five (5) years counted from the date you provide it to SMC STSC, or when they were collected, respectively.

If you are the shareholder of the Issuers handled by SMC STSC, We shall retain the Personal Data indefinitely while you own shares with the Issuer, and shall retain the Personal Data for a maximum period of ten (10) years counted from the date when you no longer have shares registered in your name in the records of the Issuer.

Disclosure and Sharing of Personal Data and Collected Data

We may disclose aggregated information about our users, and information that does not identify, or when combined with other information, does not directly and certainly identify any individual, without restriction.

We may disclose and share the Personal Data and Collected Data, subject to compliance with applicable laws and regulations, on a need to know basis, and in all cases only for legitimate business purposes, as follows:

Website Visitor Under the Age of 18

No one under age eighteen (18) (“Minors”) may provide any Personal Data on the Website. SMC STSC does not knowingly collect Personal Data from Minors. If you are a Minor, please do not use or provide any information on this Website about yourself.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Accessing and Correcting Your Personal Data

You are entitled to certain rights in relation to the Personal Data collected from you, including the right to access and correct your Personal Data being processed, object to the processing, and to lodge a complaint before the National Privacy Commission in case of violation of your rights as data subject.

You may send us an e-mail at smc_stsc@sanmiguel.com.ph to request access to, correct and/or delete any Personal Data that you have provided to us. Please be advised, however, that We cannot delete your Personal Data without restricting or removing our ability to effectively address your Concerns. We may not accommodate a request to correct and/or delete Personal Data if We believe the same would violate any law or legal requirement or cause the Personal Data to be incorrect.

Security of your Personal Data and the Collected Data

We have implemented technical, organizational, and physical measures designed to protect the confidentiality, integrity, and availability of your Personal Data and Collected Data and secure such Data from destruction, unauthorized access, alteration, disclosure, fraudulent misuse and/or any other unlawful processing, as well as other natural and human dangers.

Contact Information

Should you have any questions and/or concerns regarding this Statement, SMC STSC’s use of your Personal Data and the Collected Data, or your rights in relation thereto under the Data Privacy Act of 2012, please do not hesitate to contact the SMC STSC Data Protection Officer at the following: smc_stsc_dpo@sanmiguel.com.ph and (+632) 632-3449.

I have read, understood and agree to all the terms as set forth in this SMC Stock Transfer Service Corporation PRIVACY STATEMENT.