
CloudCfo is fully committed to protecting the Personal Data of all website visitors who visit and use this CloudCfo Website (“Visitors”) (the “Website”). We are also committed to ensuring compliance with Republic Act No. 10173, more commonly referred to as the Data Privacy Act of 2012, its Implementing Rules and Regulations and all other relevant Issuances, Circulars, Regulations, Opinions and Advisories of the National Privacy Commission of the Philippines (the “DPA”).
The purpose of this Privacy Policy is to provide information on how and why CloudCfo collects, processes, discloses, destroys and uses Personal Data obtained from Visitors during and after their use of the Website in accordance with CloudCfo’s Data Privacy obligations and confidentiality requirements and all applicable Data Privacy laws. It also sets out the rights of Visitors in relation to our processing of their Personal Data and demonstrates our commitment to transparency and fairness, two key principles of Data Privacy law.
This Privacy Policy should be read in conjunction with the Terms of Use of this Website as both are applicable to the use of this Website by Visitors.
This Privacy Policy was updated on September 12, 2024 and is effective from that date. We encourage Visitors to read and understand this Privacy Policy prior to using the CloudCfo Website and to check this Privacy Policy on each Website visit or session for any changes and/or updates to the Privacy Policy.
This Website provides information regarding the services provided by CloudCfo Inc., a company incorporated under the laws of the Philippines with the registered business address of 2F Paragon Plaza, 162 EDSA cor. Reliance Street, Mandaluyong, Metro Manila (“CloudCfo”).
CloudCfo’s services include, namely, the provision of accounting, bookkeeping, payroll and other finance-related services to businesses in the Philippines and globally.
This Privacy Notice applies to all Visitors to this Website regardless of the duration of time spent on the Website or the type of activity that a Visitor might engage in when using the Website (e.g. Newsletter subscription, sales enquiry, job application, general browsing, etc).
This Privacy Policy applies only in relation to the Personal Data provided by a Visitor or collected by us through a Visitor’s use of this Website. It does not apply to any documents or information a Visitor might provide during any future engagement with CloudCfo – this would be covered by other Data Privacy-related agreements depending on the specific nature of any such future engagement.
The relevant Personal Information Controller in relation to use of this Website is CloudCfo Inc., having its registered office at 2F, Paragon Plaza, 162 EDSA corner Reliance Street, Mandaluyong, 1550 Metro Manila.
When a Visitor interacts with this Website, they may choose to provide certain types of information to us which would enable us to identify their identity as an individual. Such information is classified as Personal Data.
Any Personal Data collected by us will usually consist of the data that is provided voluntarily by a Visitor to us through the Website via any of our online submission forms, newsletter subscription forms or chatbot. The purpose of providing this information is generally to enable the CloudCfo Team to connect directly with the Visitor for a particular reason (e.g. sales enquiry, newsletter subscription, job application).
From time to time, this Website may automatically collect data from a Visitor which helps CloudCfo to analyze website traffic, understand Visitor behaviour and help our Team to provide a better user and website experience. For example, the use of Cookies help us to recognize different web browsers and provide us with details about when, how and why a Visitor may visit our Website and understand their conduct on the Website. Some of this information can be classified as Personal Data. For further information on Cookies and the Personal Data that is automatically collected by this Website, please reference the Section below entitled “Use of Website Cookies”.
The type or categories of Personal Data that a Visitor may provide to us may vary depending on the type of actions that they engage in during their use of the Website or reasons they have for visiting the Website. Below, we have identified many of the common categories of Personal Data that either we request or Visitors generally provide voluntarily via the Website, depending on the category of Visitor:
The lists outlined above are non-exhaustive and CloudCfo may process other types of Personal Data based on a Visitor’s use of the Website. This Privacy Notice will be updated from time to time to reflect any significant changes in the categories of Personal Data that are regularly collected or processed by CloudCfo.
Further, the above does not include information that is automatically collected by CloudCfo through the use of Cookies which would generally apply to all categories of Visitor. Further information on Cookies can be found in the Section below entitled “Use of Website Cookies”.
The legal basis for CloudCfo processing Personal Data will depend on the type of Personal Data provided (i.e. Personal Information or Sensitive Personal Information) or the activity conducted by a Visitor on the Website, but will, in general, include at least one of the following:
When relying on CloudCfo’s legitimate interests as a legal basis for processing Personal Data, we will ensure to always balance the necessity to process Personal Data against the rights that a Visitor has as a Data Subject and ensure it is appropriate and justified for CloudCfo to engage in such data processing.
When using our website, we track Visitor behaviour using Google Analytics, Google Ads, Meta (Facebook) Pixel and LinkedIn Insight Tag. These tools automatically collect data on how Visitors engage with our site, including time and duration of visit, pages visited, links clicked, the website or advertisement that referred the Visitor, device and browser type, and IP address (used to estimate general location and recognise returning Visitors). Google, Meta and LinkedIn may also use this data to measure and improve the performance of our advertising on their platforms and to show our advertisements to Visitors on those platforms. Most of these activities rely on Cookies. Further information can be found in the Section below entitled “Use of Website Cookies”.
When a Visitor submits a form on our Website, we also record how the Visitor arrived at our Website (for example, the referring website or advertising campaign) and the pages viewed, to help us understand which of our content and campaigns are useful to Visitors.
You can also visit the Google Analytics Support Page for more information about how Google Analytics collects, processes and deletes Visitor data (including Personal Data).
The Google Analytics Data Retention controls give CloudCfo the ability to set the amount of time before Visitor data stored by Google Analytics is automatically deleted from Google Analytics servers. The maximum amount of time (and the default time applied) that Google Analytics will retain such Visitor data is 26 months, regardless of settings applied by CloudCfo.
To learn more about how these providers process data, Visitors may refer to the Google Privacy Policy, Meta Privacy Policy and LinkedIn Privacy Policy.
Visitors that submit an enquiry via the Website Web Form will be automatically encoded into our cloud-based Customer Relations Management system (CRM). For our CRM, we currently use PipeDrive to manage enquiries from Visitors and potential customers and partners.
To learn more about how PipeDrive collects and processes data (including Personal Data), you may refer to the PipeDrive Privacy Center.
Visitors that submit a Job Application or CV via the Website Web Form will be reviewed by the CloudCfo Team and manually encoded into our HR Management system (HRM). For our HRM, we currently use Manatal to manage Job Applications from prospective employees.
To learn more about how Manatal collects and processes data (including Personal Data), you may refer to the Manatal Privacy Center.
Visitors who subscribe to the CloudCfo Newsletter via the Website will have their email address, topic of interest and sign-up page stored in our website platform (Webflow) and added to our Newsletter Mailing List. We currently use MailChimp to manage our Mailing List subscribers and Newsletter creation and issuing.
To learn more about how MailChimp collects and processes data (including Personal Data), you may refer to the MailChimp Privacy Center.
In every Newsletter that is issued, subscribers are provided with an opportunity to unsubscribe or withdraw their consent from the Newsletter Mailing List.
CloudCfo will ensure to process any Personal Data collected via the Website in accordance with the original purpose for which the Personal Data was collected. This will regularly depend on the reason for which a Visitor has provided Personal Data via the Website, including:
“Sensitive Personal Information” refers to Personal Data which is specifically about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations, health, education, genetic or sexual life, criminal offences (including alleged offences) and court proceedings, government agency information such as social security numbers, health records, licenses, tax returns or any information classified by an executive order or an act of Congress. Sensitive Personal Information is subject to additional safeguards and protections under Data Privacy law.
CloudCfo does not request or require Visitors (of any category) to send Sensitive Personal Information via the Website. To the extent possible, CloudCfo aims to limit the collection or processing of Sensitive Personal Information and will only ever request Sensitive Personal Information in exceptional circumstances where it is absolutely necessary for a stated purpose. However, through the individual choice of a Visitor, they may opt to provide Sensitive Personal Information to CloudCfo through the Website. It is common for Job Applicants to voluntarily provide Sensitive Personal Information to CloudCfo when submitting a Cover Letter or CV.
At all times, Sensitive Personal Information will be maintained securely and in the strictest of confidence via the organizational, physical and technical security measures that CloudCfo has developed and put in place.
CloudCfo will only retain Personal Data for as long as it is strictly necessary in order to fulfill the original purpose(s) or reason(s) for which it was collected, or, as may be required to ensure compliance with applicable laws and/or regulations.
The length of time that Personal Data may need to be retained by CloudCfo will vary depending on a) the type of Personal Data and b) the category of Data Subject or Visitor and c) the length of the relationship or engagement (if any) that arises after the Personal Data has first been provided.
It is an ongoing policy of CloudCfo to review and remove or delete any Personal Data that is no longer required by or necessary for CloudCfo to retain for any further period of time.
Under the DPA, as a Data Subject and provided that CloudCfo holds or processes their Personal Data, Visitors are entitled to a range of rights when it comes to the processing of their Personal Data, including:
Please note that some of these rights may be limited where CloudCfo has an overriding interest or legal obligation to continue to process the Personal Data or where Personal Data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
For further information on Data Subject rights, Visitors can access the NPC’s Issuance, entitled “Know Your Rights” on Data Subject Rights at https://privacy.gov.ph/data-subject-rights/.
CloudCfo operates entities in a number of different jurisdictions, including the Philippines and Singapore. Any information that CloudCfo collects from a Visitor may be transferred to and processed by any CloudCfo entity.
CloudCfo also utilizes various cloud-based systems to manage and conduct the efficient and effective operations of the business. Personal Data will be transferred to or encoded into such third party cloud-based systems for further processing. CloudCfo only works with established market standard cloud-based operating systems.
In addition to the above, CloudCfo may also have a need to share Personal Data with other third parties depending on different circumstances that may arise from time to time. This may include, but is not limited to:
Where CloudCfo has a need to disclose or transfer Personal Data outside of the company, CloudCfo will ensure that there are appropriate and adequate organizational, physical and technical security measures in place in order to safeguard and protect the Personal Data in question.
We are committed to keeping all Personal Data provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the Personal Data that we have under our control from unauthorised access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
CloudCfo has in place a range of appropriate and adequate organizational, physical and technical security safeguarding measures to ensure that all Personal Data processed within and by the company is properly protected and aligns with the principles and requirements of the DPA.
However, Visitors must be aware that use of this Website and the provision of information by a Visitor is at their own risk. Visitors must understand that there are substantial risks of communicating through email, online submission forms and the internet in general, including data corruption, viruses, malicious software, hacking, unauthorized access, compromise of confidentiality, disrupted communications, server issues and system downs. While we do take appropriate security measures to protect against unauthorized disclosures of Personal Data, we cannot guarantee that such information will never be disclosed in a way that is inconsistent with our Privacy Policy. CloudCfo does not and cannot guarantee the effectiveness of the security of using email, submissions forms and/or the internet and website and we will not be responsible or liable to you for damages or losses arising from any delay in emails, system failures, emails received from an unauthorized third party, viruses, malware, corruptions software, licence failures or information (personal or otherwise) loss through hacking.
From time to time, we may transfer Personal Data outside of the Philippines. Again, this would arise in limited circumstances and only where it is necessary in accordance with CloudCfo’s legitimate interests or if required under law.
As an example, CloudCfo manages various operations of the business via market-leading third party cloud-based platforms as well as CloudCfo’s own proprietary cloud systems. Personal Data of Visitors may be stored on and processed via these cloud systems. It is common for such cloud-based systems and networks to have their servers located outside of the Philippines in various locations across the world. These locations can also change depending on the policies and protocols of the cloud networks utilized by each system.
Another example is the possible transfer of Personal Data between various CloudCfo entities that are based in different jurisdictions.
If Personal Data is transferred outside of the Philippines, CloudCfo will put in place all appropriate organizational, physical and technical security safeguarding measures to ensure that the Personal Data is adequately protected and kept safe.
CloudCfo has appointed a Data Protection Officer to oversee compliance with this Privacy Notice and to deal with any questions or concerns that Visitors might have from time to time. For further information about the matters set out in this Privacy Notice, you may contact the CloudCfo Data Protection Officer:
By Post to:
The Data Protection Office
CloudCfo Inc.
2F, Paragon Plaza
162 EDSA cor Reliance Street
Mandaluyong
1550 Metro Manila
or
by Email:
dataprivacy@cloudcfo.ph
If you are a Data Subject and wish to exercise any of the Data Subject rights outlined in this Privacy Policy, you may use the ##INLINE0## at ##INLINE1## of this Privacy Notice to submit your query or request.
If you are not happy with the way that CloudCfo is protecting your Data Privacy rights or if you wish to resolve any issue you might have in relation to how CloudCfo is processing your Personal Data, you have a right to submit a complaint with your local Data Privacy Authority in your own jurisdiction or with the National Privacy Commission in the Philippines by downloading this NPC Complaint Form from the NPC Website, completing the form and submitting it to NPC in accordance with the guidance and steps outlined by the NPC.
To ensure that you are always aware of how we use and process the Personal Data of Visitors, we will update this Privacy Policy from time to time to reflect any changes to how we use and process Personal Data. We may also make changes as required to comply with updates in applicable law or regulatory requirements. We encourage you to review this Privacy Policy each time you visit this Website to ensure that you remain updated at all times and remain fully aware about how we use, process and protect the Personal Data of Visitors.
In certain circumstances, Data Privacy law provides individuals (“Data Subjects”) with certain rights regarding their Personal Data that has been collected and/or processed by CloudCfo.
In particular, these rights include:
If you wish to exercise any of your rights under Data Privacy law or make a Data Privacy-related enquiry, you may submit this completed Data Subject Rights and Access Request Form, together with a copy of your photo identification:
By Post to:
The Data Protection Office
CloudCfo Inc.
2F, Paragon Plaza
162 EDSA cor Reliance Street
Mandaluyong
1550 Metro Manila
or
by Email:
dataprivacy@cloudcfo.ph
Please note that, in certain circumstances, you may be asked for additional information to help us fully understand the nature and extent of your request and ensure a comprehensive response.
| Surname: | |
| Middle Name: | |
| First Name: | |
| Email Address: | |
| Home Address: | |
| Telephone Number: |
| CloudCfo Employee | |
| Former CloudCfo Employee | |
| CloudCfo Customer or Former Customer (Please Indicate) | |
| Customer Employee or Former Customer Employee (Please Indicate) | |
| Supplier/Vendor or Former Supplier/Vendor (Please Indicate) | |
| Other – Please provide specific details of your relationship with CloudCfo |
| Right To Be Informed | |
| Right To Object | |
| Right To Access | |
| Right To Rectification | |
| Right To Erasure or Blocking | |
| Right To Data Portability |
| 1. Please provide specific details of your Data Rights or Data Access Request. 2. Please be aware that the more details you provide the more efficiently and effectively we will be able to manage and respond to your request. 3. Please confirm the relevant time period or timelines involved which relate to your request. 4. CloudCfo reserves the right to request additional details and information in order to support with CloudCfo’s response to and management of your request. |
Please note that in order for CloudCfo to protect the security and integrity of any Personal Data which it holds, it is necessary for you to provide proof of your identity together with your submission of this Request Form. As such, a copy of your Photo ID (Passport, Drivers Licence, National ID, etc), in which you are fully identifiable, must accompany this Form before your request can be processed.
A scanned copy of your ID should be acceptable in the majority of cases. However, CloudCfo reserves the right, at its discretion, to request an original of the applicable identification document where it deems necessary.
The information you supply in this form will only be used for the purposes of identifying the Personal Data you are requesting and for responding to your request. You are not required to complete this form to make a request, but doing so will make it easier for us to process your request with greater efficiency and accuracy.
CloudCfo will only keep a copy of these request documents until such time as your request has been fully processed and completed and all relevant review or appeal procedure timelines have expired.
| I confirm that I am the Data Subject whose details have been provided in this Data Subject Rights and Access Request Form and I confirm that I am submitting this request in order to exercise the right(s) that I have selected above in relation to the processing of my Personal Data. I understand that the details and information that I have submitted within this Form will be used by CloudCfo to verify my identity and identify the relevant Personal Data which is the subject of my request. I consent to CloudCfo processing the Personal Data that I have provided above for the purposes of this request. |
| Signed: ____________________ Date: ____________ |
| Print Name: ____________________ Print Date: ____________ |