AbroadWorks, Inc. (“AbroadWorks,” “Company,” “We,” “Us”) is a U.S.-based staffing and outsourcing company that facilitates the connection between businesses and highly skilled remote professionals. AbroadWorks specializes in providing top-tier talent across various industries, offering a seamless and efficient process to help businesses scale through global staffing solutions.

We believe that, and this Notice documents our policy that Personal Information must be:

i. Collected for specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after collection, and later processed in a way compatible with such declared, specified, and legitimate purposes only;

ii. Processed fairly and lawfully;

iii. Accurate, relevant and, where necessary for purposes for which the processing of personal information is to be used, kept up to date; inaccurate or incomplete data must be rectified, supplemented, destroyed or their further processing restricted;

iv. Adequate and not excessive in relation to the purposes for which they are collected and processed;

v. Retained only for as long as necessary for the fulfillment of the purposes for which the Personal Information was obtained or for the establishment, exercise, or defense of legal claims, or for legitimate business purposes, or as provided by law; and

vi. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data were collected and processed: Provided, that Personal Information collected for other purposes may lie processed for historical, statistical or scientific purposes, and in cases laid down in law may be stored for longer periods: Provided, further, that adequate safeguards are guaranteed by said laws authorizing their processing.

i. “Controller/Personal Information Controller/PIC” refers to an individual or entity who determines the Personal Information to be processed, as well as the manner of and purpose of processing. Unless specifically stated otherwise, the Controller as identified under this Notice is AbroadWorks, Inc.

ii. “Data Breach” refers to a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed. This includes both intentional and unintentional actions that compromise the confidentiality, integrity, or availability of Personal Information.

iii. “Data Subject” refers to any identified or identifiable natural person whose Personal Information is processed. A person is identifiable if they can be directly or indirectly identified by reference to an identifier such as a name, identification number, location data, or other factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

iv. “Notice” refers to this Privacy Notice.

v. “Information/Personal Information” refers to any data, whether recorded in material form or not, from which the identity of a natural person is apparent, or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify a person. This includes Sensitive Personal Information (as defined herein) and privileged information.

vi. “Processor/Processing” refers to the former as any natural or legal person, public authority, agency, or other body that processes Personal Information on behalf of the Controller, and the latter as any operation or set of operations performed on Personal Information, whether by automated means or not. This includes collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, erasure, or destruction of Personal Information.

vii. “Security Incident” refers to any event or occurrence that affects or may affect the availability, integrity, or confidentiality of Personal Information. This includes attempted or successful unauthorized access, disclosure, misuse, alteration, or destruction of Personal Information or IT systems.

viii. “Sensitive Personal Information” refers to Personal Information: (i) about a Data Subject’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (ii) about a Data Subject’s health, education, genetic or sexual life, or to any proceeding for any offense committed or alleged to have been committed by such Data Subject, the disposal of such proceedings, or the sentence of any court in such proceedings; (iii) issued by government agencies peculiar to a Data Subject which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (iv) specifically established by an executive order or an official act of government to be kept classified.

ix. “Territory” refers to the geographical area or jurisdiction within which the data protection laws and regulations apply.

x. “Automatically collected information” refers to any information automatically sent by your devices when you use the Website.

xi. “We/Us” refers to AbroadWorks, acting as a data controller, co-controller, or personal information controller, as defined in (iii) above.

xii. “Website” refers to https://www.abroadworks.com and its sub-pages.

We collect various pieces of Personal Information about you throughout your journey through the Website, depending on how you interact with the Website:

i. For Visitors: When you visit the Website, our servers may automatically log data regularly provided by your web browser. These may include the Internet Protocol Address (“IP Address”) of your device, your browser type and version, browser history, time, and date of your visit to the Website, time spent on each page, and other details your browser may disclose in accordance with your browser settings. If you encounter errors while using the Website, we may automatically collect data about the error and circumstances surrounding the occurrence depending on your browser settings. These data may include technical details about your device, the intended action when the error occurred, or other information you allow your browser to disclose. You may or may not be notified of these errors. We recommend checking the policies of your device manufacturer, software provider, or your privacy settings or preferences in your device to learn what information is made available to us.

ii. Other categories

You agree that any other information you choose to provide us directly or through third parties on your behalf and as instructed by you may be processed in accordance with applicable law and may be deleted upon request.

We will only process your Personal Information for the purposes for which we have collected information, as detailed above. We will inform you and obtain your consent before we use your Information for another purpose, unless we are authorized to process your Information based on our legitimate interests and/or compliance with law and regulations, in which case you will be notified of the same.

i. Direct interaction via the Website or our various social media accounts

ii. Your voluntary disclosure or submission of Personal Information pursuant to an inquiry, application, interview, onboarding, or other action

iii. Third-party sources, pursuant to your documented consent

iv. Publicly available sources

v. Cookies or other similar technologies

We only Process your Personal Information when at least one of the following conditions exist:

i. You have given your express consent, specific to the purpose and prior to the processing of your Personal Information which we have disclosed to you;

ii. The Processing of Information is necessary and is related to the fulfillment of our contract with you or in order to take steps at your request prior to entering into a contract;

iii. The Processing is necessary for compliance with a legal obligation to which we are subject;

iv. Processing is necessary to protect your vitally important interests, including life and health;

v. The processing is necessary for the purposes of our legitimate interests or by a third party or parties to whom the Information is disclosed.

When you provide us with Personal Information of third parties, it is your responsibility to ensure that the relevant third parties have been notified, and they have consented, to the use of their Personal Information, and that there is legal basis for you to provide us with such Information.

i. Subject to your consent, we may share your Personal Information with third parties for the following purposes:

ii. When required, and subject to applicable laws and/or our contractual arrangements with you, no consent will be obtained from you for sharing your Personal Information:

iii. We require all third parties with whom we disclose your Personal Information to respect the confidentiality of your Information in accordance with applicable laws and use them only for specified purposes in accordance with your and our instructions.

iv. We do not disclose your Personal Information for third party marketing purposes.

You may opt not to agree to our processing of your Information upon written request to info@abroadworks.com. We may retain some of your Information based on legitimate business reasons or legal requirement, when applicable.

i. Cross-border transfers. When we process your Personal Information, we may transfer your data outside of the Philippines. In doing so, we ensure that a similar degree of protection is applied to your Personal Information.

i. We will only retain and/or store your Personal Information for as long as it is necessary for us to be able to fulfill the purpose/s we collected for (for which your prior consent has been obtained), as well as complying with applicable legal and regulatory requirements.

ii. We may anonymize and store your Personal Information for journalistic, artistic, literary or research purposes, in which case we may retain, store and/or use such information indefinitely without further notice to you. Rest assured that such anonymized information will no longer be traced or associated with you.

iii. We may retain your Personal Information even after you have requested that it be deleted if retention is reasonably necessary for us to comply with our legitimate interests, legal and regulatory obligations, prevent and remediate any fraud and/or abuse, store in backup systems (for a period of time) or to enforce this Privacy Policy and/or our Website Terms of Use (www.abroadworks.com/terms). Personal Information held in backup systems is only held for the purposes of restoring systems in the event of a data loss.

i. We will implement reasonable organizational, physical and technical mechanisms to ensure security of your Personal Information against (i) any accidental or unlawful destruction, alteration and disclosure, as well as against any other unlawful processing; and (ii) natural dangers such as accidental loss or destruction, and human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination.

You shall:

i. Respect the data privacy rights of others. Before submitting Personal Information of other people to us, you are responsible to obtain the consent of such people;

ii. Report any suspected Security Incident or Data Breach to us by emailing info@abroadworks.com, cc: legal@abroadworks.com. Subject title of the email should be “Suspected Security Incident / Data Breach”

iii. Provide us with your accurate Information, and ensure the continued accuracy of said Information.

iv. Not disclose to any unauthorized party any non-public Information obtained or learned in confidence from us; and

v. Abide by the policies and guidelines of AbroadWorks, to the extent applicable.

i. Right to be Informed. You have a right to know when Information pertaining to you is being or will be processed, including the existence of automated decision-making or profiling, as follows:

1. Description of the Information to be Processed;

2. Purpose of Processing;

3. Basis of Processing, if not based on your consent;

4. Scope and method of Processing;

5. To whom your Information may be disclosed, whether internally or otherwise;

6. Methods utilized for automated access and Processing, if applicable;

7. The period for which the Information will be retained/stored; and

8. The existence of your rights as a Data Subject, including your right to file complaints with the National Privacy Commission.

We will not amend any of the above elements as previously disclosed without first notifying you, unless:

1. The Information is required to be Processed pursuant to an order of a court or government agency;

2. The Processing is necessary for the performance of or in relation to a contract to which you are a party; or

3. The Information is being Processed pursuant to a legal obligation.

ii. Right to Access. You may access, upon reasonable demand, the Information in our possession, including:

1. Information that was Processed;

2. Sources from which Information were obtained;

3. Names and addresses of recipients of the Information;

4. Manner by which such data were Processed;

5. Reason/s for the disclosure of the Information to recipients;

6. Details about automated processes where the data will, or is likely to, be made as the sole basis for any decision significantly affecting or will affect you; and

7. Date when your Information was last accessed and modified.

iii. Data Portability. You have the right to obtain from us a copy of your Information in an electronic or structured format that we commonly use, and which allows you further use of such Information under the said format.

iv. Right to Object to Processing

1. You have the right to object to the Processing of your Information, including Processing for direct marketing, automated processing, including the use of AI, or profiling.

2. When you object or withhold consent to Processing of your Information, we will no longer Process your Information, unless:

v. Right to Rectification. You may, within reason, dispute the inaccuracy or error in the Information and have us correct it accordingly. If the Information has been corrected, we will ensure the accessibility of both the new and the retracted Information and the simultaneous receipt of the new and the retracted Information to recipients, and third parties who have previously received such Information shall be informed of its inaccuracy and rectification upon your reasonable request.vi. Right to Erasure / Blocking. You may suspend / withdraw access to, or request the blocking, removal or destruction of your Information from our filing system upon discovery and substantial proof that your Information is incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or is no longer necessary for the purposes for which they were collected — in which case, we may notify third parties who have previously received such Information from us.

vii. Right to Damages. Under certain circumstances, you may be indemnified for damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your Information.

viii. Transmissibility of Rights. Your heirs and assigns may invoke any of your rights for which he or she is an heir or assignee, at any time after your death or when you are incapacitated or incapable of exercising your rights under this subsection.

ix. Limitation of Rights. The immediately preceding sections are not applicable if your Information is 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 you as a Data Subject; provided, that your Information will be held under strict confidentiality and shall be used only for the declared purpose. Likewise, the immediately preceding sections are not applicable to processing of your Information gathered for the purpose of investigations in relation to your criminal, administrative or tax liabilities, if any.

If you have any questions or concerns, or would like to make a complaint regarding our Processing of your Personal Information, please send an email to info@abroadworks.com, cc: legal@abroadworks.com, Re: Complaint on Processing of Personal Information.

We will notify you within 72 hours of discovery that your Personal Information has been compromised in case of a Security Incident and/or Data Breach. In providing such notification, we shall provide the nature of the data breach, the categories of data subjects and data records affected, and the name and details of the contact person in case you have questions or clarifications.

You are responsible for any and all use of your account and for maintaining the confidentiality of your password and other account information. By using the Website, you agree to indemnify and hold us, our officers, directors, employees, and agents harmless and free from any and all claims, damages, liabilities, costs, and expenses (including reasonable attorney’s fees) arising out of or related to your use of the Website, any breach of this Notice, or any violation of applicable laws and regulations.

If we change how we handle and process your Personal Information, we will promptly update this Notice and publish it on the Website.