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Republic Act No. 10173 Compliance

Privacy Policy

Effective Date: October 15, 2026 • Republic of the Philippines

1. Statutory Compliance Framework

SGWS Educational Software Systems Inc. (“SGWS”, “Company”, “we”, “us”) is committed to protecting your privacy in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and guidelines issued by the National Privacy Commission (NPC).

2. Categories of Personal Information Collected

  • Partner Profile & Identity: Legal name, organization name, mobile phone number, email address, Philippine Province, and City/Municipality.
  • Google OAuth Data: Verified email, Google User ID, and display name provided during Google Sign-in.
  • Sales Submissions: Customer names, contact info, transaction reference IDs, and payment receipt screenshots submitted for verification.
  • Disbursement Accounts: Bank account or verified e-wallet numbers (GCash / Maya) for commission payments.
  • Security & Log Metadata: IP addresses, browser user-agent strings, and system audit log records.

3. Lawful Bases & Purposes of Processing

We process personal data strictly under lawful criteria: (a) Contractual Necessity to track your product selections, compute 2-tier commissions, and disburse payouts; (b) Fraud Prevention to audit payment receipts and prevent self-dealing; (c) Tax & Legal Compliance under Bureau of Internal Revenue (BIR) statutory regulations; and (d) Legitimate Interests to provide support via our in-app messaging workspace.

4. Zero Data Monetization & Strict Disclosure Controls

We never sell, lease, or monetize personal data to marketing third parties. Data is shared exclusively with:

  • Direct Sponsors: Who can see your partner tier and activation status.
  • Secure S3 Storage Providers: For encrypted archival of transaction receipt screenshots.
  • Philippine Domestic Banks & Payment Gateways: PESONet, InstaPay, PayMongo, GCash, and Maya to fulfill payouts.

5. Your Rights under Republic Act No. 10173

Right to be Informed
Know how and why your personal data is collected and processed.
Right to Access
Request access to your stored personal information and activity logs.
Right to Rectification
Update or correct inaccurate contact, address, or profile details.
Right to Erasure / Blocking
Request deactivation or deletion subject to statutory tax retention rules.

6. Data Protection Officer (DPO) Contact

To exercise your data privacy rights, file inquiries, or report concerns, contact our designated Data Protection Officer at:

Data Protection Officer
SGWS Educational Software Systems Inc.
National Privacy Commission: https://privacy.gov.ph
Read our full partnership terms in the Terms of Service.
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