Privacy Policy

1. Introduction

LowPriceDito.com ("we", "us", or "our"), a registered trade name of Clickerwayne Holdings OPC with SEC Registration No. 2024040146156-03, operates the LowPriceDito.com website, a progressive web application (PWA) accessible via browser or installed on your device (collectively, the "Service"). We are committed to protecting your privacy and handling your personal data in compliance with:

• The Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations
• The European Union's General Data Protection Regulation (GDPR) for our international users
• Other applicable data protection laws in jurisdictions where we operate

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. By accessing or using our Service, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Data

We may collect personally identifiable information that can be used to contact or identify you ("Personal Data"), including but not limited to:

2.2 Non-Personal Data

We automatically collect certain information when you visit our Service ("Non-Personal Data"), including:

• Device Information: IP address, browser type, device type, operating system
• Usage Data: Pages visited, time spent, clickstream data
• Location Data: Approximate geographic location (city/country level)
• Cookies & Tracking: See our Cookie Policy for details

3. Legal Basis for Processing (GDPR Compliance)

For users in the European Economic Area (EEA), we process your Personal Data under the following legal bases:

4. How We Use Your Information

We use the collected data for various purposes:

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

5.1 Service Providers

We engage trusted third parties to assist in operating our Service, including:

• Payment processors (TBA)
• Shipping and logistics partners (USmile)
• Cloud hosting providers (IS, Google Cloud)
• Marketing and analytics providers (Google Analytics)

All service providers are contractually obligated to protect your data and use it only for the services they provide to us.

5.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Subpoenas, court orders, or other legal processes
• Requests from Philippine government agencies (NPC, DTI, BIR)
• Investigations of fraud or illegal activities

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction, with appropriate privacy protections.

6. International Data Transfers

As an international e-commerce platform, your data may be transferred to and processed in countries outside of your residence, including:

• Philippines (primary processing location)
• United States (for certain cloud services)
• Other jurisdictions where our service providers operate

We implement appropriate safeguards for international transfers, including:

• Standard Contractual Clauses (for EU data transfers)
• Data Processing Agreements with all international vendors
• Security measures compliant with Philippine and EU standards

7. Data Security

We implement robust security measures to protect your data:

Despite these measures, no internet transmission is 100% secure. We cannot guarantee absolute security but will promptly notify you and the National Privacy Commission (NPC) of any data breaches as required by law.

8. Data Retention

We retain your Personal Data only as long as necessary for the purposes outlined in this policy, unless a longer retention period is required by law. Our retention periods include:

• Account Data: 5 years after last activity
• Transaction Records: 10 years for tax compliance
• Marketing Data: Until consent is withdrawn
• Website Logs: 90 days for security monitoring

Upon expiration of retention periods, data is securely deleted or anonymized.

9. Your Data Rights

You have the following rights regarding your Personal Data:

To exercise these rights, please contact our Data Protection Officer at dpo@lowpricedito.com. We may require identity verification before processing requests.

10. Children's Privacy

Our Service is not directed to children under 16 (or 13 for GDPR compliance). We do not knowingly collect Personal Data from children without parental consent. If we discover we have collected such data, we will delete it immediately.

Parents or guardians who believe their child has provided us with Personal Data should contact us immediately.

11. Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

12. Changes to This Policy

We may update this Privacy Policy periodically. The "Last Updated" date at the top indicates when revisions were made. Material changes will be communicated through:

• Email notifications (for account holders)
• Website banners or pop-up notices
• Updates to our mobile applications

Your continued use of the Service after changes constitutes acceptance of the updated policy.