Privacy Policy

1 Overview

SPHERES, Inc. ("SPHERES," "we," "us," or "our") is committed to protecting the privacy and security of the personal information you share with us. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website (spheresphinc.com), communicate with us via email, or engage us for our services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all issuances of the National Privacy Commission (NPC) of the Philippines.

2 Who We Are

SPHERES operates as a Personal Information Controller (PIC) as defined under the DPA. We determine the purposes and means by which personal data collected through this website are processed.

3 Data We Collect

We may collect the following categories of personal data:

We do not intentionally collect sensitive personal information (SPI) such as health records, government IDs, or financial account numbers through this website. If any such information is shared voluntarily, it will be handled with heightened protection and explicit consent will be obtained where required.

4 Legal Basis for Processing

Under the DPA, we process personal data on the following lawful bases:

• Consent — where you have given us clear, informed, and freely given consent (e.g., submitting the contact form).
• Contractual necessity — processing is necessary to perform or prepare a contract at your request.
• Legal obligation — compliance with applicable laws including the DPA, BIR, and SEC requirements.
• Legitimate interests — for analytics, website security, and improving our services, where such interests are not overridden by your rights.

5 How We Use Your Data

• To respond to your inquiries and service requests.
• To prepare, negotiate, and fulfill consulting contracts and technical assistance agreements.
• To send relevant service updates or announcements (only with your consent).
• To monitor and improve website performance and user experience.
• To comply with legal and regulatory obligations, including tax filings and SEC/NPC reporting.
• To protect the security and integrity of our website and systems.

We will not use your personal data for purposes incompatible with those stated above without your prior consent.

6 Data Sharing & Disclosure

We do not sell, rent, or trade your personal information. We may share your data only in the following circumstances:

• Service providers — trusted third parties assisting in operating our website or delivering services, bound by data processing agreements.
• Legal compliance — government agencies, regulatory bodies (SEC, BIR, NPC), or courts where required by law or court order.
• Business transfers — in the event of a merger, acquisition, or reorganization of SPHERES, subject to the same privacy protections.
• Your consent — for any other disclosure, we will obtain your explicit prior consent.

7 Data Retention

After the applicable retention period, personal data will be securely deleted, anonymized, or destroyed.

8 Security Measures

In compliance with NPC Circular No. 2023-06, we implement reasonable and appropriate organizational, physical, and technical measures to protect your personal data, including:

• SSL/TLS encryption for all data transmitted through this website.
• Restricted access to personal data on a need-to-know basis.
• Regular review of security practices and access controls.
• Secure storage of data with access logging.

In the event of a personal data breach that may cause harm to you, we will notify the NPC and affected individuals in accordance with NPC Circular No. 16-03 and its amendments.

9 Your Rights Under the DPA

As a data subject, you have the following rights under Republic Act No. 10173 and NPC Advisory No. 2021-01:

To exercise any of these rights, contact us at info@spheresphinc.com. You may also file a complaint directly with the National Privacy Commission at privacy.gov.ph.

10 Minors

This website is intended for professionals, government officials, and organizational representatives. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has submitted personal data, we will promptly delete such information.

11 Third-Party Links

Our website may contain links to external websites. We have no control over the privacy practices of those websites and encourage you to review their respective privacy policies. This Privacy Policy applies solely to spheresphinc.com.

12 Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of our website after such changes constitutes your acknowledgment of the updated Policy.

13 Contact Us & Data Protection Officer

SPHERES shall designate a Data Protection Officer (DPO) as required by applicable NPC regulations. The DPO's contact information will be published here and registered with the NPC when the obligation applies.