Privacy Policy - PinasMart

Effective Date: 1 October 2026

PINASMART™ ("PINASMART", "PinasMart", "we", "us", or "our") is a Philippine online business discovery and business-to-business marketplace platform available at www.pinasmart.com.

PINASMART is owned and operated by KAIROXZ INFORMATION TECHNOLOGY SOLUTIONS, with business address at 1B Aveline Building, General Tinio, Nueva Ecija, Philippines.

For purposes of Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission ("NPC"), KAIROXZ INFORMATION TECHNOLOGY SOLUTIONS acts as the Personal Information Controller for personal information processed through PINASMART, except where another party independently determines the purpose and means of processing.

This Privacy Policy explains what information we collect, how and why we process it, when information is made public or shared, how we protect it, and the rights available to data subjects.

By creating an account, registering or claiming a business, submitting a business listing, uploading verification documents, publishing products or services, sending an enquiry, purchasing a listing plan or advertising service, or otherwise using PINASMART, you acknowledge that you have read this Privacy Policy.

1. Our Privacy Principles

PINASMART processes personal information according to the principles of transparency, legitimate purpose and proportionality.

We aim to:

collect only information reasonably necessary for operating and protecting the Platform;
clearly distinguish information intended for public business listings from private account or verification information;
use information only for lawful and disclosed purposes;
take reasonable measures to keep information accurate and secure;
retain information only for as long as reasonably necessary or legally required; and
respect the rights of data subjects under Philippine law.

2. What PINASMART Does

PINASMART is designed primarily to help prospective buyers discover and connect with independent businesses, sellers, suppliers, manufacturers, distributors, contractors, professionals, service providers, equipment owners and other legitimate commercial providers.

PINASMART may provide business listings, product and service catalogues, category and location searches, enquiries, requests for quotation, messaging tools, advertisements, featured listings, subscription features and related business-discovery services.

PINASMART does not ordinarily collect the purchase price of products or services offered by listed businesses, does not charge a commission on transactions between buyers and sellers, and does not ordinarily take custody of goods or control the performance of services between users.

Payments made directly to PINASMART are for PINASMART's own services, such as listing plans, additional platform features, advertising, sponsored or featured placement and related digital marketplace services.

3. Information We Collect

3.1 Account Information

When you register or use account features, we may collect:

name;
username or display name;
email address;
mobile or telephone number;
password credentials in encrypted or hashed form;
profile photograph;
account type and role;
communication preferences; and
account verification information.

3.2 Business Listing Information

Information submitted for a public business listing may include:

business name or trade name;
company description;
business registration information;
business category and industry;
business address and geographic location;
telephone and mobile numbers;
business email address;
website and social-media links;
operating hours;
business logo;
photos and videos;
products and services;
prices or quotation information;
delivery or service areas;
professional or regulatory license information where applicable;
business representatives or contact persons where authorized; and
other information the seller chooses to publish on its business profile.

Business listing information is intended to be publicly discoverable. It may appear on PINASMART search results, category pages, location pages, business-profile pages and search engines.

3.3 Business and Identity Verification Information

To help maintain the integrity of the Platform, PINASMART may request documents or information such as:

DTI or SEC registration documents;
BIR registration documents;
Mayor's or business permits;
government-issued identification;
proof of business address;
professional licenses or registrations;
regulatory permits for regulated products or services;
proof of authority to represent a business; and
other reasonably necessary supporting documents.

These verification documents are principally used for internal verification, fraud prevention, account security, regulatory compliance and dispute investigation.

Submitting verification documents does not mean that the documents themselves will automatically be made public. PINASMART will normally publish only the business information intended for the listing or information whose publication is required or permitted by applicable law.

3.4 Seller Authorization to Publish

A seller, business owner or authorized representative who creates, claims, verifies, edits or submits a business listing expressly represents that he or she has authority to provide and publish the submitted business information.

By submitting or approving a listing, the seller authorizes PINASMART to publish, display, index and make searchable the business information designated for public display, including applicable business name, address, contact information, products, services, descriptions, images and other business-profile information.

If a seller does not want information designated as public listing information to be displayed on PINASMART, the seller should not submit or approve that information and may request modification or removal of the listing, subject to applicable law, legitimate record-retention requirements and information that PINASMART may otherwise lawfully process.

Withdrawal of permission for a public listing may result in removal, restriction or closure of that listing because publication of business information is a fundamental feature of the PINASMART service.

3.5 Buyer Enquiries and Requests for Quotation

When a prospective buyer contacts a listed business, we may process:

buyer's name;
company or organization;
email address;
telephone or mobile number;
products or services requested;
quantity, specifications or requirements;
delivery location or service area;
message or enquiry content; and
date and time of the enquiry.

Information entered into an enquiry or request-for-quotation form may be transmitted to the relevant seller so that the seller can respond.

Once a buyer voluntarily communicates directly with a seller, that seller may independently process information received in connection with the prospective transaction and may have its own privacy obligations.

3.6 Communications and Support Information

We may retain information you send through:

customer-support requests;
listing correction or removal requests;
complaints;
fraud or scam reports;
intellectual-property notices;
messages to PINASMART; and
other communications concerning the Platform.

3.7 Subscription, Advertising and Payment Information

When a user purchases a listing plan, advertisement, sponsored placement or other PINASMART service, we may process:

account and business name;
selected plan or advertising service;
amount and currency;
invoice or receipt information;
transaction or payment reference;
payment status;
subscription dates and status; and
information necessary for accounting, taxation, fraud prevention and customer support.

Where payment is handled by a third-party payment processor, PINASMART may receive confirmation and transaction-reference information rather than the user's complete payment credentials.

PINASMART does not collect payments on behalf of listed sellers merely because those sellers appear on the Platform. Payments made directly to PINASMART generally relate only to PINASMART's own listing, subscription, advertising and related digital services.

3.8 Technical, Device and Usage Information

When you access PINASMART, we may automatically collect information such as:

IP address;
browser type;
device type;
operating system;
pages visited;
search terms;
categories or listings viewed;
referring pages;
login and activity timestamps;
cookie or similar identifiers;
approximate location derived from technical information where permitted;
error logs;
security signals; and
fraud, abuse or spam-prevention information.

4. Information From Public and Other Lawful Sources

PINASMART may receive or obtain business information from business owners, authorized representatives, public business websites, official or professional registries, government sources, business social-media pages, publicly accessible directories and other lawful sources.

Where information relates to an identifiable person, PINASMART will process it only where there is an appropriate lawful basis and subject to applicable data-protection requirements.

A business owner or authorized representative who believes that public business information is inaccurate, outdated or should not appear on PINASMART may request correction, verification or appropriate removal.

5. Public Business Information

PINASMART is a business discovery platform. Information intentionally submitted or approved for a business listing is therefore intended to be publicly accessible.

Public business information may:

appear on PINASMART pages;
be found through PINASMART search tools;
be indexed by Google or other search engines;
appear in search snippets or cached pages;
be displayed in category, city, municipality, province or other directory pages;
be viewed by prospective buyers and visitors; and
be shared through links to the relevant public listing.

Removal of information from PINASMART does not necessarily result in immediate removal from search-engine caches, internet archives or copies independently retained by third parties outside PINASMART's control.

6. How We Use Information

We may process information for the following purposes:

creating and securing user accounts;
creating, publishing and managing business listings;
connecting prospective buyers with sellers;
delivering buyer enquiries and RFQs to relevant businesses;
allowing sellers to showcase products and services;
verifying businesses, representatives and professional credentials;
providing free and paid listing features;
providing advertisements, featured listings and sponsored visibility;
processing payments for PINASMART's own services;
providing customer and technical support;
responding to listing corrections and removal requests;
preventing fraud, fake listings, spam, impersonation and abuse;
investigating complaints and suspicious activity;
protecting users and Platform security;
improving search relevance and listing quality;
developing and improving Platform functionality;
performing analytics and statistical analysis;
communicating service notices and important account information;
sending marketing communications where permitted;
enforcing PINASMART's Terms and policies;
complying with lawful orders and regulatory obligations; and
establishing, exercising or defending legal claims.

7. Lawful Bases for Processing

Depending on the circumstances, PINASMART may rely upon one or more lawful bases recognized under Philippine data-protection law, including:

Consent

Where you voluntarily agree to a specific use of your information, including where consent is legally required.

Performance of a Contract

Where processing is necessary to create your account, provide a listing plan, deliver an enquiry, activate advertising or otherwise provide a service you requested.

Compliance With a Legal Obligation

Where processing is required to comply with Philippine law, government requirements, lawful subpoenas, court orders or regulatory obligations.

Legitimate Interests

Where processing is reasonably necessary for legitimate business interests such as operating a business directory, maintaining accurate listings, protecting the Platform, preventing fraud, improving services and establishing or defending legal claims, provided those interests are not overridden by the fundamental rights and freedoms of the data subject.

Other Lawful Grounds

PINASMART may process information under other grounds permitted by the Data Privacy Act and applicable Philippine law.

8. We Do Not Sell Personal Information

PINASMART does not sell personal information to data brokers, advertisers or unrelated third parties as a personal-information database.

PINASMART's business model is based primarily on listing plans, additional marketplace features, advertising, sponsored or featured visibility and related digital services.

The fact that business contact information is publicly displayed as part of an authorized business listing does not mean that PINASMART is selling the underlying personal information.

Likewise, delivering a buyer's voluntarily submitted enquiry to the seller the buyer chose to contact is part of the Platform's business-connection function and is not a sale of the buyer's personal information.

9. When We May Share Information

PINASMART may disclose information to:

9.1 The Business You Contact

If you submit an enquiry or RFQ, the information you provide may be transmitted to the relevant business so it can respond.

9.2 Service Providers

We may use service providers for hosting, cloud infrastructure, cybersecurity, email, SMS or OTP delivery, customer support, analytics, payment processing, website development, backups and other operational services.

Such providers may process information only for appropriate business purposes and subject to applicable contractual and legal safeguards.

9.3 Payment Providers

Third-party processors may process payments for PINASMART listing plans, advertisements and related services according to their own privacy policies and regulatory obligations.

9.4 Professional Advisers

We may disclose information where reasonably necessary to lawyers, accountants, auditors, insurers or other professional advisers.

9.5 Government and Law-Enforcement Authorities

Information may be disclosed where required or permitted by law, including in response to lawful subpoenas, court orders, regulatory investigations, takedown orders or other valid government requests.

9.6 Corporate or Business Reorganization

If PINASMART or its business is reorganized, transferred, merged or acquired, information may be transferred as part of that transaction subject to applicable privacy requirements.

10. Seller Verification and Good-Faith Review

PINASMART endeavors to improve trust by reviewing business registration documents, permits, identity documents, professional credentials or other supporting information submitted by sellers where appropriate.

Verification is based on the information and documents available to PINASMART at the time of review.

PINASMART may compare submitted information with public registries, government records or other reasonable verification sources where available and lawful.

Verification does not guarantee the future conduct, financial condition, product quality, competence or performance of a seller.

11. Accuracy of Seller Information

Sellers are responsible for ensuring that the information and documents they provide are truthful, current, complete and lawfully submitted.

PINASMART may request updated documentation, correct obvious errors, suspend publication, remove a verification indicator or restrict a listing if information appears inaccurate, expired, misleading or fraudulent.

12. Artificial Intelligence and Automated Tools

PINASMART may use automated systems, algorithms or artificial intelligence to assist with:

search and recommendations;
listing categorization;
duplicate detection;
spam and fraud detection;
content moderation;
business matching;
data-quality improvement;
analytics; and
other Platform functions.

Where personal information is processed using such systems, PINASMART will do so subject to applicable privacy and data-protection requirements.

13. Cookies and Similar Technologies

PINASMART may use cookies, local storage, analytics identifiers and similar technologies to:

keep users signed in;
secure accounts;
remember preferences;
measure traffic and usage;
understand how visitors use PINASMART;
improve Platform performance;
detect fraud and abuse; and
support advertising and promotional measurement where applicable.

Users may manage certain cookies through their browser or available cookie settings. Disabling essential cookies may affect Platform functionality.

14. Marketing Communications

Where legally permitted, PINASMART may communicate with users regarding new Platform features, business opportunities, listing improvements, subscription plans, advertisements, promotions or other relevant services.

Users may opt out of non-essential promotional communications through the available unsubscribe mechanism or by contacting PINASMART.

Important service, security, account, verification, billing, enquiry or legal communications may still be sent where necessary.

15. Data Retention

PINASMART retains personal information only for as long as reasonably necessary for the purpose for which it was collected, legitimate business requirements, security and fraud prevention, dispute resolution, accounting and taxation, legal compliance or the establishment, exercise or defense of legal claims.

Retention periods may vary according to the type of information.

After account or listing deletion, limited information may remain temporarily or for legally permissible periods in:

backups;
security logs;
audit records;
billing and accounting records;
complaint and fraud-prevention records;
legal records;
search-engine caches; or
third-party systems outside PINASMART's direct control.

When information is no longer required, PINASMART will take appropriate steps to delete, anonymize, securely destroy or otherwise dispose of it in accordance with applicable requirements.

16. Information Security

PINASMART uses reasonable and appropriate organizational, physical and technical measures designed to protect information against unauthorized access, accidental or unlawful loss, disclosure, alteration, destruction or misuse.

Depending on the nature of the information and system, safeguards may include:

encrypted network connections;
password protection;
role-based or limited access;
administrative access controls;
system logging;
security monitoring;
backups;
fraud and abuse prevention;
staff or contractor confidentiality requirements; and
periodic review of security practices.

No internet system, electronic transmission or storage technology can be guaranteed to be absolutely secure. Users are also responsible for protecting their passwords, devices and account credentials.

17. Data Breaches

If PINASMART becomes aware of a personal-data breach, it will assess and respond to the incident and, where notification is required by applicable Philippine law or NPC regulation, notify the appropriate authorities and affected data subjects within the legally prescribed requirements.

18. Your Rights as a Data Subject

Subject to applicable law and appropriate verification of identity, you may have the right to:

be informed about the collection and processing of your personal information;
access personal information held about you;
object to certain processing;
correct or rectify inaccurate, incomplete or outdated information;
request erasure or blocking where the legal requirements are satisfied;
request data portability where applicable;
withdraw consent where processing is based specifically on consent, without affecting prior lawful processing;
claim damages where provided by law; and
file a complaint with the National Privacy Commission.

19. Requests to Correct or Remove a Business Listing

A legitimate business owner, authorized representative or affected data subject may contact PINASMART to request correction, verification or appropriate removal of information.

PINASMART may require reasonable proof of identity, ownership, authorization or other information before acting on a request to prevent fraudulent takeover or unauthorized modification of a business listing.

20. Account Deletion

A registered user may request account closure through available account controls or by contacting PINASMART.

Account deletion does not necessarily require immediate deletion of every record where retention remains reasonably necessary or legally permitted for billing, accounting, fraud prevention, cybersecurity, complaint handling, legal compliance or legal claims.

21. Third-Party Links and Services

PINASMART may contain links to independent business websites, social-media platforms, mapping services, payment providers, messaging services or other third parties.

PINASMART does not control the independent privacy practices of those third parties. Users should review the privacy terms of the relevant third-party service before providing information directly to it.

22. Cross-Border Processing

Some hosting, cloud, analytics, communication, security or other service providers may process or store information outside the Philippines.

Where personal information is transferred internationally, PINASMART will take reasonable measures required by applicable Philippine data-protection law to ensure appropriate protection.

23. Children's Privacy

PINASMART is primarily intended for businesses and persons who have legal capacity to conduct business transactions.

We do not knowingly encourage minors to create commercial seller accounts without appropriate legal authority.

If we discover that personal information of a minor has been improperly submitted, we may restrict or remove such information and take appropriate action.

24. Changes to This Privacy Policy

PINASMART may update this Privacy Policy to reflect changes in law, regulation, technology, Platform functionality or business practices.

The current version and effective date will be published on www.pinasmart.com. Where required by law, material changes will be communicated or additional consent obtained.

25. Contact for Privacy Requests and Complaints

Questions, correction requests, removal requests, objections, complaints and other privacy matters may be sent to:

KAIROXZ INFORMATION TECHNOLOGY SOLUTIONS
Operator of PINASMART™ / www.pinasmart.com
1B Aveline Building
General Tinio, Nueva Ecija
Philippines

Email: inquiries@pinasmart.com

PINASMART may require reasonable identity or authority verification before fulfilling a request involving protected personal information or control of a business listing.

26. National Privacy Commission

Data subjects who believe that their rights under Philippine data-protection law have been violated may also seek appropriate assistance or file a complaint with the National Privacy Commission of the Philippines.

27. Governing Privacy Law

This Privacy Policy is intended to operate consistently with Republic Act No. 10173, its Implementing Rules and Regulations, applicable NPC issuances and other applicable laws of the Republic of the Philippines.

Effective from: 1 October 2026

PINASMART™
Connecting Businesses. Creating Opportunities.
Owned and operated by KAIROXZ INFORMATION TECHNOLOGY SOLUTIONS