This Privacy Policy describes how NMBLR (“NMBLR,” “we,” “us,” or “our”) collects, uses, shares, stores, and protects personal data and other information (“Personal Data”) when you visit or use our website, platforms, services, or otherwise engage with us (collectively, “Services”). We are committed to protecting your privacy and complying with applicable data-protection laws, including the Data Privacy Act of 2012 (RA 10173) and its implementing rules and regulations.
By using our website or Services, or by otherwise providing personal data to us, you acknowledge and agree to this Policy.
1. Information We Collect
Depending on how you interact with us or our Services, we may collect:
- Contact & Identity details: name, email address, phone number, company name, role/position, mailing address, other business contact information.
- Website usage and analytics data: IP address, browser type, device type, operating system, pages visited, time and date of visit, referrer URL, geolocation (approximate), search terms, and other browsing or usage logs (e.g. via third-party analytics tools or cookies).
- Communications and correspondence: any messages, inquiries, forms, or other content you submit to us (e.g. contact forms, registration, requests).
- Service-specific data: if you use particular NMBLR services (e.g. enterprise AI solutions, property marketplace, incubator applications, etc.), we may collect additional data necessary to provide those services — for example corporate information, project or property details, transaction details, funding or investment information, or other relevant business or operational data.
- Any other data you voluntarily provide: other information you choose to share with us in connection with our Services.
2. How We Use Your Information
We use the collected information for the following legitimate business purposes:
- To provide and operate our Services — including onboarding, communication, support, managing user/client relationships, project or transaction management, funding, venture/incubator operations, and other business activities.
- To respond to your inquiries, requests, or communications, and to provide updates, information, or support.
- For internal record-keeping, administrative purposes, and business operations.
- For analytics and improvement of our website and Services — to understand how users interact with us, monitor performance, optimize user experience, and improve our offerings.
- For compliance with legal, regulatory, or contractual obligations.
- For purposes related to business development, marketing, or partnership communications if you have consented or opted in (e.g. newsletter, updates about our services or ventures).
3. Data Sharing and Disclosure
We do not sell your personal data. We may share or disclose your data in the following circumstances:
- With our affiliates, subsidiaries, or other related entities within the NMBLR group, for purposes consistent with this Policy (e.g. to deliver services or manage ventures/projects).
- With third-party service providers, contractors, or partners to the extent needed to support the services we provide (e.g. cloud hosting providers, analytics services, payment processors, professional advisors), provided that such parties are bound by confidentiality and data-protection obligations.
- When required by law, regulation, or legal process (e.g. responding to a valid subpoena, court order, or request from a government authority).
- To protect and defend our rights, property, or safety, and/or the rights, property or safety of our clients, users, or the public — including preventing fraud or abuse.
4. Data Retention and Anonymization
Personal Data will be retained only for as long as necessary to fulfill the purposes for which it was collected (including compliance, contractual, legal, or business obligations). After that, we will delete, destroy, or anonymize the data, unless there is a legal or regulatory requirement to retain it.
5. Data Security
We implement reasonable and appropriate technical, organizational, and physical security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. This includes safeguards in accordance with guidelines issued by the National Privacy Commission (NPC) and applicable data-protection regulations in the Philippines. ([InsightPlus][2])
6. Your Rights
Under the Data Privacy Act and relevant regulations, you have the right to:
- Be informed about whether we process your personal data, and what personal data we hold about you.
- Request access to your personal data that we hold.
- Request correction or updating of inaccurate or outdated personal data.
- Request blocking, erasure or destruction of your personal data (subject to any ongoing legal or business obligation)
- Withdraw consent (where data processing is based on your consent), subject to applicable law or contractual requirement.
7. Cookies and Tracking Technologies
When you visit our website, we may use cookies or similar technologies (e.g. analytics tools) to collect information about your browsing behavior. Cookies help us to understand how you use our site, improve functionality, and tailor user experience.
You may adjust your browser settings to refuse cookies; however, doing so may affect your ability to use certain features of the website.
8. Cross-Border Data Transfer
If we transfer your data to third parties or service providers located outside the Philippines (e.g. cloud service providers, analytics vendors), we will ensure that such transfers are done in compliance with applicable laws and with appropriate safeguards in place.
9. Consent
By using our website or Services, or by otherwise providing personal data to us, you give your informed consent for the collection, processing, storage, and sharing of data as described in this Policy.
10. Amendments to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, business operations, regulatory requirements, or applicable law. We will post any changes on our website. The revised version will be effective once published.
