Privacy Policy

1. Introduction

Infrastratus IT Services ("we," "our," or "us") is committed to protecting your privacy and ensuring compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines. This privacy policy explains how we collect, use, process, and protect your personal information when you interact with our services and website.

2. Legal Basis and Compliance

Our data processing activities are conducted in compliance with:

• Republic Act No. 10173 - Data Privacy Act of 2012
• National Privacy Commission (NPC) Implementing Rules and Regulations
• NPC Circulars and Issuances on data protection
• Industry-specific regulations applicable to IT services in the Philippines

3. Personal Information We Collect

In accordance with the DPA, we collect the following categories of personal information:

• Personal identification information: First name, last name
• Contact information: Email address, phone number
• Professional information: Company name, job title/role
• Business inquiries: Service interests, project requirements, messages
• Technical data: IP address, browser information, timestamp (for security purposes)
• Communication records: Email correspondence, consultation notes
• Demo platform access: When you access the live RAG demo at infrastratus.com/demo, we collect your email address as part of the one-time password (OTP) sign-in process. This email is retained after your session ends to help us identify and follow up with potential clients.

4. Purpose and Lawful Basis for Processing

We process your personal information for the following legitimate purposes under the DPA:

• Contract performance: To provide IT services and fulfill contractual obligations
• Legitimate business interest: To respond to inquiries and conduct business operations
• Demo lead generation: Email addresses collected during demo sign-in are retained to follow up with businesses who have expressed interest in our AI and RAG integration services. You consent to this when you accept the terms at sign-in, and you may request deletion at any time.
• Consent: For marketing communications (only with your explicit consent)
• Legal compliance: To comply with Philippine laws and regulations
• Vital interests: To protect our systems and prevent fraud or security breaches

5. Data Security and Protection Measures

In compliance with the DPA's security requirements, we implement:

• Technical safeguards: HTTPS encryption, secure data transmission protocols
• Administrative safeguards: Access controls, employee training on data privacy
• Physical safeguards: Secure facilities and controlled access to systems
• Regular security assessments: Periodic review and updates of security measures
• Incident response procedures: Protocols for data breach notification and response

6. Data Sharing and Disclosure

We may share your personal information only in the following circumstances, as permitted by the DPA:

• With your explicit written consent
• To authorized service providers bound by data processing agreements
• When required by Philippine law or court orders
• To government agencies for regulatory compliance
• In connection with business transfers (with prior notice to data subjects)

7. Data Retention Policy

We retain personal information in accordance with Philippine legal requirements:

• Contact form submissions: 3 years from last communication
• Demo platform leads: Email addresses collected at demo sign-in are retained for 2 years from your last session, or until you request deletion by emailing privacy@infrastratus.com
• Business contracts and records: 10 years as required by Philippine business laws
• Financial records: 10 years in compliance with Bureau of Internal Revenue regulations
• Marketing consent records: Until consent is withdrawn plus 1 year for compliance verification

8. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights:

• Right to be informed: About the collection and processing of your personal information
• Right to access: To obtain confirmation and details about your personal information
• Right to object: To the processing of your personal information
• Right to erasure or blocking: To have your personal information deleted or blocked
• Right to rectification: To correct inaccurate or incomplete personal information
• Right to file a complaint: To lodge a complaint with the National Privacy Commission
• Right to damages: To seek compensation for damages due to inaccurate, incomplete, or unlawful processing

9. Cookies and Digital Tracking

Our website uses cookies and similar technologies in compliance with NPC guidelines:

• Essential cookies: Required for website functionality
• Performance cookies: To analyze website usage and improve services
• Functional cookies: To remember your preferences and settings

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

10. Cross-Border Data Transfers

When transferring personal information outside the Philippines, we ensure compliance with DPA requirements by:

• Implementing adequate safeguards as required by the NPC
• Ensuring recipient countries have adequate data protection laws
• Obtaining your consent for transfers to countries without adequate protection
• Using approved standard contractual clauses for international transfers

11. Data Breach Notification

In the event of a personal data breach, we will:

• Notify the National Privacy Commission within 72 hours of becoming aware of the breach
• Inform affected data subjects when the breach poses a high risk to their rights and freedoms
• Provide details about the nature of the breach and measures taken to address it
• Implement corrective actions to prevent similar incidents

12. Children's Privacy

Our services are directed to businesses and professionals. We do not knowingly collect personal information from children under 18 years of age. If we become aware that we have collected such information, we will take steps to delete it in accordance with the DPA's special protection for children's data.

13. Updates to This Privacy Policy

We may update this privacy policy to reflect changes in our practices or applicable laws. Material changes will be communicated through:

• Email notification to registered users
• Prominent notice on our website
• Updated "Last updated" date at the top of this policy

14. Contact Information

For questions about this privacy policy or to exercise your data subject rights:

15. Regulatory Authority

If you believe your data protection rights have been violated, you may file a complaint with: