Privacy Policy

1. Personal Data We Collect

Splace Operations Philippines (“Splace,” “we”) is the Personal Information Controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, “DPA”). We collect two categories of personal information through the Splace website and services:

A. Information You Provide Directly

• Contact & inquiry forms — name, business email, phone, company name, message content;
• Sourcing Cost & ROI Calculator — headcount, current onshore wage, service tier of interest, region, and the calculated arbitrage figures together with your business email;
• Applicant intake form — name, email, phone, position of interest, brief introduction, and any attached CV/résumé (PDF, DOC, or DOCX);
• Correspondence — content of email, chat, or other communications you send to us.

B. Information Collected Automatically

• Device / browser data — IP address, user agent, operating system, screen dimensions, timezone;
• Usage data — pages viewed, referring URLs, time on page, click patterns;
• Cookies — see Section 7 for the full breakdown by category.

We do not intentionally collect “sensitive personal information” (as defined by the DPA) through the site. Where such information is submitted within a free-text field (e.g., a CV), we handle it in accordance with the DPA and delete or redact it when it is no longer needed for the original purpose.

2. How We Use Your Data

We use personal information to:

• Respond to your inquiries, generate proposals, and provide requested information;
• Evaluate applications from prospective employees and communicate with applicants throughout the recruiting cycle;
• Operate, maintain, and improve the Splace website and platform;
• Send transactional communications relating to active engagements;
• Send marketing communications only with your opt-in consent, always with a one-click unsubscribe;
• Analyse usage patterns to improve site performance and editorial content;
• Detect, prevent, and address technical issues, fraud, or abuse;
• Comply with legal and regulatory obligations under Philippine and applicable foreign law.

3. Legal Bases for Processing

Our processing is grounded in one or more of:

• Consent — where you have given specific, informed consent (e.g. ticking a checkbox, accepting cookies, submitting a form);
• Contract — where processing is necessary to respond to a request that may lead to a service engagement;
• Legitimate interests — for site improvement, fraud prevention, and internal analytics, balanced against your rights;
• Legal obligation — where required by Philippine tax, labor, or corporate law, or by law in a client jurisdiction.

4. Data Sharing & Disclosure

We do not sell your personal information. We share it only in these limited circumstances:

• Vetted service providers — email delivery, CRM (GoHighLevel), hosting, analytics — all under written agreements requiring them to protect your information and use it only for the specific service they provide us;
• CRM integration — calculator submissions and inquiry forms flow into our GoHighLevel CRM for sales follow-up and pipeline management;
• Legal requirements — where required by law, court order, or governmental request, or to protect the rights, property, or safety of Splace, our clients, or others;
• Business transfers — in the event of a merger, acquisition, or asset sale, in which case we will provide notice before your information becomes subject to a different privacy policy.

5. International Data Transfers

Splace is headquartered in Davao City, Philippines and provides services to clients in the United States, United Kingdom, Australia, Canada, the Netherlands, and New Zealand. Personal information collected through the site may be processed in — or transferred to — jurisdictions outside your country of residence, including the Philippines.

When we transfer personal information across borders, we do so in accordance with applicable transfer requirements (DPA cross-border transfer conditions and, where relevant, the requirements of the transferring jurisdiction such as the EU GDPR or UK GDPR). By using the site or submitting information to us, you consent to such transfers.

6. Data Retention

We retain personal information only as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law:

• Inquiry & calculator submissions — up to 3 years to allow follow-up and re-engagement;
• Applicant CVs & application forms — up to 2 years for future openings, then deleted unless you explicitly consent to longer retention;
• Contract-related records — engagement duration + 10 years, per statutory record-keeping requirements;
• Analytics & log data — aggregated or pseudonymised, up to 26 months.

7. Cookies & Tracking Technologies

The site uses cookies and similar technologies. When you first visit, our Cookie Consent banner lets you choose which categories to allow. Change your choice anytime by clicking “Cookie Settings” in the footer.

A. Strictly Necessary

Required for core functionality — remembering your consent choices, session security, form submissions. Cannot be disabled.

B. Analytics & Performance

Help us understand how visitors interact with the site (which pages are most read, where visitors drop off). Anonymised. Loaded only if you consent.

C. Marketing & Advertising

Used to measure the effectiveness of our campaigns and, where applicable, tailor messaging across other sites (e.g., Meta Pixel, LinkedIn Insight Tag). Loaded only if you consent.

8. Your Rights

Under the DPA and (where applicable) EU GDPR or California CCPA, you have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Delete your personal information (“right to erasure”), subject to legal retention obligations;
• Object to processing based on legitimate interests or for direct marketing;
• Restrict processing in certain circumstances;
• Data portability — receive your data in a structured, commonly used, machine-readable format;
• Withdraw consent at any time, where processing is based on consent;
• File a complaint with the Philippine National Privacy Commission (privacy.gov.ph) or your local data-protection authority.

To exercise these rights, email our Data Protection Officer at info@splacebpo.com. We respond within the timeframes required by applicable law (typically 30 days).

9. Security & Breach Notification

We implement technical and organisational security measures appropriate to the risks of the processing, including encrypted transport (HTTPS), access controls, staff training on data protection, and regular security review. Our Davao facilities meet CCAP-accredited standards; ISO 27001 certification is in progress.

No system is completely secure, however, and we cannot guarantee absolute security. In the event of a personal-data breach that is likely to result in serious harm to affected individuals, we will notify the Philippine National Privacy Commission and affected individuals within 72 hours of becoming aware of the breach, as required by the DPA.

10. Contact & Complaints

Questions, concerns, or requests regarding this Privacy Policy or your personal information should be directed to:

• Data Protection Officer — info@splacebpo.com
• Post — Splace Operations Philippines, Davao City, Philippines
• Regulator — Philippine National Privacy Commission, privacy.gov.ph

We may update this Privacy Policy from time to time. Material changes will be announced via a site banner and, for registered users, by email. Your continued use of the site after any change constitutes acceptance of the revised policy.

This Privacy Policy is a starting-point template calibrated to the Philippine Data Privacy Act and international-transfer scenarios typical for a BPO serving US / UK / AU / CA / NL / NZ clients. It is not a substitute for legal advice — have your Data Protection Officer and counsel review before publication.