Privacy Policy
OUR COMMITMENT
LUNA Services & Property Management LLC (the company) is committed to providing
its employees, clients, and Data Subjects with the highest levels of professional service.
This includes protecting their privacy, as the Company understands the importance of
their Personal Data and Personal Information.
This Privacy Policy & Manual outlines how we collect, hold, use, and disclose your
personal data. By communicating with the Company’s email address, website,
interacting with any of its social media accounts, requesting its services, applying for a
job, or otherwise providing the Company with your personal data, all individuals consent
to their data being handled as outlined in this Privacy Policy & Manual.
This policy applies to all individuals (including the Company’s clients, job applicants,
and prospective employees) who provide the Company with their personal data.
PURPOSE OF THE POLICY
This Data Privacy Policy aims to raise awareness about personal data in the Company’s
daily operations and to protect the integrity and security of personal data entrusted by
its clients, employees, and business partners. It sets out the basic obligations of
Company personnel regarding personal data. All personnel must familiarize themselves
with this policy and handle all personal data accordingly.
For questions or to report any breaches of this policy, please contact the designated
legal advisors or the Company’s Data Privacy Officer as listed below.
EFFECTIVE DATE
This Data Privacy Policy takes effect from January 2025.
DEFINITIONS
This policy adopts definitions as outlined in Republic Act No. 10173 or the Data Privacy
Act of 2012, including terms such as Data, Personal Information, Sensitive Personal
Information, and Data Sharing Agreement.
DATA PROTECTION PRINCIPLES
All Company personnel must adhere to the following principles when handling Personal
Information or Sensitive Personal Information:
1. Consent
Consent must be obtained before collecting, using, or disclosing personal data.
Individuals also have the right to withdraw their consent with reasonable notice.
2. Purpose
Personal data may only be collected, used, or disclosed for legitimate purposes. Fresh
consent must be obtained if the purpose differs from the original one communicated to
the individual.
3. Notification
The Company must notify individuals of the purposes for collecting, using, or disclosing
their personal data at or before collection.
4. Access
Upon request, individuals must be provided access to their personal data within thirty
(30) days unless restricted by law.
5. Correction
Individuals may request corrections to inaccuracies in their personal data within thirty
(30) days.
6. Accuracy
Reasonable efforts must be made to ensure the accuracy and completeness of
personal data.
7. Security
Personal data must be protected by reasonable security arrangements to prevent
unauthorized access, use, or disclosure.
8. Retention
Retention of personal data must cease when it is no longer necessary for the purpose
for which it was collected, unless required by law.
PERSONAL DATA COLLECTION
LUNA Services & Property Management LLC collects personal data such as names,
addresses, and contact information, and may also collect sensitive information for
specific purposes like payroll or recruitment.
HOW IS DATA COLLECTED
Data may be collected through social media, messaging applications, face-to-face
interactions, emails, and the Company’s website. Data subjects’ consent will always be
obtained before collection and processing.
PURPOSE OF DATA USAGE
The Company collects personal data to provide services, process payroll, recruit
employees, and improve its business strategies. Personal data will only be used for
declared and legitimate purposes.
DATA BREACH PROCEDURES
In the event of a data breach, notify the Data Privacy Officer immediately. The Data
Breach Response Team will execute the Company’s Response Plan, which includes
stopping the breach, notifying authorities, and mitigating damages.
COMPLAINTS
Complaints about breaches of this policy or data privacy principles can be directed to
the Data Privacy Officer. Complaints will be investigated, and outcomes communicated
to the complainant within a reasonable timeframe.
REVISIONS
The Company reserves the right to revise this policy periodically. Any material changes
will require the consent of affected data subjects.