Privacy Policy
Effective Date: July 22, 2026 | Version: 1.1 | Philippines
PRIVACY POLICY
Personal-data handling for a multi-service marketplace and digital platform
TEMPLATE STATUS: Complete bracketed information, align this document with the actual product
design and operations, and obtain Philippine legal review before publication or use.
Included subject areas
• Customer, Provider, event, community and commerce data
• Bookings, payments, messaging, verification and location data
• Sharing, retention, security, rights and complaint process
• Philippine Data Privacy Act-focused template
Prepared for: BBBring Australasia Pty Ltd / BBBringMe Philippines | Effective Date: July 22, 2026 | Version: 1.1
1. Introduction and Scope
This Privacy Policy explains how BBBring Australasia Pty Ltd / BBBringMe Philippines (BBBRINGME, we, us or our) collects,
uses, shares, retains and protects personal data when you use our website, mobile apps,
communications, service marketplace, booking tools, community features, event features, e-
commerce functions and related services (collectively, the Platform). This Policy applies to Customers,
Providers, specialists, organisers, community members, job applicants, business contacts and visitors,
as relevant.
DATA PRIVACY COMMITMENT BBBRINGME will process personal data in accordance with
applicable data-protection law, including the Philippine Data Privacy Act of 2012 and its
implementing rules, and will apply appropriate safeguards proportionate to the data and
processing activity.
1.1 Contact details
Personal Information
Controller BBBring Australasia Pty Ltd / BBBringMe Philippines
Business Address 21F, 8 Rockwell, Hidalgo Dr., Rockwell Center, Bgy. Poblacion, Makati City, Metro Manila 1210, Philippines
Data Protection Contact /
DPO [DPO Name or Role] - [DPO Email]
General Support [Support Email / In-App Help Centre]
Effective Date July 22, 2026
2. Personal Data We May Collect
The personal data we collect depends on your account type, actions, requested Service and the
permissions you choose to grant. We collect only data reasonably necessary for the purposes
described in this Policy.
Account and identity data: name, username, email, mobile number, profile image, date of birth
where needed for eligibility, account credentials and verified identity information.
Provider and business data: business name, service categories, professional qualifications, licences,
certifications, insurance details, tax or registration information, portfolio, availability, service areas
and verification records.
Booking, transaction and payment data: service requests, quotes, Order details, invoices, payment
status, payment method token or reference, subscriptions, refunds, cancellation history, delivery
information and support records. Full card data should be handled by the applicable payment
provider, not stored by BBBRINGME unless expressly disclosed.
Location and service data: pickup, delivery, service, event or meeting location, geographic service
areas, accessibility details and location data where you permit it or the feature requires it.
Communications and content: messages, reviews, ratings, uploaded files, photos, videos, issue
reports, recordings where disclosed, and communications with support.
Device and usage data: IP address, device identifiers, browser type, app version, log data, cookies,
feature use, crash reports and approximate location derived from IP address.
Safety and compliance data: reports, complaints, verification outcomes, fraud indicators, incident
records, sanctions or restriction history, and other information reasonably necessary to protect users
and the Platform.
Face Data
This section describes how BBBringMe collects, uses, discloses, shares, retains, and deletes face data. Face data means images or videos of your face (including live selfie and liveness/verification recordings) and related signals used to confirm that a real person is present.
Collection. When you use Identity Verification or specialist onboarding features, BBBringMe may collect face data through your device camera, including: (a) a live selfie image; (b) a short live-face video in which you complete on-screen liveness actions (for example blink, smile, or turn your head); and (c) face imagery that appears during optional video consultation or live-call features while those features are in use. Face data is collected only after you choose to start the relevant feature and grant camera (and, where needed, microphone) permission. We do not use face data for advertising, marketing profiling, or selling lists of users.
Intended uses. We use face data solely to: (1) verify that you are a real person and match your identity documents where required; (2) prevent fraud, impersonation, multi-accounting, and unsafe use of the Platform; (3) complete customer or specialist verification and eligibility checks; (4) support safety, trust, and compliance reviews by authorised BBBringMe staff; and (5) enable video consultation / live communication features you choose to join. We do not use face data to create advertising lookalike audiences.
Disclosure and sharing. Face data may be accessed by authorised BBBringMe personnel for verification and safety review. Face data may also be processed by our service providers that host or transmit it on our behalf, such as secure cloud storage/hosting providers and, for live video features, our real-time communication provider (including Agora and related face-capture / face-detection components used only to operate the call). We do not sell face data. We do not share face data with third parties for their independent marketing. If face data is shared with a processor or other third party, that party is required by contract or equivalent safeguards to protect the face data with the same or equal protections described in this Privacy Policy, and to use it only for the purposes we instruct (or as required by law).
Retention. We retain face data only as long as reasonably necessary for identity verification, fraud prevention, safety, dispute resolution, and legal/compliance obligations. Typical retention is for the life of the related verification record and account relationship, and thereafter only as needed for unresolved disputes, law-enforcement requests, or statutory retention. When retention is no longer required, face data is deleted, irreversibly anonymised, or securely archived under access controls.
Consent, revocation, and deletion. By starting live-face / selfie verification (or joining a video feature that captures your face), you consent to collection and use of face data for the purposes above. You may refuse or withdraw consent by declining camera permission, cancelling the verification flow before submission, or contacting us. To delete your face data or revoke further use: (a) use in-app account deletion (Profile → Delete account), which permanently deletes your account and associated personal data including stored verification face images/videos subject to lawful retention exceptions; or (b) email privacy@bbbring.me or support@bbbring.me with the subject “Face Data Deletion Request” and enough account details for us to verify your identity. We will process verified deletion/revocation requests without undue delay, and in any event within applicable legal timelines, except where we must retain limited copies for fraud prevention, safety, accounting, or legal compliance.
Storage and security. Face data is transmitted using encrypted connections and stored on secured systems with access limited to authorised personnel and processors. No method of transmission or storage is 100% secure; please protect your device and account credentials.
3. How We Use Personal Data
• Create and administer accounts, enable log-in, verify information and maintain Platform security.
• Match Customers with Providers, display listings, administer bookings, deliver confirmations,
facilitate communications and provide customer support.
• Process payments, refunds, subscription access, fraud controls and transaction records through
BBBRINGME or authorised payment service providers.
• Support community, event, consultation, commerce and marketplace features, including attendee
lists, purchase records, delivery arrangements and relevant notifications.
• Assess eligibility, quality, safety, service performance, compliance and policy breaches.
• Improve the Platform, analyse trends, develop features, test systems and prepare aggregated or de-
identified analytics.
• Send service, administrative, safety, legal and account-related communications, and marketing
where permitted and according to your choices.
• Comply with legal obligations, respond to lawful requests, establish or defend legal claims, and
protect the rights, property, users and systems of BBBRINGME and others.
4. Lawful Criteria for Processing
Where required, BBBRINGME will rely on one or more lawful criteria for processing, including your
consent, performance of a contract or requested transaction, compliance with legal obligations,
protection of vital interests, legitimate interests that are not overridden by your rights, or another
basis permitted by applicable law. You may withdraw consent where consent is the basis for
processing, subject to any legal or contractual limits.
5. How We Share Personal Data
We may share personal data only as necessary for the purposes described in this Policy and subject to
appropriate safeguards. Recipients may include:
• Customers and Providers involved in a booking, Order, event, community or service relationship, to
the extent necessary to arrange, perform, support or resolve the relevant transaction.
• Payment processors, banks, wallet providers, identity-verification providers, cloud hosting
providers, communication providers, analytics providers, logistics providers and other service
providers acting under our instructions or their own disclosed terms.
• Business partners or category operators where you choose to engage with their services and the
sharing is necessary to fulfil the request.
• Professional advisers, insurers, auditors, regulators, law enforcement, courts and other authorities
where legally required or necessary to protect rights and safety.
• A buyer, successor or proposed transaction counterparty in connection with a merger, acquisition,
restructuring or asset sale, subject to lawful safeguards.
6. Public Profiles, Reviews and Community Features
Provider profiles, business details, ratings, reviews, listing content, public posts, event information
and community contributions may be visible to other users or the public, depending on your privacy
settings and the feature. Do not include sensitive personal information in public profiles, listings,
messages or reviews unless necessary and lawfully permitted.
7. Cookies, Analytics and Similar Technologies
We may use cookies, SDKs, pixels, local storage and similar technologies to authenticate users,
remember preferences, keep the Platform secure, measure performance, understand usage and
deliver relevant communications. Where required, we will provide consent tools or settings for non-
essential technologies. You may manage cookies through your browser or device settings, though
some features may not function properly if essential technologies are disabled.
8. Data Retention
We retain personal data for as long as reasonably necessary to provide the Platform, meet the
purposes described in this Policy, comply with legal, tax, accounting, audit, safety and dispute-
resolution requirements, and protect against fraud or misuse. Retention periods vary based on the
data type, transaction, legal obligation and whether there is an unresolved issue or claim. We will
delete, anonymise or securely archive data when retention is no longer required, subject to lawful
exceptions.
9. Security
BBBRINGME uses administrative, organisational, technical and physical safeguards designed to protect
personal data against accidental or unlawful loss, alteration, unauthorised access, disclosure or
destruction. No system is completely secure. You must use a strong password, protect your device
and verification codes, and notify us promptly of suspected unauthorised access.
10. Your Rights and Choices
Subject to applicable law and verification of your identity, you may have rights to be informed, access
your personal data, object to processing, correct inaccuracies, erase or block data in certain
circumstances, obtain data portability where applicable, withdraw consent, and seek damages where
permitted by law. To exercise a right, contact [DPO Email] with enough information for us to verify
your request. We may need to retain limited data where required by law or needed for legitimate
legal, safety, fraud-prevention or accounting purposes.
11. International Transfers
BBBRINGME or its service providers may process personal data in countries other than the Philippines.
Where cross-border processing occurs, we will take steps reasonably designed to ensure an
appropriate level of protection and compliance with applicable requirements, including contractual,
organisational or technical safeguards where appropriate.
12. Children and Sensitive Personal Information
The Platform is not intended for unsupervised use by children. Where a feature permits participation
by a minor, the parent or legal guardian must provide the required consent and supervision. We
request that users do not submit sensitive personal information unless it is strictly necessary for a
disclosed, lawful purpose and provided through an approved process.
13. Changes and Complaints
We may update this Privacy Policy to reflect changes in law, technology, product design or business
operations. The revised Policy will show a new effective date. For questions, concerns or complaints,
contact [DPO Email]. You may also have the right to lodge a complaint with the National Privacy
Commission of the Philippines, subject to applicable procedures.
Schedule A. Reference Framework and Completion Checklist
This template is written for a Philippine-focused digital platform and should be checked against the
final product, business model, payment flow, provider onboarding, customer-support process, and
applicable local requirements before publication or signing.
Official reference links for legal review
Data Privacy Act of 2012 and National Privacy Commission resources: https://privacy.gov.ph/data-
privacy-act/
Internet Transactions Act of 2023: https://ecommerce.dti.gov.ph/internet-transactions-act-of-2023/
Internet Transactions Act Implementing Rules and Regulations:
https://ecommerce.dti.gov.ph/implementing-rules-and-regulations/
DTI E-Commerce Philippine Trustmark information: https://trustmark.dti.gov.ph/
DTI e-commerce regulatory framework resources: https://ecommerce.dti.gov.ph/ecommerce-
philippines-2022/regulatory-framework/
Before finalising this document
• Replace all bracketed placeholders, including the legal entity name, registered address, support
contact, data protection contact, governing law details, fees, booking windows and refund
timelines.
• Confirm the Platform role for each product line: marketplace facilitator, direct service provider,
merchant of record, subscription provider, payment facilitator, or a combination.
• Review service-specific approvals, permits, qualifications, insurance, age restrictions and safety
procedures for automotive, moving, home, entertainment, events, coaching, professional and
community services.
• Align the terms with the app interface, checkout flow, cancellation options, privacy notices, cookies,
provider verification process and all marketing statements.
• Have Philippine counsel assess consumer-protection, labour classification, tax, payment, intellectual
property, advertising, data privacy, local permit and sector-specific obligations.