This Privacy Policy explains how FreshNode Digital ("we", "us", "our") collects, uses, stores, and protects personal information provided by visitors to freshnode.digital and participants in our workshop programs. We are committed to complying with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.
1. Who is the Personal Information Controller?
FreshNode Digital is the personal information controller for all data collected through this website and through workshop registration and attendance. Our contact details are as follows:
Address: 6780 Ayala Ave, Legazpi Village, Makati City, 1229 Metro Manila, Philippines
Phone: +63 2 8540 0032
Email: info@freshnode.digital
2. What personal information do we collect?
We collect personal information in the following situations:
When you use the contact form: We collect your email address, any name you choose to provide (optional), and the content of your message.
When you register for a workshop: We collect your full name, email address, phone number (if provided), and payment-related information necessary to process your registration.
When you browse the website: We may collect technical information through cookies and similar technologies, including your IP address, browser type, pages visited, and time spent on the site. This is described in more detail in our Cookie Policy.
We do not collect sensitive personal information as defined under the Data Privacy Act unless you voluntarily provide it.
3. Why do we collect and use your personal information?
We collect personal information for the following purposes:
To respond to inquiries: When you submit the contact form, we use your email address and message content to respond to your question or request.
To process workshop registrations: We use your name, contact details, and payment information to confirm your registration, send venue and preparation information, and manage attendance.
To improve our website: We use aggregated, anonymised browsing data to understand how visitors use the site and to identify areas for improvement.
To comply with legal obligations: We may retain certain records as required by Philippine law, including tax and financial records related to workshop fees.
We process personal information only to the extent necessary for these purposes. We do not use personal information for automated decision-making or profiling.
4. What is the legal basis for processing?
Under the Data Privacy Act of 2012, we process personal information on the following bases:
Consent: When you submit the contact form or register for a workshop, you provide consent by ticking the privacy checkbox and proceeding with your submission.
Performance of a contract: Processing necessary to fulfil your workshop registration constitutes processing for the performance of a contract to which you are a party.
Compliance with a legal obligation: We retain certain records to meet our obligations under Philippine law, including the National Internal Revenue Code and applicable consumer protection regulations.
Legitimate interests: We use anonymised analytics data under our legitimate interest in understanding website usage, provided this does not override your rights and freedoms.
5. Do we share your personal information with third parties?
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
We may share your information with the following categories of third parties where necessary:
Service providers: We may use third-party services for website hosting, email delivery, and payment processing. These providers act as personal information processors under our instruction and are required to handle data in accordance with the Data Privacy Act.
Analytics providers: We may use anonymised analytics tools. Personal data shared with analytics providers is limited to technical identifiers and is subject to those providers' own privacy policies.
Legal and regulatory authorities: We may disclose personal information to government agencies, courts, or law enforcement bodies when required to do so by Philippine law or by a valid legal process.
6. How long do we keep your personal information?
We retain personal information only for as long as necessary to fulfil the purposes described in this policy, or as required by law.
Contact form submissions are retained for a period of up to 12 months from the date of submission, after which they are deleted unless an ongoing correspondence or registration relationship exists.
Workshop registration records are retained for a minimum of five years to comply with applicable Philippine tax and accounting requirements under the National Internal Revenue Code.
Website analytics data is retained in anonymised or aggregated form and is not subject to a fixed retention period.
7. What are your rights under the Data Privacy Act?
Under Republic Act No. 10173, you have the following rights with respect to your personal information:
Right to be informed: You have the right to know what personal information we hold about you and how it is being used.
Right to access: You may request a copy of your personal information held by us.
Right to correction: You may request that inaccurate or incomplete personal information be corrected.
Right to erasure or blocking: You may request the deletion or suspension of processing of your personal information where the data is no longer necessary for the purpose for which it was collected, or where consent has been withdrawn.
Right to data portability: You may request a copy of your personal information in a structured, commonly used format.
Right to object: You may object to the processing of your personal information, including processing for direct marketing purposes.
Right to damages: You have the right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.
To exercise any of these rights, please contact us at info@freshnode.digital. We will respond to your request within a reasonable time and in accordance with the requirements of the Data Privacy Act.
8. How do we protect your personal information?
We implement appropriate technical and organisational measures to protect personal information against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include the use of HTTPS encryption for data transmitted through the website, access controls limiting who within our organisation can access personal information, and regular review of our data handling practices.
No method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security.
9. Are there transfers of data outside the Philippines?
Some of our third-party service providers, including hosting and analytics providers, may process data outside the Philippines. Where this occurs, we take steps to ensure that appropriate safeguards are in place, consistent with the requirements of the Data Privacy Act and the National Privacy Commission's guidelines on cross-border data transfers.
10. How can you contact us or the National Privacy Commission?
For questions, concerns, or requests relating to this Privacy Policy or your personal information, contact us at:
Email: info@freshnode.digital
Phone: +63 2 8540 0032
Address: 6780 Ayala Ave, Legazpi Village, Makati City, 1229 Metro Manila
If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint is available at the NPC website at privacy.gov.ph.
11. Can this policy change?
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the nature of our services. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically. Continued use of the website after any update constitutes acceptance of the revised policy.