Privacy is about more than just protecting the personal data you may share through the use of our products and services, or when using our websites. Privacy is also about our obligation to use and disclose this information only for the purposes we’ve explained to you.

At Sun Life Grepa, we have a long history of protecting your information and we are committed to your privacy. Your information allows us to provide you the best possible service and products.

Personal data refers to personal information, privileged information and sensitive personal information as defined in the implementing Rules and Regulations of the Data Privacy Act of 2012 and other applicable law and regulation.

• Personal information refers to any information, whether recorded in a material form or not, that directly ascertains the identity of an individual. This includes your address and contact information.
• Sensitive personal information includes your age, date of birth, marital status, social security and other government identification numbers, policy information, health/ medical and financial information.
• Privileged information is any and all forms of information which, under the Rules of Court and other pertinent laws, constitute privileged communication, such as, but not limited to, information which a person authorized to practice medicine, surgery or obstetrics may have acquired in attending to a patient in a professional capacity.

By providing Sun Life Grepa with personal data, you have explicitly authorized and consented to our collection, use and processing of said data for the following purposes:

1. Processing and underwriting (both medical and financial) applications for financial and insurance products and services, either through manual or automated underwriting processes;
2. Providing, administering and servicing our products and services to help you meet your needs, including for purposes of improving/ upgrading our systems and business processes or appointment of third party vendors;
3. Assessing your suitability for products and services, including conducting data analytics, market research and surveys which aim to provide you with better products and services.
4. Adjudicating claims under your insurance or investment plan with any person or organization, who has relevant information about you including institutions, investigative agencies, insurers and reinsurers;
5. Informing you of Sun Life Grepa’s products and services, including marketing or promotional information regarding financial and insurance products through phone calls, mail, email, SMS or other electronic channels;
6. Complying with applicable laws, regulations, directives, issuances by, or agreements and obligations of Sun Life Grepa to any competent authority, regulator, supervisory body, enforcement agency, exchange court, quasi-judicial body or tribunal;
7. Identifying, investigating and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to the submission of reports to the Anti-Money Laundering Commission (AMLC);
8. Enhancing risk assessment and preventing fraud, including but not limited to uploading medical information in the Medical Information Database pursuant to the Insurance Commission’s (IC) Circular Letter No. 2016-54.
9. Enforcing and/ or defending the rights of Sun Life Grepa before any agency, court, tribunal, quasi-judicial body;
10. Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service to which the data subject is a party;
11. When necessary or desirable in the context or an employer-employee relationship between Sun Life Grepa and the data subject; and
12. Enabling Sun Life Grepa to exercise governance over its businesses and ensuring that risks arising therefrom are duly identified, measured, managed and mitigated.

We may also collect personal data from other sources, including but not limited to the insured, Medical Information Database, credit bureau or aggregation agencies, your employers and your beneficiaries.

For Partnerships and Corporate entities, you represent and warrant that you have (a) advised your data subjects of the purpose/s of collecting personal data and disclosure thereof to Sun Life Grepa, their rights as data subjects and other relevant information, and (b) obtained the necessary consent and authority to disclose personal data of your directors, officers, employees, members and other representatives to Sun Life Grepa pursuant to the Data Privacy Act, its implementing Rules and Regulations and other applicable law and regulation.

For purposes of this statement, Sun Life Grepa refers to the Sun Life Grepa Financial, Inc., a joint venture between GPL Holdings, Inc. (a member of the Yuchengco Group of Companies) and Sun Life Financial Philippine Holdings Company, Inc. (a member of the Sun Life Financial Group); Grepalife Asset Management Corporation which manages and distributes the Grepalife Funds; and Great Life Financial Assurance Corporation.

Sun Life is vulnerable to being used by criminal organizations and terrorist groups to launder money and facilitate the financing of their activities. Failure to mitigate money laundering and terrorist financing risks may bring significant regulatory sanction and carry severe reputational risk. We must all actively protect Sun Life’s products and services from being used for money laundering or for financing terrorist or other criminal activity.

Detecting money laundering and terrorist financing activity requires us to properly identify and authenticate our customers. You should report any suspicious premiums, deposits, payments, surrenders or other activities to your local money laundering reporting officer. If you fail to do so Sun Life may be exposed to the risk of legal sanction, financial penalties and reputational damage. Ask your manager or refer to the Contact Lists on The Source for the name of the money laundering reporting officer in your area.

You can find more information by consulting the Anti- Money Laundering and Anti-Terrorist Financing Policy available on The Source.

The processing of your personal data exposes you to financial, legal, regulatory or reputational risks that may result from the unauthorized processing or disclosure of personal data.

Sun Life Grepa is committed to protecting the privacy of all personal data provided to us. We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use of modification. We limit to those who have a business need to know. We are responsible for all personal data in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices.

As data subjects, you have the following rights:

1. Right to be informed. You have the rights to be informed whether your personal data
2. Right to object. You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling. You may also opt NOT to receive marketing information from Sun Life Grepa.
3. Right to Access. You have the right to reasonable access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
4. Right to rectify erroneous data. You have the right to correct any error in the personal data and if warranted, request immediate rectification.
5. Right to Erase or Block. You have based on reasonable ground, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from Sun Life Grepa’s filing system without prejudice to Sun Life Grepa continuing to process personal data for commercial, operational, legal and regulatory purposes.
6. Right to secure Data Portability. Where personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain from Sun Life Grepa a copy of such data in electronic or structured format that is commonly used and allows your further use.
7. Right to be indemnified for damages. You shall be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
8. Right to File a Complaint. You may file a complaint or exercise your rights above by reaching out to us through the contact details provided below. You may also raise privacy concerns to the National Privacy Commission through their website at www.privacy.gov.ph.

Your personal data will be retained by Sun Life Grepa throughout the duration of your plan, investment or account and/ or until expiration of the retention limit set by Sun Life Grepa standards, industry standards, laws and regulations from account closure and the period set until destruction, disposal or anonymization of records, unless withdrawn in writing or withheld due to changes in the information supplied by the Company.

Sun Life Grepa recognizes and values your data privacy rights. We seek to uphold them in accordance with the law. Personal data refers to any information that identifies you as a person. As defined by the Philippine Data Privacy Act of 2012, this may be “sensitive personal information.”

Data privacy refers to the necessity to preserve and protect any personal data collected by an organization from being accessed by a third party. This Privacy Policy Statement aims to explain the following: YOUR DATA PRIVACY RIGHTS Your data privacy rights are protected by the Philippine Data Privacy Act of 2012. This law states that you have the right to:

• Be informed. You must be advised if your personal data will be or has been processed. This includes the existence of automated decision-making and profiling in select transactions.
• Access. You have the right to reasonable access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
• Rectify incorrect data. You have the right to correct any error in your personal data and, if warranted, request immediate rectification.
• Erase or block. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from Sun Life Grepa’s filing system, without prejudice to Sun Life Grepa continuing to process personal data for commercial, operational, legal and regulatory purposes.
• Secure data portability. Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of it from Sun Life Grepa for your further use.
• Be compensated for damages. You shall be compensated for any damage sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms.
• File a complaint. You may file a complaint or exercise your rights above by reaching out to our Data Protection Officer in the contact details provided below.

WHAT PERSONAL DATA WE COLLECT

At Sun Life Grepa, we ask you for your personal data when you:

• Apply for an insurance policy
• Use our websites, applications or facilities
• Pay your premiums
• File for claims
• Take part in research or surveys
• Join our events
• Become our partner, vendor, supplier, employee or contractor

The personal data we collect from you may include the following:

• Name, age, sex, civil status, date and place of birth, nationality and/or citizenship, address, and contact details
• Employment or business information, and source of funds/property, wealth, and income
• Medical information
• Financial position and objectives, income, and investible assets
• Payment card number or bank account details
• Government-issued identification numbers [e.g., Passport, Tax Identification Number (TIN), Social Security System (SSS) or Government Service Insurance System GSIS) Numbers]
• Beneficiaries’ information
• Other information that you have directly provided us

We may also ask for personal data from other sources whom you have permitted to share your information with us. These sources may include your financial advisor, other insurers, reinsurers or distribution partners, the Medical Information Database, credit bureaus or aggregation agencies, government and other regulatory bodies, and other third parties. There may be cases where third parties send us personal information even without us requesting. In such cases, we will determine if we can legally keep the information and use it for the declared purpose.

It must be noted that this Statement does not apply to third party websites which have links to our sites. The processing of your personal data in a third party site is subject to their own Data Privacy Policy. Sun Life Grepa will not be responsible for the information collected from such sources, neither will Sun Life Grepa be liable for any loss or damage caused by the use of or reliance on such third party.

WHERE WE USE YOUR PERSONAL DATA

We process your personal data based on your consent, legitimate business interest, and lawful processing. We use it only for:

• Processing and underwriting (both medical and financial) applications for financial and insurance products and services;
• Providing, administering, and servicing our products and services to help you meet your needs, including for purposes of improving/upgrading our systems and business processes or appointing third party vendors;
• Assessing your suitability for products and services, including conducting data analytics, market research, and surveys to offer you better products and services;
• Settling claims under your insurance policy with any person or organization, who has relevant information about you, which includes institutions, investigative agencies, insurers, and reinsurers;
• Complying with applicable laws, regulations, directives, issuances by, or agreements and obligations of Sun Life Grepa to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
• Identifying, investigating, and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to submitting reports to the Anti-Money Laundering Commission (AMLC) and other regulators;
• Enhancing risk assessment and preventing fraud, including but not limited to uploading medical information in the Medical Information Database, in line with the Insurance Commission’s (IC) Circular Letter No. 2016-54;
• Enforcing and/or defending the rights of Sun Life Grepa before any agency, court, tribunal, quasi-judicial body;
• Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service in which you are part of
• When necessary or desirable in the context of an employer-employee relationship; and
• Enabling Sun Life Grepa to manage its businesses and ensuring that we are able to identify, measure, manage, and mitigate any risk that may come up.

We may use your information for other purposes necessary to provide insurance and other incidental services in line with your transactions. When using your data, we may utilize manual and/or technology-enabled data processing systems to help us serve you, including underwriting, profiling, orphan policy handling, finance-related functions, letter preparation and printing, email and call validation, and other processes.

Meanwhile, partnerships and corporate entities that Sun Life Grepa works with are expected to:

• Advise concerned people of the purpose/s of collecting personal data, including other relevant information and disclosure of the said data to Sun Life Grepa
• Inform them of their data privacy rights; and
• Obtain the necessary consent and authority to disclose personal data of its directors, officers, employees, members, and other representatives to Sun Life Grepa, as mandated by the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable laws and regulations.

HOW WE PROTECT YOUR PERSONAL DATA

Sun Life Grepa keeps your personal data in paper-based files and electronic records. While the processing of your personal data exposes you to financial, legal, regulatory, or reputational risks that may result from its unauthorized processing or disclosure, Sun Life Grepa is committed to protecting your privacy by:

• Maintaining physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use, or modification
• Using a secured server behind a firewall, encryption, and other secured controls
• Limiting access on a need-to-know basis. Sun Life takes responsibility for all your personal data in our possession. This includes information transferred to third parties who perform services on our behalf, whom we require to strictly adhere to our privacy policies and practices.

PERSONAL DATA SHARING AND DISCLOSURE

We may disclose and share your personal data based on your consent, legitimate business interest, and lawful processing, to the following parties:

• Sun Life Grepa’s directors, officers, employees, duly authorized representatives, related companies, affiliates and financial advisors;
• Third party service providers and vendors including encoding, printing and courier services; credit card processors; IT software providers; hosting vendors; partner doctors, hospitals and medical facilities; and customer support providers who are obliged to keep your personal data confidential. They will have access to your personal data only as necessary to perform their requested function on your behalf, and only if their security and privacy standards are acceptable to Sun Life Grepa;
• Business partners who help us market and distribute our products and services;
• The Medical Information Database administered by the Philippine Life Insurance Association (PLIA) and accessible to life insurance companies, for purposes allowed under Insurance Commission (IC) Circular Letter No. 2016-54, loan database administered by the Credit Information Corporation and other databases administered by similar agencies;
• Any authority, regulator, supervisory, enforcement agency, exchange, court, quasijudicial body or tribunal;
• Reinsurers and professional advisers including accounting, tax, financial or legal counsel; or
• Anyone we consider necessary for purposes of providing you products and services and other lawful purposes mentioned above.

PERSONAL DATA RETENTION

Your personal data will be retained by Sun Life Grepa throughout the duration of your policy or account and/or until the expiration of the retention limit set by Sun Life Grepa standards, industry standards, laws and regulations.

This period will be counted from account closure and will be set until destruction, disposal or anonymization of records, unless withdrawn in writing or withheld due to changes in the information supplied by the Company.

PRIVACY POLICY STATEMENT TERMS

Sun Life Grepa reserves the right to update or change sections of this Privacy Policy Statement any time and without prior notice. We will exert reasonable efforts to reach out to our clients in case there are significant changes, but we highly encourage you to review this Statement every now and then.

If you have questions about this Privacy Policy Statement, our data processing activities, or transactions made via this website, you may contact Sun Life Grepa’s Data Protection Officer at (632) 849-9558 or send an email to privacyconcern@sunlifegrepa.com.

HOW TO CONTACT US

Sun Life Grepa Financial, Inc. Grepalife Building 221 Sen Gil Puyat Ave., Makati City If you have questions about this Privacy Statement, our data processing activities or your dealings with this web site, you can contact the Data Privacy Officer by telephone at (632) 8-849-9489 or send us an email at privacyconcern@sunlifegrepa.com.

Sun Life Grepa offers products and services that can satisfy your insurance and investment needs. If you wish to receive marketing or promotional information, you may email us at wecare@sunlifegrepa.com or call our Client Care Hotline at 8-849-9633.

If you are calling from the province, you may call us toll-free via PLDT line at 1-800-10-SLGREPA (1-800-10-7547372) from any PLDT line. Our business hours are from 8 AM to 7 PM, Mondays to Fridays.

Amendments Sun Life Grepa reserves the right to change (sections of) this Privacy Statement at any time and without notice. It is recommended that you review this Privacy Statement periodically for changes.

Sun Life Grepa Financial, Inc.

Grepalife Building

221 Sen. Gil Puyat Avenue, Makati City

Attention: Data Protection Officer

If you have questions about this Privacy Statement, our data processing activities or your dealings with this website, you can contact the Data Privacy Officer by telephone at (632) 849-9558 or send us an email at privacyconcern@sunlifegrepa.com. You may also email us at wecare@sunlifegrepa.com or call our Client Care at telephone no. 849-9633. If you are calling from the province, you may call us using our toll-free number at 1-800-10-SLGREPA (1-800-10-7547372) from any PLDT line. Our business hours are from 8:00 AM to 7:00 PM, Mondays to Fridays.

Sun Life Grepa reserves the right to change (sections of) this Privacy Statement at any time and without notice. It is recommended that you review this Privacy Statement for changes.

ON DATA PRIVACY AND POLICY STATEMENTS/RIGHTS AND OBLIGATIONS

Q: What is this mailer all about and what am I expected to do?

A: This mailer is being sent to you as a valued client of Sun Life Grepa. It talks about the Data Privacy Act or DPA, and how Sun Life Grepa complies with applicable regulations on the protection of personal data gathered, collected, processed and stored for the purpose of providing, servicing and administering your insurance policy, pre-need plan or investment account.

All you need to do is read through it and provide feedback, if any.

Q: What is DPA?

A: DPA stands for ‘Data Privacy Act’ which was enacted by Congress in August 2012. The DPA was designed primarily to protect personal data that you may share when availing of Sun Life’s products and services, or when using the company’s websites. Under the DPA, the processing of personal data is allowed subject to adherence to the principles of transparency, legitimate purpose and proportionality. For more information on the DPA, you may log in to this website: (new link to follow)

Q: What do you mean by ‘personal data?’

A: Personal data refers to personal information, privileged information and sensitive personal information as defined in the Implementing Rules and Regulations of the Data Privacy Act of 2012 and other applicable laws and regulations.

Q: What are examples of personal, privileged and sensitive personal information?

A: Personal Information refers to any information, whether recorded in a material form or not, that directly ascertains the identity of an individual. This includes your address and contact information.

Sensitive personal information includes your age, date of birth, marital status, social security and other government identification numbers, policy information, health/medical and financial information.

Privileged information is any and all forms of information which, under the Rules of Court and other pertinent laws, constitute privileged communication, such as, but not limited to, information which a person authorized to practice medicine, surgery or obstetrics may have acquired in attending to a patient in a professional capacity.

Q: How is my personal data stored?

A: All information collected from clients are stored in an application system for the purpose of providing and servicing financial, insurance and investment products and services. We also have offsite storage facilities for documents containing personal data of our clients located in Metro Manila. These locations may change without need of prior notice to you.

Q: How does Sun Life Grepa protect the personal data of its clients?

A: Sun Life Grepa is committed to protecting the privacy of all personal data provided to us. We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. We limit access to those who have a business need to know. We are responsible for all personal data in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices.

Q: In the event that I avail of your products and services, does that mean you now have the authority to share my personal information with others?

A: By continuing to avail of Sun Life Grepa’s products and services, you authorize Sun Life Grepa, its employees, duly authorized representatives, related companies and third party suppliers, to use, process and share personal data needed in the administration of your insurance policy, pre-need plan, and/or mutual fund investments, with any person or organization. Sun life only shares personal data on a need-to-know basis.

Sun Life Grepa is required by law to disclose certain personal data to the Medical Information Database (MID) administered by the Philippine Life Insurance Association (PLIA) and make it accessible to life insurance companies for purposes allowed under IC Circular letter No.2016-54, Loan Database administered by the Credit Information Corporation and other databases administered by similar agencies.

Q: Who are these duly authorized representatives, related companies and third party service providers?

A: Authorized representatives include Sun Life’s directors, officers, employees and duly authorized representatives like advisors or mutual fund distributors.

Related companies include Sun Life of Canada (Philippines), Inc. or SLOCPI and its subsidiaries – Sun Life Asset Management Company, Inc. or SLAMCI and Sun Life Financial Plans, Inc. or SLFPI, its parent and regional companies – Sun Life Assurance Company of Canada; Sun Life Grepa Financial, Inc., Grepalife Asset Management Corporation, GPL Holdings, Inc. (a member of the Yuchengco Group of Companies) and Great Life Financial Assurance Corporation.

Third party suppliers include service providers and vendors including credit card processors, data analytics, IT and customer support providers who are bound by an obligation of confidentiality. They will have access to your personal data only as necessary to perform their requested function on our behalf. Sun Life has established processes to ensure that these suppliers have adequate security and privacy standards acceptable to Sun Life.

Q: What is MIB? MID?

A: MIB stands for ‘Medical Information Bureau,” a non-stock, nonprofit association of health care and life insurance companies. The concept of an MIB started in the US and Canada.

In the Philippines, a Medical Information Bureau is administered by the Philippine Life Insurance Association (PLIA). Under Insurance Commission Circular Letter No. 2016-54, life insurance companies are required to submit medical information to properly assess the risks of the applicant’s or policyholder’s insurability and prevent fraud, concealment and misrepresentation. MIB’s main objective is the maintenance of accurate medical information on persons applying for insurance, which in turn, is needed for accurate insurance underwriting.

Starting July 1, 2017, the Medical Information Bureau will be called the Medical Information Database (MID).

Q: What kind of medical information do you share with the MIB/MID?

A: A typical MIB/MID report includes information about health conditions, surgeries, critical illnesses and other disabilities. Only authorized personnel under MID/MIB shall have access to the medical information stored in the database.

Q: How do I go about accessing or finding out information about me in the MIB/MID? From whom can I ask these information?

A: You may inquire about your medical information associated with your policy with the insurance company that issued such policy.

Q: What is data analytics?

A: Big data analytics is the process of examining large and varied data sets – i.e., big data – to learn about market trends, customer preferences and other useful information that can help organizations make more informed business decisions and provide products and services that best suit their customers.

Q: What do you mean by automated processing?

A: Automated processing means using computer or computer programs to extract process, and communicate information. This includes automated processing operations where the processing becomes the sole basis of making decisions that would significantly affect you as a data subject. Sun Life Grepa employs automated processing to underwrite insurance applications with simple medical conditions. This process improves efficiency and results in shorter turn-around time in underwriting applications.

Q: Can I dictate the type of information I can provide to Sun Life Grepa?

A: Yes, you can dictate the type of information you provide to Sun Life Grepa and any of its authorized representatives. However, this selective way of sharing your personal data may affect underwriting decisions relative to your application for a life insurance policy, a pre-need plan. We are required under applicable laws and regulations to know and perform due diligence on our clients by obtaining certain information and documents

Q: What if I don’t want to give my consent to DPA and MID, what will happen?

A: Processing of personal data and information-sharing with the MID does not need client’s consent because it is required by the Insurance Commission. If you do not want to give your consent to processing of personal data , you may do either of the following:

• If an application is in process, withdraw your consent. As a consequence, the processing of your application for life insurance will be terminated;
• If the insurance policy has been issued, your right to erase or block your data in MID will be exercised. As a consequence, you will have to withdraw or surrender your life insurance policy.

Q: Will I be informed if there is a breach in the handling of my personal information?

A: We would like to assure you that Sun Life Grepa is committed to always protect and conduct proper handling of personal information in accordance with our Privacy Policy and practices. Any erroneous handling will be reported immediately to concerned parties, pursuant to breach reporting requirements of the DPA.

Q: What are my rights as a Data Subject? Can you explain each?

A: As data subjects, you have the following rights:

Right to be informed. You have the right to be informed whether your personal data is being, or have been processed.

Right to object. You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling. You may also opt NOT to receive marketing information from Sun Life.

Right to access. You have the right to reasonably access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; and the date when your information was last modified, among others.

Right to rectify erroneous data. You have the right to correct any error in the personal data and if warranted, request immediate rectification.

Right to erase or block. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking or destruction of your personal data from Sun Life’s filing systems, without prejudice to Sun Life continuing to process personal data for commercial, operational, legal and regulatory purposes.

Right to secure Data Portability. Where personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain from Sun Life a copy of such data in an electronic or structured format that is commonly used and allows your further use.

Right to be indemnified for damages. You will be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.

Right to file a complaint. You may file a complaint or exercise your rights above by reaching out to us by contacting us through our email address or client hotline 8499888. You may also raise privacy concerns to the National Privacy Commission through their website at www.privacy.gov.ph.

Q: What is the retention limit provided by law on the storage of my personal information?

A: Your personal data will be retained by Sun Life Grepa throughout the duration of your plan, investment or account and/or until expiration of the retention limit not exceeding 10 years from account closure or in case of litigation, from final judgment.

ON OPTING OUT/IN OF RECEIVING DIRECT MARKETING INFO/MATERIALS?

Q: What do you mean by direct marketing information?

A: Direct marketing information/material refers to any communication of any advertising or marketing material which is directed to particular individuals by whatever means such as mail, email, SMS and social media

Q: Can I opt out/in of marketing campaign materials in the future if I change my mind?

A: We have in this mailer a section asking if you wish to opt out of receiving direct marketing campaign materials. If you wish to opt out, you may email us at wecare@sunlifegrepa.com or call our Client Care at telephone no. 849-9633. Otherwise, we will take it to mean that you wish to receive materials regarding financial products and services that may suit your needs.

Q: What If I don’t want to give my consent to receive marketing materials? Can I only give my consent to Sun Life Grepa but not to Grepalife Asset management Corporation (or vice versa)?

A: We operate as a Sun Life Grepa group of companies so we give equal importance to all the products and services offered by each of our members be it life insurance, pre-need or mutual funds. Also, we ensure that all our clients are constantly kept abreast of all new products and services of these companies.

Opting IN would mean that you wish to receive marketing campaign materials of the Sun Life Grepa group. The same holds true for Opting OUT.