DigiPlus Interactive Corp.
Effective Date: June 2025
DigiPlus Interactive Corp., together with its subsidiaries and affiliates (collectively referred to as “DigiPlus”), convenes Annual and Special Stockholders Meetings as required under the Revised Corporation Code of the Philippines. In doing so, the company inevitably processes the personal data of individuals directly or indirectly participating in such meetings. This includes shareholders of record, proxy holders, authorized representatives, regulatory observers, advisers, and support personnel whose identities and credentials must be verified and documented to ensure compliance with corporate governance policies, security protocols, and legal requirements.
DigiPlus recognizes that while these meetings are statutory and corporate in nature, they also involve the handling of information that may directly relate to individuals and thus must be treated with due regard for privacy and data protection. The company affirms its adherence to the principles of transparency, legitimate purpose, and proportionality as set forth under Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its implementing rules and related advisories issued by the National Privacy Commission.
Processing in the Context of Corporate Governance
In line with its fiduciary obligations and in pursuit of sound governance practices, DigiPlus collects and maintains shareholder information to establish identity, ownership, eligibility to vote, and participation rights in matters requiring stockholder action. Personal data such as names, shareholdings, mailing addresses, contact details, proof of identification, and duly executed proxies or representative forms are necessary to meet quorum requirements, validate voting legitimacy, and fulfill reportorial compliance to the Securities and Exchange Commission, the Philippine Stock Exchange, and the Bureau of Internal Revenue.
This processing is not general nor commercial in nature—it is context-specific, arising solely from the individual’s relationship to DigiPlus as a shareholder or authorized participant in a regulatory proceeding. The company does not rely on consent as the primary lawful basis for these activities; rather, it invokes legal obligation, performance of a public function, or legitimate corporate interest when fulfilling its responsibilities under Philippine corporate law.
Specificity of Processing for Meeting Logistics
Participation in any stockholders’ meeting—whether in person or through digital means—requires that DigiPlus record basic and essential data points. This includes, but is not limited to, confirmation of identity, registration of attendance, access credentials to digital platforms, and where applicable, audio-visual documentation to support the integrity of the proceedings. These processes are governed by internal protocols that align with both the Revised Corporation Code and data protection requirements.
Data collected during registration or credentialing for these meetings are used solely for that defined purpose. They are not aggregated, profiled, or repurposed for marketing, customer analysis, or sales-related activities. DigiPlus has put in place clear data classification rules that separate shareholder meeting data from other data collected in the course of its commercial operations.
Use of Digital Platforms and Meeting Technologies
In cases where meetings are conducted virtually or in a hybrid environment, DigiPlus employs secure, enterprise-grade platforms that allow for encrypted communication, controlled access, and auditable interaction logs. These technologies may capture metadata such as participant IP addresses, login timestamps, device identifiers, audio/video recordings, and digital voting inputs. These are collected not for behavioral monitoring or profiling, but solely for verification, documentation, and regulatory audit trails.
DigiPlus ensures that third-party platform providers are bound by data sharing agreements and processing contracts that reflect its privacy standards. These vendors are prohibited from accessing, retaining, or using the data for any secondary purposes. Furthermore, DigiPlus does not outsource decision-making authority or legal accountability in connection with this data processing.
Restriction on Use of Information for Commercial Purposes
As a matter of policy, DigiPlus does not use any information collected through stockholders’ meetings for marketing, cross-selling, advertising, or unrelated commercial activities. The company distinguishes between its obligations as a publicly regulated entity and its role as a digital entertainment business. Information derived from corporate meetings is used strictly for governance, legal compliance, and rights administration. There is no linkage between meeting data and any customer profiling or data monetization initiatives.
Controlled Internal Access and Confidentiality
Internally, DigiPlus enforces strict access control over personal data related to stockholder meetings. Only designated departments—namely, the Office of the Corporate Secretary, the Investor Relations Unit, the Legal and Compliance Team, and the Data Protection Office—are permitted to access, process, and store such information. These departments operate under role-based access controls and are guided by a need-to-know principle. Personnel involved in such activities are bound by non-disclosure obligations and undergo regular privacy training.
No other department, including those involved in marketing, customer analytics, or business development, is permitted to use or cross-reference data obtained from shareholder meetings.
Retention and Lifecycle of Stockholder Data
DigiPlus retains data collected through stockholders’ meetings only for as long as necessary to fulfill the legal, operational, and audit-related purposes for which it was gathered. These may include periods specified under corporate retention schedules, BIR documentation requirements, or SEC compliance timelines. After the expiration of the applicable retention period, data is subject to secure destruction, anonymization, or archival procedures compliant with industry and regulatory standards.
Your Rights in Relation to Meeting Data
Individuals whose personal data are processed in connection with stockholders’ meetings have rights under the Data Privacy Act. These include the right to be informed of data processing activities, to access and correct personal records, to object or withdraw consent where applicable, to request deletion or blocking of data under specific conditions, and to lodge a complaint before the National Privacy Commission in cases of violation.
While some data processing is required by law and may not be subject to withdrawal, DigiPlus commits to evaluating every request on a case-by-case basis and ensuring that any legitimate concern regarding data use is addressed promptly and fairly.
Relationship to DigiPlus General Privacy Notice
This Privacy Notice is specific to stockholders’ meetings and is designed to supplement—but not duplicate—the general DigiPlus Privacy Notice, which governs the processing of personal data in our operational, digital, and commercial activities. Individuals who engage with DigiPlus in other capacities (e.g., players, employees, vendors, or platform users) are encouraged to refer to the broader Privacy Policy available at www.digiplus.com.ph/privacy.
How to Contact Us
For questions, clarifications, or requests relating to the processing of your data during Annual or Special Stockholders Meetings, you may contact the company’s designated Data Protection Officer:
Data Protection Officer
📧 Email: [email protected]
