I. INTRODUCTION
At Ironclad Insurance and Surety Agency, Inc., ("we", "us" or "our") we commit to the protection of data of the users ("you", "your" or "yours") obtained in the course of its business. We take the privacy of our users very seriously and urge all users to read our Privacy Policy carefully. By using our Website, using our Services or purchasing our Products, you agree and acknowledge this Privacy Policy. This also means you consent to the processing of your data or information obtained from the usage of the Website. If you do not agree to or understand this Privacy Policy, you may simply cease or refrain from using the Website.
This privacy policy (hereinafter known as "Privacy Policy") provides crucial information about:
1. The type of data or information we collect
2. The manner of collection, storage, and usage of data or information
3. The purposes for which we collect and use data
4. How we share your data or information
5. How long we retain your data or information
6. Your rights concerning your data or information
7. Management of any modifications to this Privacy Policy
8. How to contact us in case you have any suggestions, concerns, or complaints
The foregoing information will be stated by this "Privacy Policy" incorporating the minimum standards provided by Republic Act No. 10173, also known as the "Data Privacy Act of 2012" (An Act Protecting Individual Personal Information In Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission And For Other Purposes) which took effect on September 8, 2012 (the "Act").
This Privacy Policy excludes personal information about the user obtained from other sources or sources outside of the use of this Website.

​

II. EFFECTIVE DATE
This Privacy Policy comes into force and effect on 15 March 2024.

​

III. DEFINITIONS:
Website: This Privacy Policy will be applicable to www.ironcald-insurance.com, which shall hereinafter be known and referred to as "Website".
Who we are: Ironclad Insurance and Surety Agency, Inc., ("we", "us" or "our") use www.ironcald-insurance.com, and we collect, store, and use your data or information.
User: The user ("you", "your" or "yours") using this Website, which means you agree to the provisions of this Privacy Policy.
Parties: The parties to this Privacy Policy are the Personal Information Controller or "Ironclad Insurance and Surety Agency, Inc." and the user.
Personal Information Controller: Refers to Ironclad Insurance and Surety Agency, Inc. or the one who controls the processing of your data or information and has outsourced the operations of www.ironcald-insurance.com to Iris Puglia (or the Personal Information Processor).
Personal Information Processor: The operations of www.ironclad-insurance.com shall be the responsibility of Iris Puglia. This responsibility extends to the overall handling and processing of the Personal Information of the users.
Personal Information: Refers to and may be used interchangeably with your "data or information" that we obtain from your use of www.ironclad-insurance.com, which can directly or reasonably ascertain your identity.
Products: Refer to any goods or products that are offered for sale on www.ironclad-insurance.com.
Services: Refer to any services that are offered on www.ironclad-insurance.com.
 

IV. PERSONAL INFORMATION
The following are the types of personal information that will be collected from your use of the Website:
Types of personal information:
Contact Details: Name, Physical Address, Phone Number, Email address 
Personal Information: Date of Birth 
Other information required for issuance of insurance policy: valid photo ID, details of property 
Corporate Clients: Financial Information, nature of business, obligee (for surety bonds)
The following are the types of sensitive personal information or privileged information that will be collected from your use of the Website.
Types of sensitive personal information:
date of birth, specific details of properties to be insured, travel dates

​

V. LEGITIMATE PURPOSE OF PROCESSING PERSONAL INFORMATION
Your personal information will be processed pursuant to the following purposes:
To securely gather information relevant to issue a property insurance or surety bond costing proposal and to issue the corresponding policy/bond.
Your sensitive personal information will be processed pursuant to the following purposes:
- to appropriately submit quotations in accordance to the requirements of the client 
- to appropriately issue policies or bonds in accordance to the requirements of the Insurance Commission 
- to process claims against issued policies/bonds
Our main purpose for using your personal information is to improve your experience on our Website and provide you with the services and/or information you have requested. Additionally, we may use information that is not considered personal information to gain broad insights into our customer base, which may be used for market research or marketing efforts. This information might include interests based on your cookies, among other things.
Personal Information may also be processed for the following purposes:
1. Registration of your account for the use of various features of our Website
2. Communication of user account, and marketing information and if any
3. Enhancement of user experience
4. Billing or credit information or fulfilling transactions if any
5. Sharing of your data or information to affiliate companies
6. Providing customer service
7. Aggregation or combination of Data (Analytics)
8. Automated decision-making

 

VI. COLLECTION OF DATA OR INFORMATION
Depending on your usage of our Website, your personal information may be collected from you. Collection may be done in any of the following manners:
A. Registration of users: You, as a user of the Website, may register or create an account to access more features of the Website. By registering, we will collect or obtain the following personal information from you:
Personal Information: name, email address, telephone number
Personal information may be collected from you after registration in order to:
a. Allow our officers or representatives to interact with you in any manner such as by messaging or email.
b. Notify you via email or SMS about general information about your use of our Website.
c. Enable the following manner of user interaction:
- get real time quotations for personal property products 
- pay premiums for insurance policies and/or surety products 
- print-out copies of issued policies 
- submit documentary requirements for policies/bonds 
- report a claim against a policy 
- submit documents for processing of claims
The completion of your registration means you provide your consent to allow us to collect, store, use, or disclose your personal information according to the provisions of this Privacy Policy.
B. Passive usage: Data may be collected from you passively through "Cookies", even if you do not undergo the registration process. Passive data collection may include location information, IP address information, or browser data such as session information.
C. Data sharing with affiliate companies: We may share your personal information, or information that tends to show your identity with any of our affiliate companies or trusted organizations for us to provide a better user experience and offer you the best products and services suited to your needs.
This is however subject to the prior approval of such a related entity or trusted organization of our Privacy Policy, and an agreement to comply with the same standards of how we protect your data or information.
The affiliate companies or trusted organizations to which your personal information will be shared are the following:
Cocogen Insurance Co. 
Prudential Insurance Co. 
Milestone Insurance Co.  
Philippine AXA Insurance Co.
D. Billing Information: For purposes of purchasing products or services offered on our Website, we may ask you to provide certain credit information, billing address information, and additional specific information for us to be able to charge you accordingly. This information may be stored for the following period of time: 8 hours. The billing information you provide shall only be used for facilitating your transactions with us.
E. User Experience: We may ask for your suggestions on how we can improve our Website. This may be done by means of surveys, questions, or ratings asked, which may be conducted from time to time.
F. We have an automated decision-making system that may decide and take actions for you. This means that your data or information will be used to run processes for you automatically which is conducted by software programming or data management systems. Thus, this decision-making process is not done by a human.
At each instance with which you may be subjected to an automated decision-making system, we will notify you that a decision or action was made in such manner. Pursuant to your right to access, you can request for a review of such decision or action. Any automated decision-making process will take place in the following manner:
Motor Insurance: make, model and year of car will generate a corresponding quotation 
Fire Insurance: address and material used for the construction of the building will generate a corresponding quotation 
Personal Accident: name, age, occupation of client will generate a corresponding quote 
Comprehensive General Liability: type of business, area of the business establishment will generate a corresponding quote 
Additional information not mentioned above will be gathered to allow the website to issue a policy to begin coverage.
G. Combination of Data or Information: We may aggregate or combine some of your personal information in order to provide you with the best user experience and offer you the products and services that are best suited to your needs or usage patterns.This combined or aggregated information may also be shared with affiliate companies or trusted organizations in accordance with this Privacy Policy.

 

VII. PERSONAL INFORMATION WE RECEIVE AUTOMATICALLY (COOKIES)
We may gather or collect information from you using automated technology that captures data about your browsing behavior and history, and the data or information that you willingly provide to us, such as details shared during the registration process or at other points when using the Website. For instance, we may use cookies to improve or enhance your browsing experience by storing information that may pertain to your preferences, the device type you used, or previous choices you made on the site. Cookies, which are small text files, allow us to modify the Website according to your expectations and provide a more customized browsing experience. The information in a cookie is limited and can only be read by the web server that issued it. It is not an executable code and is virus-free. Cookies do not save or transmit any personal information. If cookies are disabled, the functions of our Website may be limited. To proceed without changing your cookie settings, simply continue to use our Website. The following are the type of cookies that we may receive from you:
A. HTML cookies or technical cookies are utilized to allow you to access or go through different pages of the Website. They are needed to transmit communications using the network and provide the services you request. The utilization of these cookies also allows for the safe and efficient use of our Website.
B. Cookies may also be utilized for purposes of analytics or statistics, or to collect aggregated or combined data or information.
C. Temporary session cookies are those which are destroyed or deleted after a browsing session and are used to identify you and allow you to not log in repeatedly after each browsing session so long as your browser is not closed.
D. Permanent cookies are those which remain for a longer period, while these function the same as temporary cookies in that they are used to identify you and allow you to not log in repeatedly after each browsing session, they remain on your device even after your browser is closed.
E. Profiling cookies are utilized to establish user profiles and send you marketing or advertising communications according to your browsing behavior and history.
You provide your specific consent when these types of cookies are used to enable you to have the best experience on our Website.

VIII. CRITERIA FOR LAWFUL PROCESSING OF PERSONAL INFORMATION
In accordance with the specified purposes of using your data or information, the following are the criteria or legal basis for processing your information:
A. You give us your consent before we collect and process your personal information.
B. Processing your personal information involves the performance of an obligation under a contract to which you are a party, including the act of entering into a contractual obligation.
C. Processing your personal information is required for us to comply with a legal obligation.
D. Processing your personal information is necessary to protect vitally important interests, including your life and health, or those of another.
E. Processing your personal information is necessary to respond to a national emergency, or to comply with the requirements of public order and safety, as prescribed by law.
F. Processing your personal information is necessary to fulfill the constitutional or statutory mandate of a public authority.
G. Processing your personal information is necessary to ensure our legitimate interests or the legitimate interests of a third party (except when such interests are overridden by your fundamental and constitutional rights.) Details of the legitimate interests referred to herein will be provided if this is the basis or criterion by which your personal information is processed.
Generally, we will process your personal information based on the specified purposes in this Privacy Policy mainly where:
A. We obtain your consent explicitly each time we process your personal information based on the purposes specified in this Privacy Policy.
B. It is required in order to perform a contractual obligation to which you are a party, including the act of entering into such contractual obligation with you.
C. We are required to comply with a legal obligation.
D. It is necessary to protect vitally important interests, including your life and health, or those of another.
E. It is necessary to pursue our legitimate interests or those of another after we ensure that your fundamental and constitutional rights are protected.
F. It is necessary for the fulfillment of the constitutional or statutory mandate of a public authority.
 

IX. CRITERIA FOR LAWFUL PROCESSING OF SENSITIVE PERSONAL INFORMATION
Your sensitive personal information or privileged information can only be processed in the following instances:
A. You give us your consent before we collect and process your sensitive personal information or privileged information in accordance with the specified purpose.
B. Processing your sensitive personal information or privileged information is allowed by existing laws and regulations which do not require your consent for the processing and protection of such data.
C. Processing your sensitive personal information or privileged information is necessary to protect your life and health or that of another person, and you are unable to give consent.
D. Processing your sensitive personal information or privileged information is necessary for lawful, non-commercial objectives of public organizations, confined to bona fide members only, with no transfer to third parties, and your consent was obtained before processing such information.
E. Processing your sensitive personal information or privileged information is necessary for medical treatment, with adequate data protection.
F. Processing your sensitive personal information or privileged information is necessary for legal claims or defense of lawful rights and interests of natural or legal persons in court proceedings, or pursuant to a constitutional or statutory mandate.
These situations allow for the lawful processing of sensitive personal information or privileged information. The main criterion for processing your sensitive personal information or privileged information to meet our specified purpose is when processing your personal information is based on your consent given according to the specified purpose in this Privacy Policy.

 

X. THIRD-PARTY SERVICE PROVIDERS
We may share your information with third-party service providers, and vice versa, to help improve your experience on our Website. This includes the following:
A. Non-sale of Data: Your personal information will not be sold to third parties without first obtaining your specific consent.
B. Hosting: We may use the services of third-party service providers to host our Website which will also allow such providers to access your personal information.
C. Storage: We may use the services of third-party service providers for web or cloud storage to assist us with storing your information.
D. Social Media API: Our Website uses the API (Application Programming Interface) of social networks, in order to allow integration of the functionalities of such social networks into your use of the Website. This integration allows for easy sharing of your data or information from our Website to such social networks and vice versa. Cookies are set if you voluntarily use the services of such social networks within our Website, thus it means that you consent to the use of cookies. The handling or processing of your data or information is governed by the respective privacy policies of such social networks. You may read the privacy policies in their respective websites.
E. Other: We may use the services of third-party service providers in relation to our Website to accomplish the following:
       Wixx.com
       Google.com

​

XI. LENGTH OF RETENTION OF PERSONAL INFORMATION
Your data or information will be retained by us for a period of time, not more than what is required to fulfill the purposes as specified in this privacy policy.
The manner by which we will retain your data or information is described as follows:
The information will be kept from the time of registration and will be kept after cancellation one year after the last issued policy has expired.
After the lapse of the period as stated in the previous paragraph, your information shall be destroyed, deleted, or anonymized.

 

XII. SECURITY MEASURES
We will make sure that your data or information is safe and secure through the measures we have in place for you. We have adopted organizational, physical, and technical security measures to maintain the protection of your data and information.
Organizational Security Measures:
We have appointed a Data Privacy Officer who will make sure that your data or information is protected and that we are compliant with the requirements of the Data Privacy Act of 2021 and other privacy laws, rules, and regulations;
Data is handled by employees trained in Data Privacy. 
Employees will only have access to data that is pertinent to their specific task. 
A computer login mechanism is in place for employees.
Physical Security Measures:
The company has a Non-disclosure Agreement for all employees. 
A computer log-in system is instituted for all employees. 
Active physical files are kept in a locked cabinet. 
Archived files are kept in a locked area with only the records personnel having access. 
A shredder is used to discard all unofficial and draft files.
Technical Security Measures:
 

XIII. LOCATION OR SCOPE
Your data or information shall be processed in the Philippines only and may also be shared with companies within the Philippines, and will be done in a manner that is compliant with the requirements of the Data Privacy Act of 2012.

XIV. RIGHTS OF THE USER
The following are your rights in relation to your data or information handled by us. These rights are those laid down by the Data Privacy Act of 2012:
A. Right to be informed: You have the right to be informed whether data or information pertaining to you shall be, are being, or have been processed, including the existence of automated decision-making and profiling.
B. Right to object: You have the right to object to the processing of your data or information, including processing for direct marketing, automated processing, or profiling.
When you object or withhold your consent, we shall no longer process the personal data, unless:
a. The data or information is needed pursuant to a subpoena;
b. The collection and processing are for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which you are a party, or when necessary or desirable in the context of an employer-employee relationship between the collector and the data subject; or
c. The information is being collected and processed as a result of a legal obligation.
C. Right to access: You have the right to reasonable access to, upon demand, the following:
a. Contents of your data or information that were processed;
b. Sources from which your data or information were obtained;
c. Names and addresses of recipients of your data or information;
d. Manner by which such data were processed;
e. Reasons for the disclosure of your data or information to recipients, if any;
f. Information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you;
g. Date when your personal information concerning you, was last accessed and modified; and
h. Our designation, name or identity, and address.
D. Right to rectification: You have the right to dispute the inaccuracy or error in your data or information and have us correct it immediately and accordingly unless the request is vexatious or otherwise unreasonable.
E. Right to erasure or blocking: You have the right to suspend, withdraw or order the blocking, removal, or destruction of your data or information from our systems.
F. Right to data portability: You have the right to electronically move, copy or transfer your data or information without cost for whatever use you require.
G. Right to damages and to file a complaint: You have the right to file a case and/or be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your data or information, taking into account any violation of your rights as a data subject.

 

​XV. REVISION AND UPDATE OF PRIVACY POLICY
We may update and revise this Privacy Policy from time to time and will notify you of any changes. Our Website was last published and updated on 15 March 2024.
The notice of revision may be made in the following manners:
An email will be sent to registered users.