Data Privacy

Whistleblower Application Privacy Notice Equicom Services, Inc. ("EquiServe," "we," "us") values your privacy and is committed to protecting personal data in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission. This Privacy Notice explains how personal data is collected and processed in relation to the use of EquiServe’s Whistleblower Application. Purpose EquiServe’s Whistleblower Application (the "System") is used to securely receive and process reports of suspected violations, misconduct, unethical behavior, or other acts detrimental to the Company, its employees, clients, or stakeholders. Legal Basis for Processing Personal data collected through the System is processed based on: Legitimate Interest – for the detection, prevention, investigation, and resolution of violations and misconduct; Compliance with Legal Obligations; and Employment Relationship, where applicable. Voluntary Reporting and Anonymity Use of the System is voluntary. Reports may be submitted anonymously or with identifying information. Providing contact details may assist in the investigation but is not required. Personal Data Collected Depending on the report, the following data may be processed: Reporting person’s name, contact details, and relationship to EquiServe (if voluntarily provided); Personal data of persons involved, witnesses, or relevant individuals, limited to what is necessary for the report. Access, Use, and Disclosure Personal data is accessed only by authorized EquiServe personnel on a need-to-know basis and treated with strict confidentiality. Data may be disclosed to law enforcement or regulatory authorities only when required by law or lawful order. The system provider is engaged solely for technical maintenance and has no ownership over the data. Data Security EquiServe implements appropriate organizational, physical, and technical security measures, including encrypted communications and restricted access controls, to protect personal data processed through the System. Data Retention Personal data is retained only for as long as necessary to investigate and resolve reports and to comply with legal and regulatory requirements. Thereafter, data is securely disposed of or anonymized. Data Subject Rights Data subjects have the rights to be informed, access, correct, object to processing, request limitation, and lodge a complaint with the National Privacy Commission, subject to the Company’s legitimate interests and legal obligations. Contact Information For questions or concerns regarding this Privacy Policy or the processing of personal data, you may contact: Data Protection Officer Equicom Services, Inc. dpo@equicomservices.com