1. Introduction & Scope
The Pasinaya Homes Subdivision Homeowners Association, Inc. ("HOA"), through the ePasinaya HOA Connect digital management system, is firmly dedicated to safeguarding the personal data and privacy of all registered homeowners, tenants, household members, authorized security personnel, and visitors.
This Privacy Policy explains how our subdivision processes, stores, protects, and retains your personal information in accordance with Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations (IRR), and applicable NPC Advisory Opinions on Homeowners Associations.
2. Categories of Personal Data Collected
We collect and process personal data necessary to manage the subdivision and maintain community safety:
Resident & Account Data
- Full name, email address, contact numbers
- Assigned block, lot, phase, and unit number
- Account login credentials (securely hashed)
- Property classification (owner, tenant, commercial)
Billing & Financial Proofs
- Monthly association dues assessment history
- Payment transaction receipts and reference IDs
- Proof of payment images/screenshots (bank transfers)
- Statement of account records
Gate Pass & Security Logs
- Visitor names, expected arrival dates, and purpose
- Vehicle plate numbers and delivery details
- Security guard verification timestamps
- Visitor photo identification captured at gates
Community Concerns & Tickets
- Incident reports, maintenance requests, complaints
- Uploaded photos documenting subdivision issues
- Staff resolution notes and correspondence
3. Purpose & Lawful Basis of Processing
We process personal information under the following lawful bases permitted by RA 10173:
- •Legitimate Interests (Section 12(f)): Protecting community security, controlling entry/exit at gates, verifying resident digital IDs, ensuring fair collection of maintenance dues, and emergency response.
- •Consent (Section 12(a)): For digital portal registration, communications, and voluntary profile information.
- •Compliance with Legal Obligations (Section 12(c)): Compliance with Republic Act No. 9904 (Magna Carta for Homeowners) and financial reporting standards.
4. Data Retention & Storage Limitation
In accordance with the principle of storage limitation under RA 10173, data is kept only as long as necessary:
| Record Type | Retention Period | Disposal Method |
|---|---|---|
| Visitor Photo IDs at Gates | 60 Days | Automated permanent deletion |
| Visitor Pass Logbook Records | 1 Year | Archived / automated purge |
| Dues Payments & Invoices | 10 Years | Statutory audit compliance archive |
| Resident Membership Records | Duration of residency + 2 years | Deactivated & anonymized |
5. Security Safeguards Implemented
We employ organizational, physical, and technical measures to protect personal data from unauthorized access, loss, or alteration:
- Strong Cryptography: Passwords hashed with bcrypt (cost factor 12).
- Unguessable Tokens: Digital QR codes utilize cryptographic UUID tokens, preventing roster scraping.
- Authorized File Access: Uploaded payment receipts and gate documents require verified session authentication.
- Audit Logging: All security, gate-pass verification, and payment approval actions are logged immutably.
6. Your Rights Under RA 10173
As a data subject, you hold the following rights under Philippine law:
Right to Be Informed
Know how and why your personal data is collected and processed.
Right to Access
Request copies of your member profile, invoices, and activity logs.
Right to Rectification
Dispute inaccuracies in your contact info, dues, or property records.
Right to Erasure
Request removal of data once retention periods expire.
Right to Damages
Indemnification for damages due to inaccurate or unlawful processing.
Right to File Complaint
File a grievance directly with the National Privacy Commission (NPC).
7. Data Protection Officer (DPO) Contact
If you have any questions, inquiries, or requests regarding this Privacy Policy or your rights as a data subject, please contact our Data Protection Officer:
Data Protection Officer · ePasinaya HOA
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