Executive Circle Corporation

Effective Date: August 1, 2026
Last Updated: August 1, 2026

Executive Circle Corporation ("ECC," "we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you visit goecircle.com, submit an inquiry, subscribe to communications, apply for an opportunity, or otherwise interact with us through the website (collectively, the "Website").

We process personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, applicable issuances of the National Privacy Commission ("NPC"), and other applicable laws.

1. Personal Information Controller

For personal data processed through this Website, the personal information controller is:

Executive Circle Corporation
Registered address: Phinma Plaza, 39 Plaza Drive, Makati City, 1210
Privacy contact/DPO: Martin Manalansan
Email: amm@goecircle.com
Telephone: +63 917 159 2389
Website: goecircle.com

2. Scope of This Policy

This Policy applies to personal data collected through the Website and related electronic communications with ECC.

It does not automatically govern personal data processed under a separate client, employment, supplier, or project agreement when that agreement includes its own privacy terms. Third-party websites linked from our Website are governed by their own privacy policies.

3. Personal Data We May Collect

Depending on how you interact with ECC, we may collect:

Identity and contact information, such as your name, email address, telephone number, company, job title, and business address;
Inquiry and project information, such as the service you are interested in, your message, project requirements, proposed scope, budget information, and related communications;
Subscription information, such as your email address and communication preferences;
Recruitment information, if you apply for a position, such as your resume, qualifications, employment history, portfolio, and other information you submit;
Technical and usage information, such as IP address, browser type, device type, operating system, referring page, pages visited, timestamps, and diagnostic or security logs;
Cookie and preference information, where cookies or similar technologies are used; and
Other information you voluntarily provide to ECC.

Please do not submit passwords, banking credentials, private encryption keys, medical information, government identification numbers, confidential production data, or other sensitive information through a general inquiry form unless ECC specifically requests it through an appropriate secure channel.

4. How We Collect Personal Data

We may collect personal data:

Directly from you when you complete a form, send an email, call us, subscribe, apply, or otherwise communicate with ECC;
Automatically when you access or use the Website, through server logs, cookies, and similar technologies;
From your employer, authorized representative, or business contact when they include you in a legitimate business communication; and
From lawful public sources, referrals, professional networks, or service providers where permitted by law.

If you provide personal data about another person, you confirm that you are authorized to provide it and have given that person any notice required by law.

5. Purposes of Processing

ECC may process personal data to:

Respond to questions, inquiries, and requests;
Understand your requirements and recommend relevant services;
Prepare quotations, proposals, demonstrations, and project assessments;
Communicate about prospective or existing business engagements;
Deliver contracted services and provide customer support;
Manage newsletter subscriptions and marketing preferences;
Evaluate employment or contractor applications;
Maintain business, accounting, operational, and communication records;
Administer, maintain, troubleshoot, and improve the Website;
Monitor Website performance and understand general usage patterns;
Detect, prevent, investigate, and respond to fraud, abuse, cyberattacks, and security incidents;
Establish, exercise, or defend legal claims;
Comply with contractual, regulatory, tax, audit, and legal obligations; and
Fulfill another purpose disclosed to you at the time of collection.

ECC will not use personal data for an incompatible purpose without an appropriate lawful basis and, where required, additional notice or consent.

6. Lawful Bases for Processing

Depending on the circumstances, ECC may process personal data when:

You have given valid consent;
Processing is necessary to respond to your request or take steps before entering into a contract;
Processing is necessary to perform a contract with you or your organization;
Processing is necessary to comply with a legal obligation;
Processing is necessary to protect life and health;
Processing is necessary to respond to a national emergency or fulfill a lawful public-authority function; or
Processing is necessary for ECC's legitimate interests or those of a third party, where permitted by law and not overridden by your fundamental rights and freedoms.

Where processing is based on consent, you may withdraw your consent, subject to legal and contractual limitations. Withdrawal will not affect processing lawfully performed before withdrawal.

7. Cookies and Similar Technologies

The Website may use cookies and similar technologies to provide essential functions, remember preferences, maintain security, understand Website use, and improve performance.

Some cookies may be placed by third-party providers whose components, fonts, scripts, analytics, maps, videos, or social-media features appear on the Website. Those providers may process information under their own privacy policies.

Where required, we will request consent before placing non-essential cookies. You may control or delete cookies through your browser settings, but disabling certain cookies may affect Website functionality.

8. Marketing Communications

ECC may send newsletters, service updates, invitations, or promotional communications when you request them, consent to receive them, or when otherwise permitted by law.

You may unsubscribe through the link provided in a message, if available, or contact us using the details in Section 1. We may still send essential transactional, contractual, security, or legal communications.

9. Disclosure of Personal Data

ECC may disclose personal data only when reasonably necessary and permitted by law, including to:

Authorized ECC directors, officers, employees, consultants, and contractors who need the information for legitimate duties;
Website hosting, cloud, email, communications, cybersecurity, analytics, backup, professional-advisory, and other service providers;
Clients or business partners when necessary for an authorized project or transaction and subject to appropriate safeguards;
Professional advisers, auditors, insurers, banks, and payment providers;
Government agencies, regulators, courts, law-enforcement authorities, or other parties when required or authorized by law;
A buyer, investor, successor, or adviser in connection with a legitimate merger, acquisition, financing, reorganization, or transfer of business assets; and
Other parties with your authorization or as otherwise disclosed at collection.

ECC does not sell personal data for monetary consideration.

10. Outsourcing and International Transfers

Some service providers may process or store data outside the Philippines. When personal data is transferred or made accessible across borders, ECC will take reasonable steps to use providers and arrangements that offer appropriate privacy and security safeguards, consistent with applicable law.

ECC remains accountable for personal data under its control and requires processors to use personal data only for authorized purposes and to implement appropriate protections.

11. Data Retention

ECC retains personal data only for as long as reasonably necessary to fulfill the purposes described in this Policy, meet contractual requirements, resolve disputes, establish or defend legal claims, maintain security, and comply with applicable legal, accounting, tax, and regulatory obligations.

Retention periods vary according to the type of data and purpose of processing. For example:

General inquiries that do not lead to an engagement may be retained for up to two years after the last meaningful communication;
Marketing subscription records may be retained while the subscription remains active and for a reasonable period afterward to record an opt-out;
Recruitment records may be retained for up to one year after the application process, unless a longer period is required or you consent to continued consideration;
Client and transaction records may be retained for the duration of the engagement and afterward for the period required by applicable law or legitimate legal and business needs; and
Security and server logs may be retained for a reasonable period appropriate to investigation, system integrity, and cybersecurity purposes.

Data may be retained longer when required by law, necessary for an active dispute or investigation, or preserved in secure backups until normal deletion cycles are completed. Data that no longer needs to identify an individual may be anonymized and retained for legitimate statistical or operational purposes.

12. Security Measures

ECC implements reasonable and appropriate organizational, physical, and technical measures designed to protect personal data against accidental or unlawful destruction, alteration, disclosure, misuse, loss, and unauthorized access.

Measures may include access controls, authentication, encryption where appropriate, secure configuration, backups, monitoring, personnel confidentiality obligations, vendor review, and incident-response procedures.

No internet transmission or storage system is completely secure. You should avoid sending sensitive information through unsecured channels and notify ECC promptly if you suspect unauthorized use of your information.

13. Personal Data Breaches

ECC maintains procedures for assessing and responding to suspected personal data breaches. Where notification is required by applicable law or NPC rules, ECC will notify the NPC and affected data subjects within the applicable period and provide information reasonably required by law.

14. Your Rights as a Data Subject

Subject to the conditions and limitations provided by law, you may exercise the following rights:

Right to be informed about the collection and processing of your personal data;
Right of access to personal data ECC processes about you;
Right to object to certain processing, including direct marketing, automated processing, or profiling, where applicable;
Right to rectification of inaccurate or incomplete personal data;
Right to erasure or blocking in circumstances provided by law;
Right to data portability where applicable;
Right to damages for harm caused by unlawful or unauthorized processing; and
Right to file a complaint with the National Privacy Commission.

You may also withdraw consent where consent is the basis of processing.

15. Exercising Your Rights

To make a privacy request, contact the privacy contact or Data Protection Officer listed in Section 1 and use the subject line Privacy Request.

Please describe your request clearly and provide information reasonably necessary to verify your identity. ECC may request additional verification to protect you and other individuals from unauthorized disclosure.

ECC will respond within the period required by applicable law. A request may be limited or denied when permitted by law, including when necessary to protect another person's rights, comply with a legal obligation, preserve privileged information, or establish or defend a legal claim. ECC will explain the applicable reason where required.

You may contact the National Privacy Commission through its official website at privacy.gov.ph if you believe your privacy rights have been violated.

16. Children's Privacy

The Website is intended primarily for businesses and adults. ECC does not knowingly solicit personal data from children through general inquiry forms.

If you believe a child has submitted personal data without appropriate parental or guardian authorization, please contact us so we can assess and take appropriate action.

17. Automated Decision-Making

ECC does not currently use personal data collected through its general Website inquiry and subscription forms to make decisions based solely on automated processing that produce legal or similarly significant effects.

If this practice changes, ECC will provide appropriate notice and safeguards as required by law.

18. Third-Party Links

The Website may contain links to external websites, platforms, and services. ECC does not control their privacy or security practices. Please review the privacy policies of those third parties before providing them with personal data.

19. Changes to This Privacy Policy

ECC may update this Policy to reflect changes in its Website, services, processing activities, security practices, or legal obligations.

The revised Policy will be posted on the Website with an updated "Last Updated" date. When changes materially affect your rights or the way ECC processes personal data, ECC will provide additional notice when reasonably practicable or legally required.

20. Contact Us

Questions, concerns, complaints, or requests regarding this Privacy Policy may be directed to: