Atlantis Systems Technologies Filipinas Corporation's Privacy Policy Atlantis Systems Technologies Filipinas Corporation's ("Atlantis") is concerned about the data subject right to privacy. Therefore, Atlantis pledges to be responsible when gathering data subject personal information and to protect their privacy in every possible way. Although this Privacy Policy is not a contract and does not create any legal rights, it serves as an expression of Atlantis commitment to protecting private personal information. Atlantis reserves the right to change, amend and/or vary this Privacy Policy at any time and will notify users of the same by updating the policy on Atlantis website @ glocorp.asia (“Website”) and by including a "NEWLY UPDATED" label with the "PRIVACY POLICY" link on the websites governed by this policy for a period of 30 days. This Privacy Policy describes the information that Atlantis collects, how it is used, when it may be shared with others, and how we safeguard its confidentiality and security. This Privacy Policy is applicable to all users of our Website including Travel Reservations, Corporate Sales, Marketing Research, Investor Relations, Customer Relations/Service and Customer Support. "Information collection" We collect and maintain information that data subject enter on our Website or give us in any other way (collectively, "Personal Information"). The data subject can choose not to provide certain information, but they may not be able to enjoy all the features of our Website and services provided by Atlantis. Personal Information we learn from data subject helps us to personalise and continually improve their online experience. Here are the types of Personal Information that we collect: • Personally identifiable information e.g. Name, gender, date of birth, nationality, country of residence; • Contact information e.g. address, email address and phone numbers; • Travel information e.g. flight information, and currency, departure destination or other product preferences; • Technical information e.g. IP address. When the data subject interact with applications created by Atlantis or our affiliates, we may collect information about their location and mobile device. The information may be used to provide them with location-based services such as search results and marketing content. Data subject may decline to share their Personal Information with us, or disable location services on their mobile device at any time. "Use of information collected" Generally, we use the data subject Personal Information for administrative purpose e.g. processing, confirming, fulfilling and completing your transactions and requests for our services. In the event there is a transaction problem/issue, we will notify the data subject via email based on the Personal Information which they provided to us through our booking engine. In addition to this, Data Subject Personal Information will be used for the purposes of sales, marketing or cross-marketing of products and services, investigation of claims and inquiries, check-in, refund, safety, security, statistical and marketing analysis, information systems management, system testing, maintenance and development, operational, support, customer surveys, customer relations and to improve and help us in any future dealings with them, for example by identifying your requirements and preferences. If our client/hotel is subscribed to our Loyalty Program and the data subject elected to be a member, they will also be a participant in the Atlantis Loyalty Programme In such cases, their Personal Information will also be used to administer their membership and offer them the perks which they are eligible for under this programme. "Sharing of Information Collected" We may process and disclose data subject Personal Information with Atlantis Group, our subsidiaries and affiliates and/or third parties, such as credit card verification providers, data analytics, safety and security personnel, parties which have business or contractual dealings with Atlantis and its subsidiaries or affiliates, and other third party who is able to demonstrate that you have explicitly consented to the disclosure of your Personal Information by us to such third party. Your Personal Information may also be disclosed or transferred to any of Atlantis actual and potential assignee, transferee or acquirer (within or outside Philippines) (including our affiliates and subsidiaries) or our business, assets or group companies, or in connection with any corporate restructuring or exercise including the our restructuring to transfer the business, assets and/or liabilities. Furthermore, Atlantis will jointly use Personal Information as well as cookies for the purposes as described in “Use of information collected” and “Cookies” respectively. Whenever required by law, we will disclose your Personal Information to the government bodies or authorities or third parties pursuant to a subpoena or other legal process accordingly. As part of our effort to serve you better, we are constantly enhancing and expanding our services to fulfill your ever-growing needs. In order to realise this business aim, we will from time to time appoint, authorise or contract with strategic business partners. Your Personal Information may be disclosed to these business partners, authorised or contracted third parties, service providers or advertisers to make available promotions, offers, products or services, which may or may not belong to us but relate to the products or services you have elected to obtain from us. However, to ensure that you will not receive unwanted communications, only information with regards to promotions, offers, products or services which are relevant to your transaction with us, or that you have selected or marked as interested in your member profile, will be shared with the respective business partners, service providers or third parties. In the circumstances set out in this Privacy Policy where Atlantis shares your Personal Information to a third party, we will ensure that the security measures that such party has in place in relation to the processing of your data are at least as stringent as those employed by Atlantis if not better. This does not apply where we are required by law to pass your information to a third party. In the event we go through a business transition, such as sale of part or all of our assets, merger or acquisition, your information will likely form part of this transition and be transferred. Atlantis does not sell or rent any of your Personal Information on our Website to any other parties. Atlantis may share anonymous and/or aggregated information about all our users with third parties. For inquiries on management of Personal Information disclosed to, or shared with Atlantis and/or third parties hereunder, please see “Contact information” section below. "Data storage" The headquarters of Atlantis is located in Philippines. However, we may transfer and store the data subject Personal Information on our servers located overseas. Such transfers are necessary pursuant to our contract with data subject and/or our contract(s) with the relevant third parties. Atlantis will secure the storage in compliance with the minimum security measures prescribed under the Philippine Data Privacy Act of 2012, its regulation and standards, in the following manners: "Data subject consent" Atlantis or any third party service providers engaged by us will obtain data subject consent to collect and use their Personal Information at the time of collection, subject to certain legally prescribed circumstances where their consent is not required. Where required by law, Atlantis will adopt an ‘opt-in' policy to obtain their express written consent when collecting their Personal Information. They may be asked, for example, to sign a form or tick a box. Generally, in using the Website, data subject consent to the collection and use of their Personal Information by Atlantis in the ways described above (which may change from time to time) unless and until data subject inform us to the contrary. Data subject may submit a request to withdraw their consent at any time by contacting Atlantis. If you have provided us Personal Information of third party individuals in your travel party, you are required to obtain the individual's prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their personal information to us. By providing us Personal Information of third party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Privacy Policy. In most instances, it is obligatory for you to provide us with your Personal Information in order to allow us to satisfy your request or provide you with the service that you have requested for. However, we will provide you with an avenue to opt-out or unsubscribe from receiving marketing, communications, promotional offers, newsletters or any other communications from Atlantis. "Access to and Correction of Your Personal Information" Data subject may access their Personal Information by logging-in to your Member Profile. We will need data subject assistance to ensure that Personal Information they provide to us is current, complete and accurate. If there are errors or changes to be made, please contact us and we will work towards either correcting it or discussing alternative actions with them. We will not correct their Personal Information upon request of a third party, unless such third party is able to demonstrate that data subject have provided the authority to such third party to work with us to correct their Personal Information.