Data Privacy Notice

1. About This Notice

The Rotary Club of Makati-Paseo de Roxas (“RCMPDR,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal data collected and processed in connection with the RCMPDR x IBM SkillsBuild Program.

This Data Privacy Notice explains:

• What personal data we collect;
• Where we obtain it;
• Why and how we process it;
• With whom it may be shared;
• How long it may be retained;
• How we protect it; and
• How you may exercise your rights under Republic Act No. 10173, or the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (“NPC”).

This Notice applies to personal data processed through the RCMPDR IBM SkillsBuild landing page, learner registration form, administrative portal, partner-school or organization records, IBM/APC report reconciliation process, and related program communications.

2. Who Is Responsible for Your Personal Data

For personal data collected directly through the RCMPDR registration portal, the intended Personal Information Controller is:

RCMPDR determines the purposes and means by which registration information is collected and used for the administration, monitoring, and reporting of this program.

3. Separate RCMPDR and IBM SkillsBuild Systems

The RCMPDR registration portal and the IBM SkillsBuild platform are separate systems.

Submitting the RCMPDR registration form:

• Records your participation under your selected Rotary Club and school, office, or organization;
• Does not automatically create an IBM SkillsBuild account;
• Does not automatically enroll you in an IBM SkillsBuild course; and
• Does not guarantee course completion or the award of an IBM digital credential.

After completing the RCMPDR form, you will be directed to the official IBM SkillsBuild platform, where you must separately create or access an IBM SkillsBuild account. You should use the same email address on both the RCMPDR registration form and the IBM SkillsBuild platform. This allows RCMPDR to match your registration with the reports later provided by IBM and/or Asia Pacific College (“APC”).

Personal data that you submit directly to IBM is processed according to IBM’s own privacy notice, terms, and data-processing practices.

4. Personal Data We May Collect

Depending on your participation and the final program configuration, we may collect and process the following information:

A. Information You Submit Through the Registration Form

• First name;
• Last name;
• Email address;
• Learner category;
• Complete name of school, college, university, office, company, or organization;
• Sponsoring Rotary Club;
• Rotary Club number and district number automatically associated with your selected club;
• Grade level, year level, department, program, cohort, or other school-related information, if later approved and included;
• Information included in messages, registration-correction requests, inquiries, or support requests;
• Your confirmation that you have read this Notice;
• Your consent, where consent is used as the lawful basis for processing; and
• Any other information clearly identified as optional or required at the time of collection.

B. Information Received From IBM and/or APC

The reports provided by IBM and/or APC may contain:

• IBM SkillsBuild Learner ID;
• Learner name;
• Learner email address;
• Learning activity or course title;
• Learning activity or course ID;
• Course duration;
• Learning delivery type;
• Learning source or content provider;
• Transcript or course status, such as “In Progress” or “Completed”;
• Completion date;
• Number of courses or learning activities taken;
• Total learning hours; and
• Other participation, engagement, or completion information included in the approved IBM/APC report format.

Information relating to your education, learning history, and course progress may be considered sensitive personal information under applicable law and will be handled with additional care.

C. Information Received From Schools, Organizations, or Rotary Clubs

Partner schools, offices, organizations, or Rotary Clubs may provide an authorized participant list containing information such as:

• Learner name;
• Email address;
• School, organization, department, or cohort;
• Learner category;
• Sponsoring Rotary Club; and
• Confirmation that the individual has been nominated, endorsed, invited, or included in the program.

Where your information is received from another organization instead of directly from you, we will provide or make this Notice available to you at the next practical opportunity.

D. Website and Technical Information

The portal may automatically collect limited technical data necessary to operate, secure, and troubleshoot the website, such as:

• Internet Protocol address;
• Browser and device type;
• Operating system;
• Date and time of access or registration;
• Pages or functions accessed;
• Referral or campaign source;
• Security and error logs; and
• Strictly necessary cookies or similar technologies.

5. How We Obtain Your Personal Data

We may obtain your personal data:

• Directly from you when you complete the registration form or contact the project team;
• From your school, office, organization, or sponsoring Rotary Club through an authorized participant list;
• From IBM and/or APC through program enrollment, engagement, progress, and completion reports;
• From your use of the RCMPDR registration website; and
• From authorized RCMPDR administrators who correct, verify, classify, or update a registration record.

6. Why We Process Your Personal Data

We may process your personal data for the following purposes:

• To register your interest and participation in the RCMPDR x IBM SkillsBuild Program;
• To categorize and associate your registration with the correct Sponsoring Rotary Club, Rotary district, School/organization, and Learner category;
• To direct you to the unique IBM SkillsBuild registration link;
• To remind you to use the same email address when creating your IBM SkillsBuild account;
• To match and reconcile your RCMPDR registration with IBM/APC learner reports;
• To determine whether a registration is matched with an IBM learner record, not yet found, found in an IBM report but not in the database, matched through an approved partner-school roster, a possible duplicate, or in need of manual review;
• To monitor program registration, participation, engagement, course progress, learning hours, and completion;
• To prepare reports for RCMPDR, participating Rotary Clubs, partner schools, offices, organizations, APC, IBM, and other authorized program stakeholders;
• To provide registration assistance, correct submitted information, and respond to inquiries;
• To produce aggregated or anonymized statistics relating to program reach, participation, engagement, and impact;
• To maintain accurate records, import histories, audit trails, and administrative logs;
• To protect the security and integrity of the website, database, and administrative portal;
• To investigate errors, suspected abuse, unauthorized access, security incidents, or data breaches;
• To comply with legal, regulatory, contractual, audit, and reporting obligations; and
• To establish, exercise, or defend legal claims when necessary.

We will not sell your personal data or use it for unrelated commercial advertising.

7. Lawful Basis for Processing

Depending on the specific processing activity, RCMPDR may rely on one or more lawful grounds permitted under the Data Privacy Act of 2012, including:

• Your freely given, specific, and informed consent;
• The legitimate interests of RCMPDR and authorized program partners in administering, securing, monitoring, and evaluating the program, provided that these interests do not override your fundamental rights and freedoms;
• Compliance with a legal or regulatory obligation;
• The establishment, exercise, or defense of legal claims; and
• Other lawful grounds permitted by the DPA and applicable NPC issuances.

Where education-related, age-related, or other sensitive personal information is processed, RCMPDR will process it only under a lawful ground permitted for sensitive personal information, including your specific consent where required.

Where processing is based on consent, you may withdraw your consent by contacting the RCMPDR privacy contact. Withdrawal will not affect processing lawfully performed before the withdrawal. However, withdrawal may prevent RCMPDR from continuing to match, monitor, verify, or include your participation in named program reports.

8. Matching and Automated Processing

The portal may use your email address as the main identifier for matching your RCMPDR registration with IBM/APC records.

The system may also automatically:

• Associate your selected Rotary Club with its club number and district;
• Normalize email addresses for matching;
• Identify possible duplicates;
• Categorize records as matched, unmatched, or requiring review; and
• Calculate program statistics based on imported report information.

These automated functions are intended to assist with record administration and reporting. They are not intended to make a decision that determines your eligibility to create an IBM account, access an IBM course, complete a course, earn a digital credential, or obtain employment.

Where a match is uncertain, the record should be referred to an authorized administrator for manual review.

9. With Whom We May Share Your Personal Data

Access to identifiable personal data will be limited to authorized persons who require it for legitimate program purposes. We may disclose or make relevant information available to:

• A. Authorized RCMPDR Administrators: Authorized RCMPDR project officers and administrators may access registration, matching, learning activity, and reporting information to administer and monitor the program.
• B. Asia Pacific College and IBM: RCMPDR may receive relevant learner and progress information from APC and/or IBM. RCMPDR may also share limited registration or verification information with APC and/or IBM when necessary for approved program administration, record matching, issue resolution, reporting, or compliance.
• C. Sponsoring Rotary Clubs: Authorized representatives of your selected sponsoring Rotary Club may receive information reasonably necessary to verify registrations attributed to the club, monitor participation, support learners, review engagement and completion results, and receive agreed program reports.
• D. Partner Schools, Offices, and Organizations: Authorized representatives of your school, office, or organization may receive information reasonably necessary to confirm your inclusion in the program, monitor the participation of their own learners or members, provide learner support, and receive agreed participation and completion reports.
• E. Futurex Inc. and Other Technical Service Providers: Where Futurex Inc. or another contracted provider hosts, develops, maintains, secures, backs up, troubleshoots, or supports the portal and database, that provider may process limited personal data only under RCMPDR’s instructions and for authorized technical purposes.
• F. Hosting, Email, Cloud, Security, and Other Service Providers: We may engage reputable providers for services such as website hosting, email delivery, and security. These providers should receive only the information necessary to perform their contracted services.
• G. Government Authorities and Other Parties Required by Law: We may disclose information where required by law, regulation, lawful order, subpoena, investigation, or legal process.

10. Reports and Public Information

RCMPDR may prepare reports according to Rotary Club, school, office, organization, learner category, course, engagement status, completion status, or learning hours. Named or identifiable learner-level reports should be provided only to authorized recipients with a legitimate program purpose and under approved data-sharing arrangements.

Reports intended for the public, social media, promotional materials, or general project presentations should use aggregated or anonymized information unless the learner has separately authorized the publication of identifiable information. Photographs, videos, testimonials, success stories, and quotations are not covered by general program registration consent and should require a separate, specific release where applicable.

11. Cross-Border and External Processing

IBM SkillsBuild and some technology or cloud service providers may operate systems or infrastructure outside the Philippines. When you proceed to the IBM SkillsBuild website, any personal data that you submit directly to IBM may be processed in accordance with IBM’s own privacy notice and applicable international data-processing arrangements.

Where RCMPDR transfers or permits the processing of personal data outside the Philippines, RCMPDR will remain accountable for the data under its control and will require appropriate contractual, organizational, and security safeguards as required by applicable law.

12. How Long We Retain Personal Data

RCMPDR will retain identifiable personal data only for as long as reasonably necessary to fulfill the purposes described in this Notice, comply with applicable legal or contractual requirements, respond to inquiries or disputes, and establish or defend legal claims.

At the end of the applicable retention period, records will be securely deleted, destroyed, anonymized, or aggregated so they can no longer reasonably identify an individual, unless continued retention is permitted or required by law.

13. How We Protect Your Personal Data

RCMPDR will implement reasonable and appropriate organizational, physical, and technical measures designed to protect personal data against accidental or unlawful loss, alteration, destruction, unauthorized access, disclosure, or other unauthorized processing.

No online system can be guaranteed to be completely secure. RCMPDR will nevertheless maintain safeguards proportionate to the nature and risks of the personal data being processed.

14. Participants Below 18 Years Old

The program may include senior high school students, some of whom may be below 18 years old. RCMPDR will seek to present privacy information in language that is understandable to younger participants and will coordinate with partner schools or organizations where appropriate.

If you are below 18 years old:

• Please review this Notice with your parent or legal guardian and your authorized school representative;
• Do not provide personal data that is not required by the registration form; and
• Follow any parent, guardian, or school authorization process stated in the registration instructions.

A parent or legal guardian may exercise applicable privacy rights on behalf of a minor.

15. Your Rights as a Data Subject

Subject to applicable conditions and limitations under the Data Privacy Act of 2012, you may have the right to: Be Informed, Access Your Personal Data, Correct Inaccurate Information, Object to Processing, Withdraw Consent, Request Erasure or Blocking, Request Data Portability, Claim Damages, and File a Complaint with the National Privacy Commission.

RCMPDR may request reasonable information to verify your identity before acting on a privacy request. This is intended to prevent unauthorized access to another person’s records.

16. How to Exercise Your Rights or Raise a Privacy Concern

To request access, correction, deletion, blocking, withdrawal of consent, or other appropriate action concerning your personal data, contact:

Program, registration, or partnership inquiries that are not privacy-related may be sent to the RCMPDR IBM SkillsBuild Project Team (Email: rcmpdr.skillsbuild@gmail.com).

17. Changes to This Notice

RCMPDR may update this Notice when circumstances require. The latest version will be posted on the program website together with its effective date and version number. Where a change materially affects how identifiable personal data is processed, RCMPDR will provide an appropriate notice and, where required, obtain a new or updated consent.

18. Registration Form Acknowledgment

By submitting the registration form, you confirm that you have read and understood the RCMPDR x IBM SkillsBuild Program Data Privacy Notice. You understand that your registration information will be used to administer the program, associate you with your school or organization and sponsoring Rotary Club, match your registration with IBM/APC learner reports, monitor participation and course progress, and prepare authorized program reports.