First Metro Asset Management, Inc. (FAMI) and its subsidiaries, collectively referred to as “FAMI”, “The Company”, “We”, “Us” or “Our”, is committed in safeguarding the privacy of your personal data.
We take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of our users throughout their visiting experience. This website and its terms and conditions based on the existing requirements of R.A. 9160 or the Anti-Money Laundering Act of 2001, Data Privacy Act of 2012, their respective Implementing Rules and Regulations and all other applicable laws and regulatory requirements. It shall likewise be regularly updated to reflect statutory and regulatory amendments. By using FAMI’s website you agree with the Company’s terms and conditions and policies.
Collection and Processing of Personal Data
To carry the Company’s business and to continue to provide financial products and services to you consistent with the statutory and regulatory requirements, FAMI may collect and process certain type of data from you. In return, these personal information is used to better provide you with the required financial products and services.
The personal data that FAMI may collect and process include but not limited to the following:
- Full name;
- Date of birth;
- Residential address;
- Contact information, including valid telephone and mobile number and valid postal and electronic mail (e-mail) address;
- Proof of identification (government issued identification cards or document) identity card, passport, driver’s license, etc.;
- Profession, job, occupation, business or trade;
- Personal documents such as banking information, constitutional information, organizational or incorporation documents, list of investors or stockholders, business;
- Financial and credit position, status or background
- Latest account and financial information (including source of funds);
- Latest proof of postal and/or business address;
The collection and processing of your personal information shall be used solely for lawful and business purposes, including without limitation, to process your account opening with us, address your complaints, inquiries or requests and to improve the products and services we provide you with. We may also send you a text message or e-mail to your verified mobile number or e-mail address, respectively, containing newsletter, press release, promotions and special offers as part of our marketing communication and to fulfill or comply with statutory and regulatory requirements (AMLA, Foreign Account Tax Compliance or FATCA, etc.).
Use or Disclosure of Personal Data
FAMI either currently uses, or may in the future use your personal data for any purpose prohibited by law. The information provided are therefore used for:
- Account opening and other transactions, operations relating to fund account, establishing or revising sales load and closing fund;
- Logging in your FAMI portal to view the progress of your fund investment;
- Daily operation or provision of financial products and services to you, managing or carrying out any of your transactions, requests or queries in connection with your contract with the Company; transaction reporting; enforcement of our agreement with you;
- Providing (by post, email or SMS) marketing, advertising and promotion information, materials or documents related to FAMI business offerings;
- Responding to queries and requests;
- Implementing internal credit, risk and control, management, administrative, operational, compliance functions/programs/policies;
- Complying with applicable legal or regulatory requirements within the Philippines;
- Enhancing or upgrading the Company’s system infrastructure, operational, technical and other internal systems and processes maintained by or on behalf of the Company;
- Resolving problems in regards to client account and fund investment;
- Managing client relationship; creating better financial products or services to meet client needs.
FAMI may share your personal information with our business units, and strategic partners and, only to an extent as applicable, to third party service providers, to accomplish the purposes for which it was originally collected.
With your consent we may disclose your information to the following categories of parties;
- Our parent company, subsidiaries, holding companies, associated companies, or affiliates of, or similar relationships;
- To any person or company who is acting as an agent or representative for or on behalf of FAMI, or with FAMI, in respect for the purpose as mentioned and covered by a data sharing agreement;
- To internal and external auditors, consultants, accountants, lawyers or other financial or professional advisers; and/or
- To companies or organizations, including third party service providers and their affiliates we partnered to process the products and/or services you applied, subscribed and/or requested for.
However, even without the consent of data subject, processing shall be done in the following circumstances:
- Personal data is needed in pursuant to a valid or lawful subpoena or order of a court of jurisdiction or government institutions or agencies;
- Processing are for obvious purposes, such as when it is necessary for the performance of or in relation to a contract of service to which the data subject is a party, or when necessary or desirable in the context of an employer-employee relationship between the collector and the data subject; or
- When the processing is being done pursuant to a legal obligation.
FAMI will not use, disclose or process personal data for purposes which are not stated above or for which the consent of the data subject have not been obtained.
Consent to Collection and Processing
Protection of Your Personal Data
We take serious precaution when it comes to the personal information you submit and provide through our official website, both online and offline. Our website uses encryption technology, such as Secure Sockets Layer (SSL), to protect the information you provide or transmit using our website facility.
That being said, we would like you to understand that we cannot absolutely guarantee the security or confidentiality of electronic transmission using the internet.
Nevertheless, as our lifetime commitment to protect and respect your personal data privacy, FAMI will, through appropriate management and strict application of criteria and controls implement the following;
- Observe fully the conditions regarding the fair and lawful processing of personal information;
- Fulfill its legal obligation to inform the clients of the nature, purpose and extent of processing of his/her personal data;
- Process appropriate personal information and only to the extent that it is necessary for the declared and specified purpose for which these were collected;
- Ensure the quality of information used;
- Ensure that personal data is not retained longer than necessary;
- Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include the following rights:
- To be informed that processing is being undertaken;
- To object to the processing of personal information;
- To reasonable access of one’s personal information;
- To rectify any wrong information;
- To erase or block one’s personal information; and
- To be indemnified for any damages resulting from the improper handling and processing of personal information.
- Implement reasonable and appropriate organizational, physical and technical security measures to safeguard personal information;
- Establish clear procedures for responding to requests for information.
Correcting and Updating Your Personal Data
It is with the Company’s utmost initiative to ensure that all data collected is current and accurate. For any missing information or requirement, FAMI may contact you to complete the details you submitted before proceeding in processing your application or request.
As soon as there is/will be changes on your information, especially your contact number and email address, please do not hesitate to inform FAMI.
You may send an email request to email@example.com or contact FAMI through their hotline (632) 891-2860 to 65.
FAMI shall require existing customers/investors to update their information as required in FAMI’s Account Opening Form and submit additional identification and supporting documents, if necessary, at least once every three (3) years.
Record Keeping and Retention of Your Personal Data
To ensure that all customer identification records are maintained and safely stored as long as the account exists all transaction documents shall be maintained and safely stored for a period of five (5) years. Account opening forms, account files, business correspondence and other customer identification records and supporting documents shall be kept for five (5) years after the accounts are closed.
However, records relating to any ongoing lawful investigations or transactions that have been the subject of a lawful disclosure shall be retained beyond the specified retention period until it is confirmed that the case or investigation has been closed.
Depending on the classification of the client’s account, follow the record keeping instruction as mandated below:
- Closed Accounts
- Customer Information Sheets, account files, business correspondence and other customer identification records shall be kept for five (5) years after the accounts are closed.
- The Sales and Marketing Group and Operations Department shall require existing customers/investors to update their Account Opening Form and submit additional identification documents, if necessary, at least once every three (3) years.
- Reassessment and review of existing accounts/customers for possible change in the risk rating shall likewise be performed every three (3) years.
In order for us to fully serve you and improve our financial products and services, we have engaged with third-party service providers to analyze the web traffic data whenever someone visits our website.
These information are analyzed and utilized as part of continuous and constant improvement in the performance of the FAMI website. For advertising purposes, FAMI may create a general summary of the website traffic data collected to represent the audience the site is able to reach.
Information gathered includes;
- Your IP Address
- The pages, content and links you viewed and/or clicked within our site
- The site path you took from start to end of the session
- The technology and operating system you used to access our site
- The referral URL or website through which you accessed our site
- The search terms you entered
- The date and time you visited our site
Cookies are small data files that contain information and can later be read by the Company to facilitate access, visitorship and experience of people who access the FAMI website. A cookie may also convey information to us about how you use our website from pages viewed, links clicked, IP address, length of session, etc. Generally, cookies can be removed by setting and following instructions provided in any Internet browser’s settings.