Privacy Policy

This Privacy Policy explains how Verbilink Learning Hub (“we,” “us,” “our,” or “the Platform”) collects, uses, stores, shares, protects, and manages information provided by users (“User,” “you,” or “your”) in accordance with the **Japan Act on the Protection of Personal Information (APPI)** and the **Philippines Data Privacy Act of 2012 (DPA)**.

 

By accessing or using the Platform, you agree to the terms described in this Privacy Policy. If you do not agree, you must discontinue use and request account deletion.

1. Scope and Governing Law

 

This Privacy Policy applies to all personal data we collect from Users residing in or accessing the Platform from:

Japan, governed by the APPI;

The Philippines, governed by the DPA and its Implementing Rules and Regulations.

 

The applicable jurisdiction is based on your location or the location where processing occurs.

2. Information We Collect:

 

We may collect the following categories of information:

 

2.1 Personal Information Provided by Users

 

* Name, email address, phone number

* Username, password, profile details

* Language preferences

* Payment information (processed via third-party payment processors)

 

2.2 Automatically Collected Data

 

* IP address, browser type, device information

* Usage data, log files

* Cookie and tracking data

 

2.3 User-Generated Content

 

* Messages, uploaded files, learning materials, audio, video, or text shared on the Platform

 

Users are solely responsible for the content they submit.

 

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3. Purpose of Data Collection

 

We collect and process data for the following purposes:

 

* Account creation and management

* Service provision and improvement

* Communication with Users

* Security monitoring and fraud prevention

* Compliance with APPI, DPA, and other applicable laws

* Analytics, performance measurement, and personalization

 

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4. User Responsibility

 

Users are solely responsible for:

 

* The accuracy and legality of all data they submit

* Ensuring they have rights or permissions to share certain information

* Their own interactions and disclosures to other Users

 

The Platform does not verify User-submitted information and bears no liability for any consequences arising from it.

 

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5. Limitation of Liability

 

To the maximum extent permitted by **APPI**, **DPA**, and other applicable laws:

 

The Platform shall not be liable for:

 

* Unauthorized access, breaches, cyberattacks, or incidents beyond our reasonable control

* Data loss, deletion, corruption, or unauthorized modification

* User-to-user interactions or disclosures

* Third-party service failures

* Indirect, incidental, consequential, punitive, or special damages

 

This limitation does not apply to cases where the law prohibits such exclusions (e.g., willful misconduct or gross negligence).

 

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6. No Guarantee of Absolute Security**

 

While we apply organizational, physical, and technical measures required under APPI and DPA, we **do not guarantee absolute security** of electronic systems.

Users acknowledge the inherent risks of online data transmission and agree to use the Platform at their own risk.

 

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7. Cross-Border Data Transfers**

 

User Data may be transferred to and stored on servers located outside Japan or the Philippines.

 

We comply with:

 

* APPI requirements for ensuring foreign data recipients maintain equivalent protection standards

* DPA requirements for data-sharing agreements and contractual safeguards

 

By using the Platform, you consent to the international transfer of your information.

 

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8. Data Subject Rights**

 

8.1 Japan (APPI)**

 

Users may request:

 

* Disclosure of retained personal information

* Correction, addition, or deletion

* Suspension of use

* Suspension of third-party disclosure

 

Subject to APPI exceptions.

 

8.2 Philippines (DPA)**

 

Users may request:

 

* Access and correction

* Erasure or blocking

* Data portability

* To object to processing

* To file complaints with the NPC

 

We may require identity verification before processing any request.

 

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9. Data Retention**

 

We retain data only for as long as necessary to:

 

* Provide services

* Meet legal, regulatory, and operational requirements

* Resolve disputes or enforce agreements

 

Data no longer required will be securely deleted or anonymized.

Users may request deletion subject to legal retention obligations.

 

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10. Security Measures**

 

We implement safeguards in accordance with APPI and DPA, including:

 

* Encryption

* Secure authentication protocols

* Restricted employee access

* Regular audits and vulnerability assessments

* Use of accredited and secure cloud providers

 

No system is completely secure.

 

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11. Data Breach Notification**

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We will notify:

 

* The Personal Information Protection Commission (PPC), and

* Affected Users

  when required under APPI.

 

11.2 Philippines (DPA)**

 

We will notify:

 

* The National Privacy Commission (NPC), and

* Affected Users

  within 72 hours if the breach meets the harmful disclosure threshold.

 

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12. Third-Party Services**

 

We use third-party services such as:

 

* Payment processors

* Cloud hosting providers

* Analytics platforms

* Communication tools

 

We are not responsible for the privacy practices or security of third-party providers.

Your interactions with third parties are governed by their own privacy policies.

 

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13. Cookies and Tracking Technologies**

 

We may use cookies and analytics tools for:

 

* Service functionality

* Performance monitoring

* Personalization

* Usage analysis

 

You may disable cookies in your browser settings, but some features may not function properly.

 

Where required, we will obtain explicit consent before using non-essential cookies.

 

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14. Children’s Privacy**

 

We do not knowingly collect personal information from:

 

* Children under **13** in the Philippines

* Children under **15** in Japan (consent required from guardian)

 

If we learn that a child has provided data without proper consent, we will delete it promptly.

 

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15. User Assumption of Risk**

 

Users acknowledge that any information shared:

 

* In chats

* On profiles

* In uploaded content

* In public sections of the Platform

 

is disclosed voluntarily and at the User’s own risk.

We are not responsible for how other Users or third parties use or disclose such information.

 

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16. Indemnification**

 

Users agree to indemnify and hold harmless the Platform from any claims, liabilities, damages, fines, or expenses arising from:

 

* User’s actions or negligence

* User’s violation of this Privacy Policy

* User’s breach of APPI or DPA

* Any content User provides

 

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17. Changes to This Policy**

 

We may update this Privacy Policy from time to time.

Changes will be posted on this page with an updated “Last Updated” date.

Continued use of the Platform constitutes acceptance of the revised policy.

 

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18. Contact Information / Data Protection Officer**

 

End of Privacy Policy

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