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Legal document

Privacy Policy

MARS INTELLIGENCE CORPORATION

Effective Date: 2026-09-11 | Last Updated: 2026-09-11

1. Who We Are

Mars Intelligence Corporation ("Mars", "we", "us" or "our") is a stock corporation duly organised and existing under the laws of the Republic of the Philippines, registered with the Securities and Exchange Commission ("SEC") under SEC Registration No. 2025060203943-00, with principal office at Penthouse, Marajo Tower, 312 26th Street corner 4th Avenue, Bonifacio Global City, Fort Bonifacio, Taguig City 1634, Philippines.

Mars engages in marketing activities and renders integrated marketing support services, including without limitation customer engagement and outreach through messaging, telephone and voice channels, digital advertising placement and campaign management, sales promotion, market research, and related data and analytics services, for and on behalf of persons, companies, organisations, brand owners and advertisers (each, a "Client").

We are committed to processing Personal Data fairly, lawfully and transparently, in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations (the "IRR"), and the issuances of the National Privacy Commission (the "NPC").

2. Scope of This Privacy Policy

This Privacy Policy describes how we collect, use, disclose, store, transfer and otherwise process Personal Data in connection with, including without limitation:

  • communications and interactions that we initiate, send, receive, place, route, manage or support through any channel, including without limitation Rich Communication Services ("RCS"), short messaging service ("SMS"), multimedia messaging service, over-the-top and in-application messaging, chat and chatbot, telephone and voice calls (whether placed or answered manually or by automated means, and including interactive voice response ("IVR"), automated or pre-recorded voice, voice broadcast, click-to-call, voice-over-internet-protocol, and voice or video calls made through messaging or over-the-top applications), video, electronic mail, push notification, and any other communication or engagement channel we may use from time to time (collectively, the "Engagement Channels");
  • marketing, promotional, advertising, survey, loyalty and customer-engagement campaigns, landing pages, forms and other marketing activities that we plan, place, deploy, operate, monitor, measure or optimise for ourselves or for a Client;
  • our website at http://www.marsyntel.com and any other website, page, form or microsite we operate (collectively, the "Website"); and
  • our dealings with business contacts, representatives of Clients, suppliers, service providers and other counterparties.

This Privacy Policy does not apply to the processing of Personal Data by a Client, by the owner or operator of any product, application or service referred to in our communications, by a mobile network operator, by a device, operating system or messaging application provider, or by any other third party acting under its own privacy policy. Where you interact with the product, application or service of any such party, its own privacy policy governs its processing of your Personal Data.

3. Definitions

For the purposes of this Privacy Policy:

  • "Personal Data" means, collectively, personal information, sensitive personal information and privileged information as those terms are defined under the DPA.
  • "Data Subject" means an individual whose Personal Data is processed.
  • "Processing" means any operation or set of operations performed upon Personal Data, including without limitation collection, recording, organisation, storage, updating, modification, retrieval, consultation, use, consolidation, blocking, erasure and destruction of data.
  • "Personal Information Controller" or "PIC" and "Personal Information Processor" or "PIP" have the meanings given to them under the DPA.

4. Our Role

Depending on the activity concerned, we act:

  • as a PIC, where we determine the purposes and means of the Processing — for example, in relation to our own business contacts, the Website, our own market research, and our own records of consent and opt-out preferences; and
  • as a PIP, where we process Personal Data on behalf of, and in accordance with the documented instructions of, a Client that acts as the PIC — for example, where a Client provides us with a contact list, or engages us to reach out to its own customers or users. In such case, the privacy policy of that Client also applies to the Processing, and we may refer your request to that Client for action.

Where we act as a PIP, we process Personal Data only for the purposes instructed by the relevant Client, and we do not use it for our own unrelated purposes.

5. Personal Data We Collect

The categories of Personal Data we may collect include without limitation:

  • Contact details and identifiers — name, mobile number, landline or other telephone number, electronic mail address, messaging identifier or handle, and, where you provide them, address and other contact details;
  • Communication and interaction data — the content of communications and replies you send through the Engagement Channels, communication status and delivery information (such as sent, delivered and, where made available by the channel, read status), keyword replies (including opt-out keywords), taps or clicks on suggested replies, suggested actions, cards, media, buttons or links, call detail records (including the date, time, duration, outcome and disposition of a call), IVR menu selections and keypad or voice inputs, and the date, time and frequency of such interactions;
  • Campaign and engagement data — impressions, clicks, views, conversions, form submissions and similar campaign performance data, including data made available to us by advertising platforms, publishers or measurement providers, whether in identifiable, pseudonymised or aggregated form;
  • Technical and device data — internet protocol address, device type and model, operating system, browser type, mobile network, Engagement Channel capability information (including whether your device and network support RCS), language and locale settings, cookie and similar identifiers, and system log data;
  • Preference and consent data — your consent, opt-in, opt-out, objection and communication preferences, and the records evidencing them, including suppression records;
  • Information you voluntarily provide — enquiries, requests, feedback, survey responses, complaints, expressions of interest, and any other information you choose to provide or disclose to us through the Engagement Channels, the Website or otherwise; and
  • Information from other sources — Personal Data lawfully provided or made available to us by a Client, by our service providers, from publicly available sources, or by other third parties, in each case where lawfully obtained.

We do not require you to disclose sensitive personal information through the Engagement Channels. Please do not provide to us, through the Engagement Channels, your government-issued identification numbers, bank account or payment card numbers, passwords, personal identification numbers, one-time passwords ("OTP"), health information, or any other sensitive personal information. Where any such information is nevertheless received by us, we will process it only to the extent necessary for the purpose for which it was submitted and in accordance with the DPA.

6. How We Reach Out to You, and Your Consent

We reach out to you through the Engagement Channels only where there is a lawful basis to do so, including without limitation where:

  • you have expressly consented to the marketing and promotional activities, or to receiving communications from the service providers engaged by it;
  • the Processing is necessary for the purposes of the legitimate interests pursued by us or by a Client, except where such interests are overridden by your fundamental rights and freedoms; or
  • any other lawful criterion for Processing under the DPA applies.

Where consent is required, it is obtained before the first solicitation, and records of consent are maintained. By interacting with us through the Engagement Channels or the Website, or by providing or making available to us any information in the course of such interaction, you hereby give your consent to, and authorise, our collection, Processing, storage, transfer and disclosure of any and all such information, and of any and all information relating to you that we lawfully obtain, for the purposes described in Section 7 and in accordance with this Privacy Policy and applicable law. Where the information you provide relates to another individual, you confirm that you are authorised to provide it to us for such purposes. You may withdraw your consent, or object to the Processing of your Personal Data for direct marketing purposes, at any time and at no cost to you, by the means described in Section 11. Withdrawing consent is as easy as giving it. Upon withdrawal or objection, we will cease reaching out to you for promotional purposes and will not continue to rely on legitimate interests to do so.

7. Purposes of Processing

We process Personal Data for the following purposes, including without limitation:

  • to plan, deploy, deliver, personalise, monitor, measure, report on and optimise marketing, promotional and advertising communications, calls and campaigns for ourselves and for our Clients;
  • to deliver service, transactional, account-related and other non-promotional communications that are requested by you or relevant to your relationship with a Client, including without limitation verification and authentication communications, application and account status notifications, schedule, payment and appointment reminders, service advisories and other notices, where we are instructed to do so;
  • to conduct conversational, voice and rich-media interactions, and to receive, acknowledge, assess and respond to your replies, enquiries, requests, feedback and complaints, and to provide customer support and follow-up;
  • to record, administer and honour your consent, opt-out and communication preferences, and to maintain suppression lists, including do-not-call and do-not-contact records;
  • to conduct market research, surveys, audience segmentation, analytics, modelling, reporting, reconciliation and performance measurement, including in pseudonymised, de-identified or aggregated form;
  • to monitor and assure the quality of our outreach and customer service, and to detect, investigate, prevent and address fraud, spam, abuse, impersonation, unauthorised use, security incidents and other unlawful or prohibited activity, and to protect our rights, property and safety and those of our Clients, our personnel and the public;
  • to operate, administer, maintain, secure, test and improve the Website, the Engagement Channels and our systems and processes;
  • to comply with applicable laws, rules and regulations, lawful orders, subpoenas and requests of competent authorities, and with the onboarding, registration, verification, brand and sender authentication, content and anti-spam requirements of mobile network operators, messaging and voice platform providers and other channel providers; and
  • to establish, exercise or defend legal claims, and for audit, accounting, tax, insurance and record-keeping purposes.

Where we intend to process your Personal Data for a purpose that is not compatible with those described above, we will provide you with a separate notice and, where required, obtain your consent.

8. Disclosure and Sharing of Personal Data

We may disclose or share Personal Data with the following categories of recipients, including without limitation:

  • the Client for whom the relevant campaign, communication or activity is undertaken, and its affiliates, appointed agents and service providers;
  • communication and technology service providers, including RCS aggregators and resellers, SMS, voice and email service providers, contact centre, dialler, IVR and telephony providers, customer-engagement and marketing automation platforms, cloud hosting, information technology and cybersecurity providers, and analytics providers;
  • mobile network operators, messaging and voice platform providers and the provider of the RCS platform, to the extent necessary to deliver, route, place, connect, verify, authenticate, support or audit communications, and to satisfy their registration, verification and anti-abuse requirements;
  • advertising platforms, publishers, media owners and agencies engaged in connection with the placement and measurement of campaigns;
  • our affiliates within our group of companies, including our shareholder and affiliates located outside the Philippines, for administration, consolidated reporting, audit, compliance and support purposes;
  • our professional advisers, auditors, insurers and banks, in each case subject to duties of confidentiality;
  • courts, tribunals, regulators, law enforcement agencies and other government authorities, where required or permitted by applicable law, including without limitation the SEC, the NPC and the Bureau of Internal Revenue; and
  • an actual or prospective acquirer, successor or assignee, in connection with a merger, consolidation, reorganisation, sale of assets or similar transaction, subject to appropriate confidentiality and data protection safeguards.

We do not sell your Personal Data.

Where we engage a PIP to process Personal Data on our behalf, we do so under a written agreement that provides for the matters required under the IRR, including the obligation to process Personal Data only upon our documented instructions, to implement appropriate security measures, to maintain confidentiality, and to delete or return the Personal Data upon the termination of the engagement.

9. Cross-Border Transfers

Some of the recipients described in Section 8, including certain of our affiliates and service providers, may be located outside the Republic of the Philippines. Where we transfer Personal Data outside the Philippines, we will comply with the applicable laws governing the Personal Data so transferred, and we take commercially reasonable steps to ensure that a comparable level of protection is afforded to it, including through commitments with the recipient as to purpose limitation, confidentiality, security and onward transfer.

10. Retention and Disposal

We retain Personal Data only for as long as necessary for the fulfilment of the purposes described in Section 7, or for such longer period as may be required or permitted by applicable law, a lawful order, a regulatory retention requirement, our contractual obligations to a Client, or the establishment, exercise or defence of legal claims. Records of your opt-out or objection are retained for as long as necessary to give continuing effect to your request.

Upon the expiry of the applicable retention period, Personal Data is securely disposed of, or is anonymised or aggregated in a manner that prevents further processing of identifiable information.

11. Your Rights as a Data Subject

Subject to the conditions, qualifications and exceptions provided under the DPA and the IRR, you have the right to be informed, the right to object, the right to access, the right to rectification, the right to erasure or blocking, the right to damages, and the right to data portability in respect of your Personal Data.

Opting out of promotional communications. You may stop receiving promotional communications at any time and at no cost by:

  • replying with the keyword STOP to any promotional communication sent to you through the Engagement Channels, or telling our representative during a call that you no longer wish to receive promotional communications;
  • using the opt-out reply, action or link provided within the communication, where available; or
  • contacting us using the details in Section 15.

Upon receipt of your opt-out request, we will acknowledge it and cease reaching out to you for promotional purposes, and we will record your request in our suppression list, including our do-not-call records. We may continue to deliver to you non-promotional service or transactional communications where this is permitted or required by applicable law, or where these are necessary in connection with an existing relationship between you and a Client.

Exercising other rights. To exercise your other rights, please contact our Data Protection Officer using the details in Section 15. We may require you to verify your identity and to provide sufficient particulars of your request. We will act on your request within a reasonable period and will inform you if we are unable to accede to it in whole or in part, together with the reasons therefor.

Complaints. If you believe that your rights under the DPA have been violated, you may lodge a complaint with us using the details in Section 15, and you may also file a complaint with the authority in accordance with its rules of procedure.

12. Security Measures

We implement commercially reasonable and appropriate organisational, physical and technical security measures intended to protect Personal Data against accidental or unlawful destruction, alteration and disclosure, and against any other unlawful Processing. These measures include without limitation the designation of a Data Protection Officer, role-based access controls and authentication, confidentiality undertakings and training for personnel, encryption or other protective measures for data in transit and, where appropriate, at rest, logging and monitoring, due diligence over service providers, and incident response, breach assessment and breach notification procedures.

While we endeavour to protect Personal Data, no method of transmission over the internet or over a mobile network, and no method of electronic storage, is completely secure. We therefore cannot guarantee absolute security.

13. Minors

Our campaigns and the Engagement Channels are intended for individuals who are at least eighteen (18) years of age. We do not knowingly collect Personal Data of a minor without the consent of the minor's parent or legal guardian. If we become aware that we have collected Personal Data of a minor without such consent, we will take steps to delete it.

14. Fraud and Impersonation Notice

We will never ask you, through the Engagement Channels, for your password, OTP, personal identification number, full payment card number or card verification value, and we will never ask you to remit money to a personal account in exchange for the release of a loan, a prize, a refund or any service. If you receive a communication that purports to come from us or from a Client and appears to be fraudulent, please do not respond to it and report it to us using the details in Section 15.

15. How to Contact Us

For any question, request, or complaint relating to this Privacy Policy or to our Processing of your Personal Data, you may contact:

Data Protection Officer
Mars Intelligence Corporation
Penthouse, Marajo Tower, 312 26th Street corner 4th Avenue, Bonifacio Global City, Fort Bonifacio, Taguig City 1634, Philippines
Electronic mail: soporte@marsyntel.com
Telephone: +639171539259

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, in the Engagement Channels, in the services we provide, or in applicable legal or regulatory requirements. The current version is published on the Website and takes effect on the Effective Date stated above. Where a change materially affects the Processing of your Personal Data, we will provide notice by such means as are appropriate in the circumstances and, where required by applicable law, obtain your consent.

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