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Website Privacy Policy


This policy shows what we will post in our company website.


1. Who We Are

Frontline Philippines Pty Ltd is the data processor and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).


Our email address is:


Our office address is Suite 81, Level 2, 66 Victor Crescent, Narre Warren VIC 3805, Australia.


We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy policy, please contact our Data Protection Officer or our Article 27 representative using the details set below.

Full Name of Legal Entity: Frontline Philippines Pty Ltd

Name of Data Protection Officer: Von Cyrus De Leon

Office Address: Suite 81, Level 2, 66 Victor Crescent, Narre Warren VIC 3805, Australia

Email address of Data Protection Officer:

Contact number: +63 2 8351 6062

Full Name of Legal Entity: XpertDPO Ltd

Name of Article 27 Representative: Stuart Anderson

Office Address: 20 Harcourt Street, Dublin 2, D02 H365, Ireland

Email of Article 27 Representative:

Contact numbers: Mobile +353 87 066 4008; Dublin   +353 1 678 8997; London +44 203 9955652; Wicklow +353 404 53906

2. Scope

This privacy policy provides you with details of how we collect and process your personal data.


All data subjects whose personal data is collected, in line with the requirements of the General Data Protection Regulation (GDPR).

3. Our Responsibilities

If you are our staff or a visitor to our website, we act as the ‘data controller’ of personal data. This means we determine how and why your data are processed.


If you are our Business Process Outsourcing client who uses our offshoring services, then we act as the 'Data Processor'.

4. Your Responsibilities

If you are our client, please also check the proposal it may contain further details on how we process your data.

If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.

5. How We Collect Data

We may collect data about you by providing the data directly to us (for example by filling in forms on our website or by sending us emails and correspondence by post or by speaking with us on the telephone and in virtual meetings). We may collect data from third parties who you authorize us to obtain the data from on your behalf (for example a government agency, financial institution).

We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as the Companies Registration Office and others.

6. Types of Data We Collect

    - Contact Details - Your name, address, telephone number, email address, etc.

    - Financial Information – Your bank account number, sort code, etc.

    - Data that Identifies You – Your IP address, location information about where you might be.

    - Data on how you use our website – your URL clickstreams (the path you take through our site), services               viewed, page response times, how long you stay on our page, what you do on those pages and how often         you visit our page.

7. Do We Collect Special Categories Data?

We do not collect any sensitive or special categories of Data about you. Special categories of data refer to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about convictions and offenses.


Where we are required to collect personal data by law, or under the terms of the proposal between us and you do not provide us with that date when requested, we may not be able to perform the agreement (for example, to continue to act for you). If you do not provide us with the requested date, we may not have to cease to act for you but if we do, we will notify you at the same time.


We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.


We may process your personal data without your knowledge or consent where this is required or permitted by law.


We do not carry out automated decision making or any type of automated profiling.

8. International Transfers

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal date, so European law has prohibited transfers of personal date outside of the EEA unless the transfer meets certain criteria.


Many of our third parties service providers are based outside the European Economic Area (EEA) so, their processing of your personal data will involve a transfer of data outside the EEA.


Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:


  • We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data share between Europe and the US.


If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.


Please email us at


If you want further information on the specific mechanism used by us when transferring your data out of the EEA.

9. Disclosure of Your Personal Data

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services including cloud-based services.           

  • Professional advisers including lawyers, accountants, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Risk management auditors and quality control companies.

  • The Revenue Commissioners, the Data Protection Commission, the Central Statistics Office, and other regulators and authorities based relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.


We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

10. Your Rights as a Data Subject

Under certain circumstances, you have rights under the data protection laws in relation   to your personal data. These include the right to:

  • Request access to your personal data

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

If you wish to exercise any of these rights set out above, please email us at

You may access your personal data anytime (or to exercise any to the other right). We may refuse to comply with your request if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the appointed governing body within your local jurisdiction. Please contact us first at If you do have a complaint so that we can try to resolve it for you.

11. How Secure Is the Data We Collect?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. How Long Do We Store Your Data?

We will only retain your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


In some circumstances you can ask us to delete your data.


In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for legal know-how, research or statistical purpose in which case we may use this information indefinitely without further notice to you.


We may change this privacy policy from time to time. You are encouraged to review this policy for any changes that may affect you. All changes are effective immediately upon notice and we will notify you by including in our site that says we have updated our privacy policy.

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