Privacy Notice

Last updated: [EFFECTIVE DATE] | Version: 1.2 (adds the AI job helper and AI photo suggestions)

This notice explains how [LEGAL ENTITY NAME] ("Jaypees", "we") handles your personal data when you use our apps and website. We follow the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and issuances of the National Privacy Commission (NPC).

Personal Information Controller: [LEGAL ENTITY NAME], [REGISTERED ADDRESS] Data Protection Officer (DPO): [DPO NAME], [DPO EMAIL e.g., dpo@jaypees.ph], [DPO PHONE] NPC registration: [NPC REGISTRATION / CERTIFICATE NO. - or "registration in process"]

1. Who this applies to

Customers, Workers and applicants, visitors to our website, and people who contact us. You must be 18 or older to use Jaypees. We do not knowingly collect data from minors. If you believe a minor has an account, tell our DPO and we will delete it.

2. What we collect

Under the DPA, government-issued IDs, and information about offences or proceedings (such as a police or NBI clearance) are sensitive personal information. We process them only with your consent or as otherwise allowed by Section 13 of the DPA.

3. Why we use your data and our legal basis

We do not sell your personal data. We do not use KYC documents for marketing or analytics.

4. How KYC verification works

• Before uploading, you must give consent in the app. We record the consent and version.
• Review is by our authorised verification staff. We use automated checks (for example expiry, same ID type used twice, duplicate ID detection) to help staff. Approval or rejection is a human decision; no Worker is approved or rejected by automated processing alone.
• AI-assisted pre-check. [If enabled,] we send images of your IDs, police clearance (or NBI clearance) and selfie, but never your resume or biodata, to an automated assistant (an AI model) run by a third-party vendor, [AI VENDOR NAME], acting as our processor. It reads the visible text and points out problems such as blur, glare, edits or mismatched names, and returns a suggestion to our staff. We send only the images (resized, with photo metadata removed), not your phone number or account details. We store the suggestion encrypted, keep only the last 4 characters of any ID number from it, and delete it with your documents. The suggestion does not decide anything: a person always reviews your application. You may object to this step at any time by contacting our DPO, and a person will review your documents without it. [CONFIRM final design and the vendor's retention and training terms.]
• Files are stored privately and are not publicly accessible. Staff access is limited to authorised personnel and is logged.
• The police clearance (or the NBI clearance, if that is what you upload) must not be older than 6 months at submission. A resume or biodata has no expiry. Other IDs must be valid (unexpired).
• Customers never see your ID, only a "Verified" badge and your public profile.
• See the KYC Policy for more detail.

4A. The AI job helper (customers)

The AI job helper is optional and is off unless we switch it on. Booking works exactly the same without it. When you use it, it suggests a service, how long the job may take, a rough price range and a clearer description. It only suggests. You check and change everything before you book, and it never decides anything about you.

• Agreeing first. Before first use the app shows what is sent and who receives it, in English and Filipino. The box is not ticked for you, and you must tick it. Photos need a second, separate agreement the first time you add a photo. You can say no to photos and still use the text helper.
• What is sent. The text you type, with phone numbers, emails, links and house or street details removed on our server first (this removal is a best effort, so please do not type personal details), your answers to up to three follow-up questions, and the photos you add (up to 3). We do not send your name, phone number, email, account or booking details, or your location.
• Photos. We remove the location and camera information from each photo on our server and shrink it before it is sent. We do not store the photos. Please do not photograph people, faces, IDs, papers or screens with personal information. The AI service is asked to check for these, and if it finds one we ask you to retake the photo and do not use it. This check is not perfect: a photo like that can still reach the AI service before it is flagged, which is why photos have their own agreement and why you should only photograph the problem.
• Who receives it. A third-party AI service, [AI VENDOR NAME], acting as our processor, only to produce the suggestion, [with no keeping and no model training] [CONFIRM the vendor's retention and training terms]. It may process data outside the Philippines (see section 6).
• What we keep. Not your text, not the reply, not the photos. Only a record of your agreement (which version, when, and the network address of your device, for security) and a usage record per try (time, which service was suggested, counts and cost, number of photos). Usage records are deleted after [90 days]. Agreement and usage records are deleted when you delete your account, and are included if you ask for a copy of your data.
• Withdrawing. In the app, open Settings, then AI job helper. You can see which version you agreed to and when, and withdraw the text agreement and the photo agreement separately, at any time. Withdrawing stops any further sending right away. Withdrawing the text agreement also stops photo use, because photos need both.
• No automated decisions. The helper fills in a form that you approve. Price ranges are estimates from rates set by workers on Jaypees. They are not a quote, and the exact price is shown before you pay.

5. Who we share data with

• Other users: a Customer sees a Worker's public profile, ratings and, for a confirmed booking, name and relevant contact/chat. A Worker sees the Customer's name, job address and job details for an accepted booking. Phone numbers are not shown to the other party unless [CONFIRM].
• Service providers (processors) under written agreements: cloud hosting and storage [PROVIDER, REGION]; AI document pre-check provider [AI VENDOR NAME] (images of KYC documents only, for the automated pre-check described in section 4, [no retention and no model training] [CONFIRM]); AI job helper provider [AI VENDOR NAME] (the text and photos a customer chooses to send, as described in section 4A, [no retention and no model training] [CONFIRM]); HitPay (payments); SMS/OTP provider [PROVIDER]; push notification services (Apple, Google/Expo); email delivery [PROVIDER]; analytics [PROVIDER, only with consent]; maps [PROVIDER].
• Government and law enforcement: when required by law, court order or valid request, or to protect rights and safety.
• Business transfer: if we merge or are acquired, your data may transfer subject to this notice.

HitPay acts as an independent controller for the payment transaction data it processes under its own privacy policy.

6. Overseas processing

Some providers may store or process data outside the Philippines, for example [COUNTRY/REGION, e.g., Singapore]. Under the DPA, we remain accountable for personal data transferred to processors abroad and use contracts and safeguards to ensure comparable protection. [CONFIRM actual hosting region; prefer Philippines or ASEAN region for KYC files.]

AI pre-check provider. [If enabled,] the images of KYC documents are sent for automated analysis to [AI VENDOR NAME], whose servers may be located outside the Philippines, for example in [COUNTRY/REGION, e.g., the United States]. The images travel over encrypted connections, are used only to return the analysis, and are not kept by the vendor beyond [NO RETENTION / MAX DAYS] [CONFIRM contract]. We rely on a written data processing agreement with comparable-protection terms (DPA Sec. 21; NPC guidance on outsourcing and cross-border sharing) and on your informed consent given in the app. [LAWYER: confirm the transfer mechanism, whether a data sharing/outsourcing agreement and an update of our NPC registration are needed, and the vendor's sub-processors.]

AI job helper provider. [If enabled,] the text and photos you choose to send are processed by [AI VENDOR NAME], possibly outside the Philippines, for example in [COUNTRY/REGION]. The same safeguards as above apply: encrypted connections, a written processing agreement, use only to return the suggestion, and your separate informed agreement in the app (photos have their own). [LAWYER: confirm the transfer mechanism and the vendor's retention terms, and whether sending a photo that turns out to show a person or document, before the AI service flags it, is acceptable under the photo agreement or needs an on-server check first.]

7. How long we keep data

We keep data only as long as needed for the stated purpose, and then delete or anonymise it. These periods are our current plan and will be confirmed with legal counsel.

If a legal hold, complaint or investigation is ongoing, we keep relevant data until it ends.

8. How we protect data

We apply organisational, physical and technical measures required by the DPA and NPC Circulars, including:

• Encryption in transit (TLS) and encryption at rest for databases and file storage; sensitive fields encrypted.
• Private, non-public file storage for KYC documents, accessed only through authenticated, audit-logged staff endpoints.
• Role-based access control and least privilege; admin accounts protected by strong passwords [and two-factor authentication].
• Short-lived access tokens, OTP rate limiting, and monitoring for abuse.
• Webhook signature verification for payment events.
• Staff confidentiality undertakings and privacy training; vendor due diligence.
• Regular backups and a documented incident response plan; periodic security testing [CONFIRM schedule].

No system is perfectly secure. Please protect your phone and never share OTP codes.

9. Data breaches

If a personal data breach occurs that is likely to give rise to a real risk of serious harm, we will notify the National Privacy Commission and affected individuals within 72 hours of knowledge or reasonable belief that the breach occurred, as required by NPC Circular 16-03 [CONFIRM current circular], and describe what happened and what you can do.

10. Your rights as a data subject

Under the DPA you have the right to:

1. Be informed about how your data is processed.
2. Access a copy of your personal data.
3. Object to processing, including direct marketing, profiling or automated decisions, and to withdraw consent. We make no decision solely by automated processing: the AI-assisted KYC pre-check only suggests, and a person decides, and the AI job helper only fills in a form that you approve. You can object to the AI step in particular by contacting our DPO, and you can withdraw your agreement to the AI job helper (text and photos separately) in Settings in the app.
4. Rectify inaccurate or incomplete data.
5. Erase or block data that is unlawfully held, no longer necessary, or where you withdraw consent (subject to legal retention).
6. Data portability of your data in a commonly used electronic format.
7. Damages if you suffer harm from inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of data.
8. Lodge a complaint with the NPC (www.privacy.gov.ph).

To exercise a right, email our DPO at [DPO EMAIL] or use Settings in the app. We will respond within [15] days [CONFIRM], and may need to verify your identity. You can also delete your account in the app; we will delete or anonymise your data except for what we must keep under Section 7.

Withdrawing consent for KYC processing means a Worker can no longer be listed.

11. Cookies and tracking

Our website uses cookies as described in the Cookie Policy. Non-essential cookies are used only if you opt in.

12. Children

Jaypees is for adults (18+). We do not knowingly allow minors to register.

13. Changes

We will post updates here and notify you in the app or by SMS/email for material changes. The version and date are shown at the top.

14. Contact and complaints

Questions or requests: DPO at [DPO EMAIL], [DPO ADDRESS]. If we cannot resolve your concern you may contact the National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City [CONFIRM current address], www.privacy.gov.ph.

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Drafting notes for the founder and lawyer (remove before publishing)

• NPC registration: Registration of data processing systems is required for entities with 250+ employees, or processing sensitive personal information of 1,000+ individuals, or where processing is likely to pose risk to rights and freedoms. Jaypees will process sensitive personal information (IDs, police clearances, resumes) at scale; plan to register and appoint a DPO from day one. [CONFIRM thresholds under NPC Circular 2022-04.]
• Perform and keep a Privacy Impact Assessment for the KYC flow.
• Ensure a data sharing / outsourcing agreement with each processor (HitPay, cloud, SMS).
• Decide whether to retain clearance images at all after verification. Retaining less is the safest design.
• Consent for sensitive data must be specific, informed and evidenced; the app records version-stamped consent (current version 2026-10-v2, which discloses the AI-assisted pre-check; workers not yet approved must accept it before uploading).
• AI job helper (customer text and photos): off by default; do not switch it on in production until counsel and the DPO have approved the vendor terms (no training, retention, region), the Privacy Impact Assessment addendum and the final wording of the in-app terms and the separate photo agreement (current versions 2026-10-h3 and 2026-10-p1; the app shows a DRAFT notice while they are placeholders). Open legal question: a photo showing a person or document reaches the vendor before the model flags it; decide whether that is acceptable under the photo agreement or an on-server detector is required first. Data held: agreement records and usage counts only, deleted with the account and included in the data export.
• AI pre-check: do not enable it in production until the vendor agreement, the cross-border/outsourcing analysis, the Privacy Impact Assessment addendum and the objection process are done (ADR 0012). It is OFF by default.