Privacy Statement – Shareholder

Privacy Statement for shareholders

We value your data

We value the privacy of every individual shareholder of Meralco and their authorized representatives as well as the officers, employees, attorneys-in-fact, trustees, and authorized representatives of juridical entities that own Meralco shares. We make sure that copies of personal data that we either receive directly from our shareholders through subscription agreements or sourced from regulatory disclosures are maintained in secure storage spaces, whether physical or electronic. Whenever we are required by law to disclose information about our shareholders in reportorial requirements, in view of Meralco’s capacity as a publicly listed company, we only share information to government agencies and the general public that are specifically stated in the applicable rules and regulations.

Collecting your personal data

We collect your personal data in the course of, or incidental to the conduct of, our business with you. This data includes any other information that you voluntarily provide for a legitimate purpose declared at the point of collection, as well as information about you that we received from third parties and other sources where the disclosure was subject to a consent that you gave separately, as the result of a legal requirement, or any legitimate purpose made known to you.

Transparency in processing. Whenever we collect personal data, we provide just-in-time privacy notices and consent forms, when applicable, at the point of collection. 

Data minimization. The data we collect is only as much as is relevant and necessary to meet our processing purpose. We collect this personal data in the course of or incidental to our business with you. 

The data we collect. Generally, we collect the following information:

1. Information you submit to us when you become a shareholder of or while being a shareholder of MERALCO like your name, address, contact details, marital status, government-issued identification information, bank account information, and if applicable, details of your authorized representative and heir/s.
2. Information provided to us by your broker or by the Company’s stock transfer agent.

Purpose of Processing 

We store, process, and analyze the collected personal data for legitimate purposes related to, or incidental to, our business operations, including maintaining safety and security within the company premises.

Specifically, we may store, process, and analyze your personal data for the following and any other legitimate purposes related to the fulfillment thereof:

1. To manage investor relations. We process your personal data to maintain your account and our relationship, to administer the shareholder register, to facilitate payment of your dividend or any other amounts related to your shareholdings, to coordinate with your broker or our stock transfer agent for your concerns, and to comply with legal or disclosure requirements.
2. To improve our stakeholder engagement. We process your data to facilitate communications with you, including responding to your queries and requests, sending notices of general meetings, annual reports, and shareholder circulars to you, registering shareholders at general meetings and shareholders’ events including without limitation to verification of your identity and/or your proxy.

How do we process your personal data

1. Data Subject – Shareholders and their authorized representatives
2. As needed / as applicable
3. When applicable, data sharing or outsourced processes are covered by DSA, NDA, and/or OAs

Note: Privacy Notice is process specific while the Privacy Statement is a public commitment to data privacy

Read the diagram as text

The diagram follows the data subject, Meralco, its subsidiary and third parties through the personal-data lifecycle.

1. Collect. Meralco publishes the Privacy Statement and prepares the Privacy Notice and Consent/Acknowledgment Form. You read the privacy notice, statement, notice terms and conditions, and provide consent if you agree (as needed / as applicable). You provide personal information through forms, purchasing of stocks Meralco receives the accomplished forms.
2. Store. Meralco properly secures and stores the personal information.
3. Use. Meralco carries out the following processes in the order shown:
   1. Manage Investor relationship
   2. Stakeholder Engagement
4. Transfer.
   • Government may request personal data for audit, examination, or investigation (as needed / as applicable). Meralco provides information.
   The provision of information is subject to note 3 above.
5. Dispose. Meralco conducts the retention and disposal procedure. The diagram routes the final use process and the provision of information to this procedure, then ends.

Sharing your personal data 

Unless you provide specific consent or in instances allowed under law, we do not share your personal data with our business partners or other third parties for their own commercial purposes or benefit. 

Additionally, we do not use your personal data to enable third-party targeted advertisements that are unrelated to our business. 

When data is shared, especially across borders and jurisdictions, we ensure your data is protected through appropriate Data Sharing Agreements. 

In the processing of your personal information, we may have to disclose your data to parties acting as personal information processors, which may fall across these broad categories:

• Authorized Representatives and Consultants. We ensure that our authorized representatives and consultants adhere to the same standards as our employees and trainees, and require them to commit to observing the company’s privacy policies. We require our Authorized Representatives and Consultants to sign a Non-Disclosure Agreement (NDA), to ensure that they process your data confidentially in a manner consistent with the purpose of their employment or engagement. 
• Contractors and Business Partners, including Auditors. We require our contractors, subsidiaries, and business partners to secure and keep your data confidential through appropriate contractual and operational controls. We do not allow our contractors, subsidiaries, and business partners acting as personal information processors to disclose or share your data with others or use it for their own purposes. We take punitive or legal action in cases of proven misconduct. 

In the processing of your personal information, such personal information may nonetheless be disclosed when legally required or when necessary to complete our commitment to provide services to you. 

These entities to whom your personal data may be disclosed include:

• Government entities. Your information may also be disclosed to government entities pursuant to and in compliance with applicable laws and regulations, subpoena or court order.

Keeping your data secure 

We are committed to ensuring the integrity, confidentiality, availability, and security of your information. We implement reasonable organizational, physical, and technical security measures in collecting, processing, transmitting, storing, and disposing your personal data such as using secure servers, firewalls and security controls and ensuring regular conduct of audit and testing of our security protocols. We only store your personal data in Meralco-owned and/or controlled data storage solutions.

For an enhanced online experience, our services are available through compatible devices, such as laptops, PCs, tablets, and mobile phones. For your added security, we recommend that you install anti-virus software on any such device before accessing the internet.

You are responsible for the security of your information once it reaches you or your representative in any medium, including but not limited to written correspondences, bills, emails, system applications, and on-line accounts. 

You should take appropriate measures to ensure that any medium or device you use to monitor or manage your account is secure and not accessible to anyone without permission. 

Retaining your personal data 

We keep your personal data only for as long as necessary to fulfill the declared, specified, and legitimate purposes outlined above, or until the processing relevant to those purposes has been completed or terminated. We may also retain your data for the establishment, exercise, or defense of legal claims, or for other business purposes that align with standards established or approved by regulatory agencies governing Meralco.

For further information on our retention rules for documents with personal data, you may refer to our DP FAQ 2021-01 Retention of Documents Containing Personal Data .

Thereafter, your personal data shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.

Your data subject rights 

If you wish to request a copy of your personal data, or have it corrected or deleted, or to exercise your rights as data subject, you may reach out to us through our Data Privacy Office (DPO). Meralco DPO will promptly respond to your request or questions and also review any feedback that you may have about our Privacy Statement. 

We uphold your right to be informed whenever we provide a link to or a copy of this Statement prior to collecting your personal data or as soon as reasonably practicable after collection. In processing your data for the specific purposes we discussed in this Statement and those that may be related to such purposes, we shall endeavor to prepare privacy notices that remind you how we collect, use, disclose, and process your personal data in the manner described in this Statement, including our procedures relating to cookies, IP addresses and log files. As to any other purpose that you may not find or cannot infer from this Statement, we shall take all reasonable efforts to obtain your permission through a separate consent form that may either require your signature or contain a button that you could click as proof of your consent. 

About this Statement 

From time to time, we may update this Statement to comply with applicable laws, rules, and regulations; to reflect any changes to the foregoing; to align with industry practices; or for other legitimate purposes. 

You may view past versions of the Statement below.