Project Sagwan

PixelTech Phils. Inc. ("PixelTech," "we," "us," or "our") is committed to protecting your personal data and upholding your right to privacy under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and guidelines issued by the National Privacy Commission (NPC). This Data Privacy Policy explains how we collect, use, process, store, disclose, and protect personal data obtained from users ("User," "you," or "your") accessing Sagwan—our specialized online review and diagnostic platform for Naval Architecture and Marine Engineering (BS NAME) licensure preparation—via our website, mobile interface, and web applications (collectively, the "Platform").

1. Business & Entity Details

Data Controller: PixelTech Phils. Inc.
Platform: Sagwan Online Review System
Official Address: Las Piñas City, Metro Manila, Philippines
Data Protection Officer (DPO) Contact: dpo@pixeltechph.com

2. Information We Collect

We collect personal information necessary to fulfill our service commitments, deliver personalized diagnostic evaluations, and manage institutional accounts.

A. Personal Information You Provide Directly

Identity & Account Data: Full name, gender, email address, personal contact details, account passwords, and profile picture (optional).
Academic & Professional Status: Enrolled Higher Education Institution (HEI), year of graduation and student identification number.
Payment Data: Transaction receipts, reference numbers, or billing metadata (note: bank credentials are processed directly by certified third-party payment gateways and are never stored on Sagwan servers).

B. Data Generated Through Platform Usage

Diagnostic & Examination Metrics: Diagnostic test scores, time-per-question metrics, subject mastery breakdowns, mock exam completion records, and review streak histories.
Technical & System Data: IP address, browser type, operating system, device identifiers, login timestamps, session durations, and error logs.
Anti-Cheating & Integrity Logs: Automated concurrent login logs, IP geolocation data, and device signature checks used to enforce single-user access rules.

3. Purpose of Data Processing

We process your personal data strictly for legitimate, lawful purposes linked to our core functionalities:

Educational Delivery & Analytics: Providing access to mock exam modules, tracking diagnostic performance, and displaying progress dashboards.
Institutional Reporting: Generating aggregated, anonymized, or specific academic performance reports for subscribing Higher Education Institutions (HEIs) to track student readiness.
Platform Security & Fraud Prevention: Detecting unauthorized account sharing, preventing content scraping, and ensuring system integrity.
User Support & Communications: Responding to technical support inquiries, pushing critical platform updates, and sending system notification alerts.
Legal & Regulatory Compliance: Fulfilling obligations under Philippine law, NPC directives, and valid legal orders.

4. Legal Basis for Processing

We process your personal data under the following legal bases pursuant to Section 12 of the Data Privacy Act of 2012:

Consent: When you explicitly agree to this policy upon account registration.
Contractual Necessity: Processing required to fulfill our obligations under our end-user or institutional agreements.
Legitimate Interest: To maintain platform security, optimize low-bandwidth systems for marine/sea-transit environments, and prevent intellectual property theft.

5. Disclosure and Sharing of Information

PixelTech does not sell, rent, or trade your personal data to third parties or advertising networks. We may share your information under the following limited conditions:

Subscribing HEIs and Educational Partners: If your account is tied to an institutional subscription (e.g., your university or college), designated faculty or administrators may access your academic performance and diagnostic progress metrics.
Authorized Service Providers: Trusted third-party vendors who assist in operating our infrastructure (such as cloud hosting services, SMS/email delivery providers, and payment processors) bound by strict Data Sharing Agreements (DSAs) and confidentiality obligations.
Legal Mandates: When required by law, subpoena, court order, or regulatory demands from government agencies (e.g., NPC, CHED, or PRC).

6. Data Protection & Security Measures

PixelTech implements organizational, physical, and technical security measures designed to safeguard your data against unauthorized access, alteration, disclosure, or destruction:

Encryption: Data in transit is encrypted using industry-standard Transport Layer Security (TLS/SSL), and sensitive data at rest is encrypted using AES-256 standards.
Access Control: System access is restricted strictly to authorized PixelTech personnel under role-based access protocols.
Security Audits: Regular vulnerability checks, security monitoring, and automated anomaly detection for unauthorized logins.

7. Retention and Disposal of Data

Retention Period: Your personal data is retained for as long as your account remains active or as needed to provide you access to review materials, satisfy institutional agreements, or fulfill legal obligations.
Data Anonymization: Upon account expiry or termination, performance data may be anonymized for longitudinal statistical analysis of board exam readiness.
Secure Disposal: When personal data is no longer required, it is securely deleted or overwritten in compliance with NPC guidelines.

8. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), you possess the following rights regarding your personal information:

Right to be Informed: The right to know how your data is being collected, used, and processed.
Right to Access: The right to request reasonable access to your personal data held by PixelTech.
Right to Rectification: The right to request corrections to inaccurate or outdated personal details.
Right to Erasure or Blocking: The right to suspend, withdraw, or order the removal of your personal data upon valid grounds.
Right to Object: The right to object to processing based on consent or legitimate interest.
Right to Data Portability: The right to obtain a copy of your personal data in an electronic, structured format.
Right to File a Complaint: The right to lodge a complaint with PixelTech's Data Protection Officer or directly with the National Privacy Commission (NPC) if you believe your privacy rights have been violated.

9. Cookies and Local Storage

Sagwan utilizes essential cookies and browser local storage mechanisms to keep you logged in, save your active exam state during unexpected internet drops, and optimize system load times. You may control cookie settings via your browser preferences, though disabling essential cookies may impact platform functionality.

10. Updates to This Privacy Policy

PixelTech reserves the right to update this Data Privacy Policy periodically to align with platform enhancements, legal mandates, or NPC circulars. Material revisions will be communicated via dashboard alerts on Sagwan or through your registered email address at least fifteen (15) days before taking effect.

11. Contact Our Data Protection Officer (DPO)

For any questions, privacy concerns, or requests to exercise your data subject rights, please contact our Data Protection Officer:

PixelTech Phils. Inc.
Attn: Data Protection Officer
Email: dpo@pixeltechph.com
Address: Las Piñas City, Metro Manila, Philippines