1. Personal Information Controller
The Personal Information Controller (PIC) responsible for all personal data collected through this website and its associated forms is:
Brian Jay Loria acts as the sole Personal Information Controller for this website. Insurance-related data may be co-processed with FWD Life Insurance Corporation (Philippines) as described in Section 6.
2. Personal Data We Collect
We collect only the personal data necessary to respond to your inquiry and deliver our financial planning services. We do not collect sensitive personal data as defined under RA 10173 unless expressly required for regulatory compliance.
From inquiry & review forms
- Full name (first and last)
- Email address
- Mobile phone number
- Healthcare profession or role
- Current insurance situation (self-reported)
- Financial goals or concerns (self-disclosed, free text)
Automatically when you visit this website
- IP address and approximate geographic location (country/region only)
- Browser type, operating system, and device type
- Pages visited and time spent on the website
- Referral source (how you arrived at the website)
3. Purpose of Data Collection
Your personal data is collected and processed solely for the following specific, declared purposes:
- To respond to your financial review or inquiry request — Brian will use your contact details and submitted information to send you a personalized response within 24 hours.
- To schedule and conduct consultations — Your contact details are used to confirm, reschedule, or follow up on booked sessions.
- To provide financial planning services — Information you share about your financial situation is used solely to prepare recommendations relevant to your needs.
- To comply with FWD Philippines regulatory requirements — When a formal financial plan or insurance application is initiated, data may be processed per Insurance Commission of the Philippines requirements.
- To improve website performance — Anonymized, aggregated analytics data is used to understand how visitors interact with the website.
- To send relevant educational content — Only where you have given explicit, separate consent and can unsubscribe at any time.
We do not use your data for automated decision-making, profiling, or any purpose not listed above without your prior consent.
4. Legal Basis for Processing
Under RA 10173 and its Implementing Rules and Regulations, processing of your personal data is conducted on the following lawful bases:
- Consent — You provide explicit, informed consent via the checkbox on our inquiry form before submitting any personal data.
- Contractual necessity — Processing is necessary to respond to your inquiry and provide the financial planning services you have requested.
- Legal obligation — Processing may be required to comply with the Insurance Commission of the Philippines, Anti-Money Laundering Act (RA 9160 as amended), and other applicable laws.
- Legitimate interests — Limited analytics processing to improve website performance, where such interests are not overridden by your data protection rights.
5. Data Retention
Your personal data is retained only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable Philippine law.
| Data Type | Retention Period |
|---|---|
| Inquiry with no follow-up | 12 months from submission, then securely deleted |
| Active client / financial planning relationship | Duration of relationship + 5 years after conclusion |
| Regulatory compliance records | As mandated by applicable law (up to 10 years) |
| Website analytics data | Aggregated and anonymized; up to 24 months |
At the end of the applicable retention period, your data will be securely disposed of in a manner that prevents unauthorized recovery or reconstruction.
6. Data Sharing & Third Parties
Your personal data will not be sold, rented, or traded to any third party for marketing purposes. Data may be shared only in the following limited circumstances:
- FWD Life Insurance Corporation (Philippines) — When a formal insurance application is initiated, required personal information is shared with FWD as the licensed underwriter, governed by FWD's own Privacy Policy and Insurance Commission requirements.
- Regulatory authorities — We may disclose data to the National Privacy Commission (NPC), Insurance Commission, Anti-Money Laundering Council, or other competent authorities when required by valid law or legal process.
- Technology service providers — Trusted platforms (e.g., email, website hosting, scheduling tools) may process data on our behalf as Personal Information Processors (PIPs), bound by data processing agreements consistent with RA 10173.
We do not transfer personal data outside the Philippines without ensuring protections equivalent to RA 10173 standards.
7. Security Measures
We implement reasonable organizational, physical, and technical security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:
- HTTPS encryption for all data transmitted through this website
- Access controls limiting data access to authorized personnel only
- Regular review of data handling practices and access logs
- Use of reputable, security-certified third-party platforms for data storage and communication
- Secure disposal of data upon expiry of retention periods
8. Your Rights as a Data Subject
Under RA 10173 and its IRR, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected]. We will respond within 15 working days as required by the NPC.
National Privacy Commission of the Philippines
For complaints not resolved directly with us, you may file a complaint at
www.privacy.gov.ph
or call the NPC hotline. The NPC is the independent body authorized to administer and
implement the Data Privacy Act and to monitor and ensure compliance with international
standards for data protection.
9. Cookies & Analytics
This website may use cookies and similar tracking technologies to enhance your browsing experience and collect aggregated analytics data.
- Essential cookies — Required for the website to function correctly (session management, form security). Cannot be disabled without affecting site functionality.
- Analytics cookies — Used to understand how visitors interact with the website (page views, session duration). Data is anonymized and aggregated — no individual user is identified.
- Marketing/tracking cookies — May be set by third-party platforms (e.g., Facebook Pixel) if advertising campaigns are active. You can opt out via your browser settings or the platform's own opt-out tools.
You may disable non-essential cookies through your browser settings at any time. Disabling essential cookies may affect certain features of this website.
10. Data of Minors
This website is intended for adults, specifically healthcare professionals seeking financial planning information. We do not knowingly collect personal data from individuals below 18 years of age. If you believe a minor has submitted personal data through this website, please contact us immediately at [email protected] and we will delete the information promptly.
11. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our data practices, applicable law, or NPC guidelines. When material changes are made, we will update the Effective Date at the top of this page and, where appropriate, notify you by email.
We encourage you to review this page quarterly. Your continued use of this website after an update constitutes acknowledgment of the revised policy. Prior versions are available upon request.
12. Contact & Data Privacy Inquiries
For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, reach Brian directly:
We commit to responding to all data privacy inquiries within 15 working days from receipt of your request, as required by the NPC.