PalaOne Freediving Tours - Privacy Policy

1. Introduction

PalaOne Freediving / PalaOne Freediving Coron ("we," "us," "our," "Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you visit our website at www.palaonefreediving.com, book our services, or interact with us.

Business Information:

• Business Name: PalaOne Freediving / PalaOne Freediving Coron
• Business Type: Sole Proprietorship
• Business Address: PalaOne Freediving, Bancuang Baba, Barangay 5, Coron, Palawan, Philippines
• Website: www.palaonefreediving.com

Data Controller: PalaOne Freediving is the data controller responsible for your personal information under this Privacy Policy.

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2. Information We Collect

2.1 Information You Provide Directly

Contact and Booking Information:

• Name (first and last name)
• Email address
• Phone/contact number
• Service interests (which freediving activities you're interested in)
• Inquiry messages and communication content
• Booking details (tour dates, number of participants, special requests)
• Emergency contact information (for tour participants)

Payment Information:

• Billing information for payment processing
• Transaction details and payment confirmations
• Note: We do not store credit card numbers or payment details on our systems. All payment processing is handled by secure third-party payment processors (PayPal, credit card processors, GCash, Maya).

Safety and Medical Information:

• Medical conditions or physical limitations relevant to activity participation
• Certification levels and diving experience
• Emergency contact details
• Age and parental consent information for minors

2.2 Information Collected Automatically

Website Usage Information:

• IP address and location data
• Browser type and version
• Device information (mobile, desktop, tablet)
• Pages visited and time spent on our website
• Referring website information
• Date and time of visits

Cookies and Tracking Technologies:

• Essential website functionality cookies
• Analytics cookies (Google Analytics)
• Social media integration cookies (Facebook, Instagram)
• Booking system cookies for functionality
• Performance monitoring cookies

2.3 Information from Third Parties

Social Media Integration:

• Information from social media platforms when you interact with our social media pages or share our content
• Profile information if you choose to log in through social media platforms

Partner Organizations:

• Information from transportation and accommodation partners when arranging services for you
• Booking information from third-party booking platforms

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3. How We Use Your Information

3.1 Primary Purposes

Service Delivery:

• Processing and confirming tour bookings
• Providing freediving instruction and guiding services
• Coordinating transportation and accommodation through partners
• Managing equipment rentals and returns
• Delivering underwater photography/videography services

Safety and Emergency Response:

• Ensuring participant safety during activities
• Maintaining emergency contact information
• Assessing fitness and medical suitability for activities
• Coordinating emergency response if needed

Communication:

• Responding to inquiries and booking requests
• Sending booking confirmations and updates
• Providing pre-activity safety briefings and information
• Sharing important safety or weather-related updates

3.2 Secondary Purposes

Business Operations:

• Improving our services based on customer feedback
• Managing customer relationships
• Processing payments and maintaining transaction records
• Compliance with legal and regulatory requirements

Marketing and Promotion:

• Sending promotional materials about our services (with consent)
• Sharing updates about new offerings or special packages
• Creating marketing materials using photos/videos from activities (with consent)
• Social media marketing and content sharing

Website Improvement:

• Analyzing website usage to improve user experience
• Understanding which services are most popular
• Optimizing website performance and functionality
• Preventing fraud and ensuring website security

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4. Legal Basis for Processing (Where Applicable)

We process your personal information based on the following legal grounds:

Contract Performance: Processing necessary to fulfill our service agreements with you, including booking processing, service delivery, and payment handling.

Legitimate Interests: For business operations, website analytics, fraud prevention, and direct marketing to existing customers.

Consent: For marketing communications, photo/video use, and non-essential cookies (where consent is required).

Legal Obligations: For compliance with safety regulations, tax requirements, and other legal obligations.

Vital Interests: For emergency response and safety situations during activities.

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5. Information Sharing and Disclosure

5.1 Service Partners

Essential Service Providers:

• Transportation partners (boat operators, van services) for logistics coordination
• Accommodation partners for booking assistance
• Payment processors for secure transaction handling
• Equipment suppliers for gear rental management

Professional Service Providers:

• Medical professionals for emergency response
• Legal advisors for compliance matters
• Insurance providers for coverage verification
• Accounting services for financial management

5.2 Third-Party Technology Providers

Website and Analytics:

• Google Analytics for website usage analysis
• Social media platforms (Facebook, Instagram) for integration and marketing
• Booking system providers for reservation management
• Email service providers for communication

Important: We only share information necessary for these providers to deliver their services, and we require them to protect your information appropriately.

5.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Respond to emergency situations
• Prevent fraud or illegal activities
• Comply with industry safety regulations

No Commercial Sale: We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

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6. International Data Transfers

Geographic Scope: Our services are provided in the Philippines, and your information is primarily processed within the Philippines.

Third-Party Services: Some of our service providers (such as Google Analytics, PayPal, Facebook) may transfer data internationally. These providers have appropriate safeguards in place to protect your information.

Travel Context: If you are visiting from another country, you understand that your information will be processed in the Philippines under Philippine law.

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7. Data Security

7.1 Security Measures

Technical Safeguards:

• Secure Socket Layer (SSL) encryption for website communications
• Regular security updates and monitoring
• Secure storage systems with access controls
• Regular data backups with encryption

Physical Safeguards:

• Secure office facilities with restricted access
• Locked storage for physical documents
• Secure disposal of sensitive documents
• Limited access to personal information

Administrative Safeguards:

• Staff training on privacy and security practices
• Access controls based on job responsibilities
• Regular security audits and assessments
• Incident response procedures

7.2 Payment Security

• We do not store credit card information on our systems
• All payment processing uses secure, PCI-compliant processors
• Transaction data is encrypted during transmission
• Payment confirmations are securely stored

Security Limitations: While we implement strong security measures, no system is completely secure. We cannot guarantee absolute security of your information.

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8. Data Retention

8.1 Retention Periods

Booking and Service Records:

• Active customer information: Retained while you remain an active customer
• Completed service records: 7 years for business and tax compliance
• Payment records: 7 years for financial and legal compliance

Communication Records:

• Email correspondence: 3 years from last contact
• Inquiry messages: 2 years or until booking completion
• Marketing communications: Until you unsubscribe

Safety and Medical Information:

• Medical disclosures: 7 years for liability and safety compliance
• Emergency contact information: Duration of relationship plus 2 years
• Incident reports: 10 years for legal protection

Website Analytics:

• Usage data: 26 months (Google Analytics default)
• Cookies: As specified in cookie settings (typically 30 days to 2 years)

8.2 Disposal

When retention periods expire, we securely delete or anonymize your information using:

• Secure deletion software for digital records
• Shredding for physical documents
• Data anonymization for analytical purposes
• Certificate of destruction for sensitive materials

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9. Your Rights and Choices

9.1 Access and Control

Information Access: You may request to see what personal information we hold about you.

Correction Rights: You can request correction of inaccurate or incomplete information.

Communication Preferences: You can opt out of marketing communications at any time by:

• Clicking unsubscribe links in emails
• Contacting us directly
• Updating preferences through our website (when available)

Account Information: You can update your contact information by contacting us.

9.2 Data Portability and Deletion

Data Portability: Where technically feasible, we can provide your information in a commonly used format.

Deletion Requests: You may request deletion of your information, subject to:

• Legal retention requirements
• Ongoing service obligations
• Legitimate business needs
• Safety and liability considerations

Restriction of Processing: You may request that we limit how we use your information in certain circumstances.

9.3 Withdrawal of Consent

• You can withdraw consent for marketing communications at any time
• You can adjust cookie preferences through browser settings
• Withdrawal may limit our ability to provide certain services
• Some processing may continue based on other legal grounds

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10. Cookies and Tracking Technologies

10.1 Types of Cookies We Use

Essential Cookies:

• Website functionality and navigation
• Booking system operation
• Security and fraud prevention
• User session management

Analytics Cookies:

• Google Analytics for website usage analysis
• Performance monitoring and optimization
• User experience improvement
• Traffic source analysis

Marketing Cookies:

• Facebook Pixel for targeted advertising
• Social media integration
• Conversion tracking
• Remarketing capabilities

Preference Cookies:

• Language and region settings
• User interface customization
• Accessibility features
• Previously entered information

10.2 Cookie Management

Browser Controls: You can control cookies through your browser settings:

• Block all cookies (may limit website functionality)
• Block third-party cookies only
• Delete existing cookies
• Set cookie preferences by website

Opt-Out Options:

• Google Analytics: Google Analytics Opt-out
• Facebook Pixel: Through Facebook Ad Settings
• General advertising: Network Advertising Initiative

Mobile Devices: Adjust privacy settings in your device settings for app-based tracking.

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11. Children's Privacy

11.1 Age Requirements

Minimum Age: Our services are designed for participants of all ages, but those under 18 require parental consent.

Parental Consent: For participants under 18, we require:

• Written parental consent before collecting any information
• Parent/guardian contact information
• Medical and emergency information provided by parent/guardian
• Acknowledgment of risks by parent/guardian

11.2 Information from Minors

Limited Collection: We only collect information from minors that is necessary for:

• Safety and emergency response
• Service delivery
• Parental communication
• Legal compliance

Parental Rights: Parents/guardians may:

• Review information we've collected about their child
• Request correction or deletion of their child's information
• Refuse further collection or use of their child's information
• Receive information about our privacy practices

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12. Updates to This Privacy Policy

12.1 Policy Changes

Regular Review: We review this Privacy Policy regularly and update it as needed to reflect:

• Changes in our business practices
• New legal requirements
• Technological developments
• Customer feedback

Notification Methods:

• Website posting with prominent notice
• Email notification for significant changes
• Social media announcements
• Direct communication with active customers

12.2 Continued Use

Continued use of our services after policy updates constitutes acceptance of the revised Privacy Policy. If you disagree with changes, please contact us or discontinue use of our services.

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13. Contact Information and Complaints

13.1 Privacy Contact

For privacy-related questions, requests, or concerns, contact us:

PalaOne Freediving

• Address: Bancuang Baba, Barangay 5, Coron, Palawan, Philippines
• Email: palaonefreediving@gmail.com
• WhatsApp: +63 905 375 6012 (English & Mandarin)
• WhatsApp: +63 967 206 9708 (English & Tagalog)
• Website: www.palaonefreediving.com

13.2 Response Time

We will respond to privacy inquiries within:

• Acknowledgment: 3 business days
• Simple requests: 7 business days
• Complex requests: 30 business days
• Urgent safety matters: Same day when possible

13.3 Complaint Resolution

Internal Process:

1. Contact us directly with your concern
2. We will investigate and respond within 30 days
3. If unsatisfied, you may escalate to our management
4. We will work to resolve issues fairly and promptly

External Options: If you believe we have not properly handled your privacy concerns, you may contact:

• Philippine Data Privacy Commission
• Local consumer protection agencies
• Legal counsel for advice on your rights

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14. Business Transfers

In the event of a business sale, merger, or acquisition, your personal information may be transferred to the new owner. We will:

• Notify you of any such transfer
• Ensure the new owner honors this Privacy Policy
• Provide options for opting out where legally possible
• Require appropriate data protection commitments

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15. Specific Service Privacy Notes

15.1 Photography and Video

Consent: By participating in activities, you consent to photography/videography for promotional use unless you specifically opt out.

Usage Rights: Photos and videos may be used for:

• Website and social media marketing
• Promotional materials and brochures
• Educational content creation
• Business documentation

Opt-Out: Inform us before activities begin if you do not want to be photographed or filmed.

15.2 Emergency Information

Special Handling: Medical and emergency contact information receives enhanced protection due to its sensitive nature.

Limited Sharing: This information is only shared with:

• Medical professionals in emergencies
• Designated emergency contacts
• Authorized safety personnel
• Insurance providers when necessary

15.3 Social Media Integration

Platform Policies: When you interact with our social media pages, those platforms' privacy policies also apply.

Information Sharing: We may share promotional content between our website and social media platforms.

User-Generated Content: Photos or reviews you share publicly may be used for promotional purposes with attribution.

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16. Final Notes

16.1 Language

This Privacy Policy is written in English. If translated into other languages, the English version takes precedence in case of conflicts.

16.2 Accessibility

We are committed to making this Privacy Policy accessible to all users. If you need this information in an alternative format, please contact us.

16.3 Regular Updates

We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your information.

Remember: Your privacy is important to us, and we are committed to protecting your personal information while providing you with exceptional freediving experiences in the beautiful waters of Coron.

This Privacy Policy governs the collection, use, and protection of your personal information by PalaOne Freediving and reflects our commitment to transparency and data protection.

Last Updated: August 1, 2025
Version: 1.0