1. Introduction

This Privacy Policy explains how Cornerstone Global, Inc. ("Cornerstone," "we," "us," or "our") collects, uses, shares, protects, and retains your personal data when you use the Cornerstone: Connect application and related services (the "App"). It should be read together with our Terms of Use.

We are committed to processing your personal data fairly, lawfully, and transparently, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

2. Who is responsible for your data

Cornerstone Global, Inc., organized under the laws of the Republic of the Philippines, is the personal information controller responsible for your personal data. If you have questions about this Policy or how we handle your data, contact us at [email protected].

3. Information we collect

We collect the following categories of personal data, most of which you provide directly when you sign in and create your profile:

• Account and contact data: your mobile phone number and the one-time passcodes (OTP) used to verify it.
• Profile information: first, middle, and last name, nickname, date of birth, gender (optional), and address (street, city, province, and postal code).
• Profile photo: a photo of your face shown on your profile and used to identify you at events.
• Identity (EKYC) documents: the type and number of a government-issued ID, a photo of that ID, and a selfie of you holding the ID — used to verify that the ID belongs to you.
• Verification status and member identifier: your verification (EKYC) status and a member ID encoded into your attendance QR code.
• Technical data: limited information needed to operate and secure the App, such as session and authentication cookies.

Some of the above — particularly your government ID and the data it contains — may constitute sensitive personal information under the Data Privacy Act. We collect it only with your consent and handle it with additional care.

4. How and why we use your data

We use your personal data for the following purposes:

• To create and secure your account and verify your phone number via OTP.
• To verify your identity (EKYC) and confirm your eligibility to participate in Cornerstone activities.
• To generate your member QR code and record your attendance at Cornerstone events.
• To operate, maintain, troubleshoot, and improve the App and keep it secure.
• To communicate with you about your account, verification status, or these policies.
• To comply with legal obligations and respond to lawful requests from authorities.

Our legal bases for processing include your consent (which you may withdraw at any time), the performance of our agreement with you under the Terms of Use, our legitimate interests in operating a secure community App, and compliance with legal obligations.

5. Identity documents and retention

We use your ID photo and selfie solely to verify your identity. We delete these images once your profile has been verified. If verification cannot be completed, the images are retained only for as long as necessary to attempt verification or as required by law, and are then deleted.

Other profile information (such as your name, date of birth, address, profile photo, and verification status) is retained for as long as you have an account or as needed to provide the App and meet our legal, accounting, or reporting obligations. When data is no longer needed, we securely delete or anonymize it.

6. How we store and protect your data

Your data is stored using reputable third-party cloud infrastructure and database providers engaged to process data on our behalf. We apply organizational and technical safeguards — including access controls, authentication, and restricted storage permissions — designed to protect your data against unauthorized access, alteration, disclosure, or loss.

No method of transmission or storage is completely secure, but we work to protect your data and to limit access to those who need it to operate the App.

7. When we share your data

We do not sell your personal data. We share it only in these limited circumstances:

• Service providers: cloud hosting, database, storage, and SMS/OTP providers that process data on our behalf under appropriate confidentiality and data-protection commitments.
• Event organizers within Cornerstone: when you present your member QR code, authorized organizers record your attendance using your member identifier.
• Legal and safety: when required by law, regulation, or valid legal process, or to protect the rights, safety, and property of Cornerstone, our members, or the public.

8. International transfers

Some of our service providers may process or store data on servers located outside the Philippines. Where this happens, we take steps intended to ensure your data continues to receive a level of protection consistent with the Data Privacy Act.

9. Your rights as a data subject

Under the Data Privacy Act, you have the right to:

• Be informed about how your personal data is processed.
• Access the personal data we hold about you.
• Object to or withdraw consent for certain processing.
• Have inaccurate or outdated data corrected (rectification).
• Request the erasure or blocking of your data, subject to legal limits.
• Data portability, where applicable.
• Lodge a complaint with the National Privacy Commission, and to be indemnified for damages from unlawful processing.

To exercise any of these rights, contact us at [email protected]. We may need to verify your identity before acting on your request.

10. Children and minors

The App may be used by individuals who are at least 13 years old. If you are under 18, you may use the App only with the consent and supervision of a parent or legal guardian, who consents to the processing of your personal data — including your identity documents — on your behalf. If you believe we have collected a minor's data without the required consent, please contact us so we can address it.

11. Cookies and similar technologies

We use strictly necessary cookies and similar technologies to keep you signed in and to maintain the security of your session. These are required for the App to function and are not used for advertising.

12. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date above and, where appropriate, provide notice within the App. Your continued use of the App after changes take effect means you accept the updated Policy.

13. Contact us

For questions, concerns, or requests regarding this Privacy Policy or your personal data, contact Cornerstone Global, Inc. at [email protected]. If you are not satisfied with our response, you may also contact the National Privacy Commission of the Philippines.