This global Privacy Policy explains how App Universa ("we," "our," or "us") collects, uses, stores, and protects your personal data when you create an account and interact with any application within the App Universa ecosystem. This policy is strictly governed by Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.
Ecosystem Integration: This Privacy Policy serves as the central data governance document for your App Universa identity. It is incorporated into and forms an integral part of the Terms of Service for any specific application within our ecosystem. By affirmatively accepting the Terms of Service for any of our applications via the checkbox mechanism described therein, you also consent to the ecosystem data practices described in this document. The Terms of Service for each application are available at https://www.appuniversa.com/terms-of-service.
1. What Data Do We Collect?
App Universa collects the following categories of personal data to maintain your central identity and facilitate your use of ecosystem applications:
- Personal Identification Information: Name, email address, and phone number.
- Account Credentials: Username and encrypted password.
- Connected App Data: Usage logs, application preferences, and interactions within the App Universa ecosystem.
- Technical Data: Browser information, IP address, device type, and standard internet log information.
- Platform Acceptance Records: Date, time, version, and account associated with each Terms of Service and Privacy Policy acceptance event across our applications.
App Universa does not centrally process, collect, or hold financial payments. Any financial transactions occur strictly between the user and the specific application service provider or ecosystem partner. We do not collect or store credit card numbers, bank details, or financial data within your global identity profile.
2. How Do We Collect Your Data?
You directly provide App Universa with most of the data we collect. We collect and process data when you:
- Register for a unified App Universa account.
- Utilize or engage with specific applications within the ecosystem.
- Voluntarily complete a survey, provide feedback, or contact our support team.
- Interact with the ecosystem in ways that generate technical log data.
3. Legal Basis for Processing and How We Use Your Data
Under RA 10173, App Universa is required to declare the legal basis for each processing activity. The table below sets out every category of processing we perform, the data involved, and the legal basis that authorizes it:
| Processing Activity | Data Involved | Legal Basis (RA 10173) |
|---|---|---|
| Account registration and management | Name, email, phone, credentials | Contract — necessary to provide the unified identity service |
| Application-specific interactions | Name, email, application preferences | Contract — necessary to process your actions within ecosystem applications |
| Sharing data with ecosystem partners | Name, contact details | Contract — necessary to fulfill the service you requested within an application |
| Platform security and anti-abuse | IP address, device data, behavioral data | Legitimate interest — protecting the ecosystem and its users |
| Transactional communications | Email address | Contract — necessary to deliver service notifications |
| Promotional communications | Email address | Consent — only where you have explicitly opted in |
| Essential and functionality cookies | Session and preference data | Legitimate interest — necessary for platform functionality and identity persistence |
| Compliance and legal records | Acceptance logs, application audit records | Legal obligation — dispute resolution and RA 10173 compliance |
Data processed for platform security and anti-abuse — including your IP address used for rate-limiting and similar protective measures — is handled transiently for that purpose alone. App Universa does not retain your IP address as a stored identifier for these purposes: where technically necessary it is held only briefly (seconds to minutes) and in a non-identifying (hashed) form, is never written to our permanent records, and is never placed alongside data that identifies you. This transient security processing is separate from, and does not form part of, the retained records described in Section 5.
App Universa will not process your personal data for any purpose not listed above without first obtaining your explicit consent or establishing a new lawful basis, and updating this Privacy Policy accordingly.
4. Sharing Data with Ecosystem Partners
App Universa connects users with various ecosystem partners and localized service providers. When you engage with a specific application or service within the App Universa ecosystem, we share your necessary contact information with that specific partner solely so they can provide the requested service or facilitate your interaction.
4.1 Strict Partner Restrictions
All ecosystem partners and application service providers are legally bound by the localized Terms of Service of their respective applications. They are strictly prohibited from:
- Using your data for marketing or commercial purposes unrelated to the specific service you engaged with.
- Sharing or selling your data to any third party without your express written consent.
- Retaining your data beyond the period reasonably necessary to fulfill the service, as specified in the applicable application's Terms of Service, unless you grant explicit consent for continued retention.
- Processing your data in any manner that violates RA 10173 or any other applicable data protection law.
Violations will result in access termination and formal reporting to the National Privacy Commission (privacy.gov.ph).
4.2 Contextual Advertising (Permanently Non-Personalized)
App Universa monetizes the ecosystem by displaying advertisements through our own internal ad engine and through third-party advertising networks, including Google AdSense. App Universa operates a permanently Non-Personalized Ads (NPA) model. Advertisements are selected based solely on the context of the page or application you are viewing — not on your identity, personal data, or browsing history. App Universa does not build behavioral profiles of users and does not engage in targeted advertising of any kind.
In NPA mode, third-party advertising partners including Google AdSense may set limited functional cookies on your device for purposes such as frequency capping and fraud prevention. These cookies do not track your identity or behavior across sites for advertising or profiling purposes. App Universa does not permit advertising partners to deploy tracking, behavioral, or profiling cookies under any circumstances. This NPA-only model is a permanent commitment and is not subject to change without a full amendment to this Privacy Policy and the affirmative re-consent of all users under Section 10.
5. Data Storage, Retention, and Cross-Border Transfers
5.1 Infrastructure and Cross-Border Transfers
Your data is securely stored utilizing Vercel's cloud infrastructure. As Vercel is a US-based provider, your data may be transferred to and processed on servers located outside the Philippines. By affirmatively ticking the acceptance checkbox when engaging with any App Universa ecosystem application, you provide your informed consent to this cross-border transfer in accordance with RA 10173. Further information on Vercel's security practices is available at https://vercel.com/docs/security.
5.2 Tiered Data Retention Policy
App Universa operates a tiered data retention approach:
- Unstructured Data (Media and Blobs): Photos, images, and other media or blob files uploaded within any ecosystem application may be deleted by App Universa at any time, at our sole discretion, to conserve storage and in accordance with the principle of data minimization under RA 10173. No specific retention period is guaranteed for unstructured data. Users are advised to maintain their own copies of any uploaded media and should not rely on App Universa as a primary or permanent storage solution.
- Profile Media: Profile images and identity-linked media are subject to the same discretionary deletion policy and will be permanently deleted upon account closure.
- Structured Database Records: App Universa will endeavor to retain structured account and application database records — including identity data, usage logs, and platform acceptance records — for a period of up to three (3) years from the date of the relevant interaction or last account activity, whichever is later. This represents a best-efforts commitment and not a guarantee of retention.
- Application-Specific Partner Data: Retention obligations for data shared with ecosystem partners are governed by the Terms of Service of the specific application through which the interaction occurred.
5.3 Data Loss and Notification
In the event that retained data is lost, corrupted, or becomes irrecoverable due to circumstances beyond App Universa's reasonable control — including but not limited to infrastructure failure, force majeure events, or security incidents — App Universa will notify affected users and the National Privacy Commission as required under RA 10173 and NPC Circular 16-03. App Universa's liability in connection with any such data loss is limited as set out in the applicable application's Terms of Service and shall not extend to compensation, reconstruction of lost data, or consequential damages of any kind.
5.4 Secure Disposal
Upon expiration of the applicable retention period, personal data will be permanently deleted or securely anonymized in a manner that prevents unauthorized access, reconstruction, or disclosure to any party, in accordance with the IRR of RA 10173.
6. Cookies
App Universa uses the following categories of cookies. We are transparent about all cookies placed on your device, including those set by third-party advertising partners in connection with our permanently NPA advertising model.
- Essential Cookies: Keep you signed in to your unified App Universa identity across ecosystem applications. Legal basis: legitimate interest and contract. These cannot be declined without losing core platform functionality.
- Functionality Cookies: Remember your previously selected preferences within and across applications. Legal basis: legitimate interest.
- NPA Advertising Functional Cookies: Limited functional cookies set by third-party advertising partners (including Google AdSense) operating in Non-Personalized Ads mode. These are used solely for frequency capping and fraud prevention and do not track your identity, profile your behavior, or enable personalized advertising of any kind. Legal basis: legitimate interest. You may decline these via your browser settings without affecting core platform functionality.
App Universa does not use, and does not permit advertising partners to use, tracking, behavioral, or profiling cookies of any kind. The NPA-only model described in Section 4.2 is a permanent commitment. You may manage cookie preferences through your browser settings at any time.
7. Marketing Communications
App Universa will only send you promotional communications where you have provided your separate, affirmative, and freely given consent to receive them. Consent to receive marketing is not a condition of using the platform or any ecosystem application.
- You may opt out of promotional communications at any time by contacting us at contact@appuniversa.com. We will process your opt-out request within five (5) working days.
- Opting out of marketing communications does not affect essential transactional communications such as account notices and service updates.
8. Your Data Protection Rights
Under RA 10173, every user of App Universa is entitled to the following rights:
- Right to be Informed: You have the right to know whether your personal data is being processed, the extent of processing, and any possible recipients of your data.
- Right to Access: You have the right to request copies of the personal data we hold about you.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete information.
- Right to Erasure or Blocking: You have the right to request that we erase or block your personal data, subject to applicable legal retention obligations.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
- Right to Data Portability: You have the right to request that we transfer your data to another organization or directly to you in a structured and commonly used format.
- Right to Object: You have the right to object to the processing of your personal data, including for direct marketing purposes.
To exercise any of these rights, please contact our Data Protection Officer at dpo@appuniversa.com. By law, we will respond within fifteen (15) working days of receipt, extendable to thirty (30) calendar days for complex requests. We will notify you if an extension is required.
9. Data Breach Notification
In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, App Universa will, in strict accordance with NPC Circular 16-03:
- Notify the National Privacy Commission within seventy-two (72) hours of discovering the breach.
- Notify affected data subjects without undue delay, providing details of the breach, the data involved, the potential impact, and the remedial actions taken or planned.
- Maintain a breach register documenting all incidents, our assessment of risk, and actions taken.
Notification will be made via the email address associated with your account.
10. Amendments and Active Consent
App Universa keeps this Privacy Policy under regular review. Whenever this Privacy Policy or the Terms of Service of any ecosystem application are amended, all users will be required to affirmatively tick an acceptance checkbox upon their next ecosystem interaction requiring assent before proceeding. App Universa does not rely on passive or implied acceptance for any amendments.
Amendments take effect on the date specified in the updated document. App Universa maintains system logs recording the date, time, version, and account associated with each acceptance event. The most current version of this Privacy Policy will always be accessible at https://www.appuniversa.com/privacy-policy.
11. Contact Us and Data Protection Officer
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact our designated Data Protection Officer:
Data Protection Officer Email: dpo@appuniversa.com
General Support Email: contact@appuniversa.com Website: https://www.appuniversa.com
12. Contact the National Privacy Commission
If you believe App Universa has not addressed your privacy concern satisfactorily, or if you wish to file a formal complaint, you may contact the National Privacy Commission:
National Privacy Commission Website: https://privacy.gov.ph/contactus/ Address: 5th Floor Delegation Building, PICC Complex, Vicente Sotto Avenue, Pasay City, Metro Manila 1307
App Universa — Global Privacy Policy — Governed by Republic Act No. 10173 (Data Privacy Act of 2012)