1. Who we are
10XME Technology Inc., 6784 Rufino Pacific Tower, Ayala Avenue corner V.A. Rufino Street, San Lorenzo, Makati City 1223 operates KONEK and is responsible for your personal information. Our Data Protection Officer is [DPO name], who may be reached at [dpo@ email address] or by post at the address above.
2. At registration
Your mobile number (verified by one-time code), your password (stored in a secured form that we cannot read), and your full name, date of birth, sex, email and residential address.
3. To verify your identity
Before you spend points: your ID type, number and images, and a selfie with a liveness check matched against your ID. Before a prize above PHP 10,000 is released: your Taxpayer Identification Number, complete address and payout details, and such other information as may reasonably be required to verify you, process your payout or comply with applicable law, such as your employment status, source of funds and income bracket. Identity verification is performed on our behalf by a third-party service provider not affiliated with KONEK, under a written agreement requiring it to protect your information. Your government-issued identification details and the biometric data from your selfie are sensitive personal information. We collect them with your consent or as required by applicable law, and use them only to verify your identity, comply with applicable law and prevent fraud.
4. What you do in KONEK
Tasks you complete, points earned and spent, entries, box opens, wins and claims, referrals, and the messaging accounts you connect. We also collect technical information from your device, such as your IP address, device type and app logs, to secure your account and prevent fraud.
5. Surveys
Your answers to profile and brand surveys, which you provide with your consent. We treat questions on education, household and finances as sensitive: you may answer 'Prefer not to say' and still earn the full points. Brands receive survey results only as grouped statistics.
6. Photos and receipts
Photos and receipts you upload are read by automated systems to check the task. If a proof is refused, you may ask Support for a review by a member of our team. We keep the image for 12 months and the details read from it for 36 months. A photo showing an ID, a card number or an address label is deleted, and you will be asked to retake it.
7. Location
We use your device location only when you scan a partner's QR code in store, and only with your permission, to confirm that you are there. We check your precise location at that moment but do not store it; we keep only the approximate area, such as the store or city, for 12 months.
8. Smart and TNT purchases
When you buy a participating Smart or TNT product, Smart shares with KONEK your mobile number, the product, the amount, the date and time of the purchase and Smart's purchase reference, so that we can credit your points. Smart does so only for mobile numbers registered on KONEK, under a data sharing agreement between Smart and 10XME Technology Inc. If you made a qualifying purchase before registering, Smart shares it once you register.
9. Why we use it
We use your information to: operate your account and the tasks you choose (to perform our contract with you); verify your eligibility and identity, credit points, conduct draws and release prizes (to perform our contract with you and to conduct the promotion under the DTI-approved mechanics); comply with our legal obligations to the DTI, the BIR and other authorities; prevent and investigate fraud and protect KONEK and its users (our legitimate interests); improve KONEK using grouped or de-identified information (our legitimate interests); and send the promotional messages you turn on (with your consent). We process sensitive personal information only with your consent or where the law requires or permits it.
10. Partner brands
Brands receive grouped statistics only, never your individual record.
11. Others who receive it
Our identity verification provider; cloud hosting and messaging providers, which may store information outside the Philippines subject to the safeguards required by the Data Privacy Act; prize suppliers and delivery partners (to deliver your prize); Smart (to confirm purchases, under our data sharing agreement); partner brands (only the information needed to confirm a task they offer, and grouped statistics); the DTI (the full list of winners it requires); the BIR (for prize tax reporting); the public (winners' names, as announced under the mechanics); our auditors and legal advisers; and courts and government authorities where required by law.
12. Winners
Winners are published by first name and the initial of the surname. Your photo is used only if you agree at claiming.
13. Marketing
Promotional messages are off on every channel until you turn them on in Message Settings. You can turn them off there at any time, reply STOP, or use the unsubscribe link. Account, security and prize messages continue as part of your account.
14. How long we keep it
Account and identity records: for the life of your account and thereafter for the period required or permitted under applicable law. Selfie and liveness data: [90 days] after the check is completed, although we retain the result of the check with your identity record. Tax and payout records, and promotion records (entries, draws, winners and prizes): for the period required or permitted under applicable law. Survey answers: 36 months, or until you withdraw your consent. Photos: 12 months, and the details read from them: 36 months. Approximate location: 12 months. Connected messaging accounts: until you disconnect them, plus 30 days. We may retain any record for longer where required or permitted by applicable law, including while a tax assessment, regulatory inquiry or legal claim is pending. At the end of these periods, we delete or anonymize the information.
15. How we protect it
We maintain the organizational, physical and technical security measures required by the Data Privacy Act, including encryption, access limited to the staff and service providers who need it, access logging, and the separate storage of identity records. While no system is completely secure, we review these measures regularly.
16. Your rights
You have the right to be informed about, and to access, your personal information; to have it corrected; to have it erased or blocked; to object to its processing; to withdraw any consent; and to obtain a copy of it in a commonly used electronic format. You may also lodge a complaint with the National Privacy Commission. You may exercise these rights through in-app Support or by contacting our Data Protection Officer. We may ask you to verify your identity first, and will respond within the period required under applicable law. Some requests may be limited where applicable law requires or permits us to retain your information.
17. Withdrawing consent
You may withdraw your survey, location or marketing consent at any time, in the app or through Support, and keep the points you have already earned. Withdrawal does not affect processing carried out before it, and we will stop using that information for that purpose, except where the law requires us to retain it. Identity verification is required to spend points and claim prizes; if you withdraw your consent to it, you will not be able to spend points or claim prizes until you verify again.
18. Age
KONEK is for users aged 18 or older. An account found to belong to someone younger is closed.
19. Device storage
The app stores your session and settings on your device, for example through cookies or local storage, so that you stay signed in and your preferences are remembered.
20. If something goes wrong
If a personal data breach gives rise to a real risk of serious harm to you, we will notify the National Privacy Commission and you as required by applicable law, and will tell you what happened and the steps you can take to protect yourself.
21. Changes
When we make a material change to this policy, such as a new purpose, a new type of information or a new recipient, we will show you the updated version in the app before it takes effect and, where the change requires your consent, we will ask for it. Each version shows its effective date.
Questions about this page? Write to hello@konek.now.