Data Protection & Compliance — GuiHub Delivery

Owner: GuiHub Digital Solutions Incorporated Version: 1.0 — [EFFECTIVE DATE] Data Protection Officer (DPO): Dave Ricablanca, patcherrom@gmail.com

⚠️ Template notice (internal document). This is an internal compliance/governance template tailored to how GuiHub Delivery processes data. It is not legal advice. Validate it with Philippine counsel and against current NPC issuances. It is meant to support (not replace) your NPC registration, privacy management program, and Google Play Data safety declarations.

This document records how GuiHub Delivery ("the App") complies with the Philippine Data Privacy Act of 2012 (RA 10173), its IRR, and NPC issuances, and with the platform/advertising policies that apply to the App.


1. Roles

and why personal data is processed.

contactable at patcherrom@gmail.com. Responsible for oversight, breach response, and data-subject requests.

number and date once obtained. Registration is required for PICs that meet the NPC thresholds; assess your headcount and sensitive-data processing.]

2. Data inventory (what we hold)

CategoryExamplesSourceSensitivity
Account & identityname, username, phone, email, hashed password, birthdate, age, profile photouserPersonal
Locationdelivery addresses, saved locations, GPS coordinates, driver live/background location during deliveriesuser / devicePersonal
Orders & financeorder contents, prices, fees, wallet balance, top-ups, payouts, remittances, driver earnings & cash-on-handuser activityPersonal / financial
Driver operationsshift time in/out records, daily earnings, debt statusapp activityPersonal
Marketplacelistings (incl. photos & location), buyer–seller chats & images, seller reputation signalsuserPersonal
SupportHelp Centre messages and screenshotsuserPersonal (may contain more)
Device & technicalpush token (FCM), app version, device/OS, diagnostics/crash datadevicePersonal
Advertisingdevice advertising identifier (via AdMob, where enabled)devicePersonal (identifier)

Sensitive personal information (as defined by the DPA) is not intentionally collected. Free-text fields are monitored/moderated to discourage users from submitting it.

3. Lawful basis for processing

Processing relies on: contract (to provide the ordered service), consent (e.g. marketing, precise location, ads personalization), legitimate interests (fraud prevention, safety, service improvement — balanced against user rights), and legal obligation (financial recordkeeping, lawful requests). A basis is mapped to each purpose in the Privacy Policy (§4).

4. Data subject rights — handling process

We honour the DPA rights: be informed, access, object, rectify, erase/block, data portability, damages, and complaint to the NPC.

logged.

changing data.

required by the DPA/NPC. [Insert your internal SLA, e.g. 15 working days.]

5. Security measures (technical & organizational)

and write — users can only access their own data (own orders, own profile), stores/drivers/customers see only what a transaction requires, and administrative access is gated by a server-verified admin allow-list. Reads of order data are scoped per role so no client can bulk-read others' personal data.

identity; sensitive server logic runs in Cloud Functions.

roles (e.g. a driver sees the customer's delivery details only for an active order).

abuse/fraud investigation; admin panels record moderation actions.

are still performed client-side and are on the roadmap to be enforced entirely server-side (Cloud Functions). Track and close these as "Stage 3" hardening.

6. Personal data breach management

immediately.

data subjects within 72 hours** of knowledge of a breach that meets the notification criteria (sensitive/financial data, real risk of serious harm).

7. Sub-processors / third parties

ProviderPurposeData sharedLocation
Google Firebase (Auth, Firestore, Cloud Functions, Cloud Messaging)hosting, auth, database, pushmost app dataGoogle data centers (may be outside PH)
Google AdMobin-app advertising (where enabled)advertising identifier, device/usage signalsGoogle (outside PH)
Google Play Services / Play Integrityapp distribution & integritydevice/app integrity signalsGoogle
Map & geocoding (e.g. OpenStreetMap / Nominatim, Leaflet tiles)maps & reverse-geocodingcoordinates queriedprovider infra
Payment gateway [NAME, once integrated]wallet top-ups / payoutspayment/transaction dataprovider infra

Cross-border transfers are covered by the safeguards in the Privacy Policy (§7). Maintain data-processing/sub-processor agreements with each provider as required.

8. Retention schedule

DataRetention
Active account dataWhile active + [X] after closure
Financial/transaction records[Longer period for tax/legal — insert]
Marketplace chats[Insert]
Support tickets & screenshots[Insert]
Driver shift/earnings records[Insert]
Diagnostics/logs[Insert]

After the period, data is deleted or anonymized.

9. Children

The App is for users 18+. We do not knowingly process children's data; if discovered, it is deleted.

10. Google Play & advertising compliance

declare the data collected/shared above (identity, location incl. background location for drivers, financial info, photos, messages, device IDs) and the purposes.

camera, and notifications are declared and used only for their stated purpose, with a prominent in-app disclosure and consent for background location.

with the Families/most-users ad policies. Provide a working Privacy Policy URL.

account and data deletion (Play now requires this). [Insert the URL / in-app path.]

11. Privacy management program (checklist)

tracking and financial data.

12. Document control