ClickrSpace Privacy Policy

1. Controller and privacy contact

The controller is ClickrSpace, operating in the Philippines through its duly registered owner or operating entity. Privacy questions, data-subject requests, and security reports may be sent to privacy@clickrspace.com.

Launch requirement: the owner must publish the registered legal name, complete business address, and designated Data Protection Officer contact here before commercial launch, and must register data processing systems or the DPO with the NPC when required.

2. Personal data we process

• Account data: name, date of birth, email or phone number, username, password hash, verification status, policy-consent records, and security settings.
• Profile and content: profile and cover photos, bio, location, optional home address and contact information, work and education history, interests, posts, comments, reactions, stories, live broadcasts, groups, events, reports, and content metadata. Home address is private to the account owner; optional contact information is shown only when the user enables its visibility setting.
• Communications: direct and group messages, support requests, and related delivery or abuse-prevention metadata.
• Technical and activity data: IP address, device and browser details, login sessions, timestamps, approximate network location, security events, cookies or local-storage identifiers, and interaction logs.
• Payment and creator data: transaction references, amounts, payout preference, masked account details, verification status, and records required for accounting, fraud prevention, disputes, and law. Payment card details are handled by the payment provider and should not be stored by ClickrSpace.
• Sensitive personal information: only when necessary and permitted by law, such as date of birth or identity-verification information processed by an approved verification provider. Government IDs should not be uploaded into ordinary posts, messages, or profile fields.

3. Purposes and lawful bases

We process data only for declared, specified, and legitimate purposes, and only to the extent necessary and proportionate. Depending on the activity, the lawful basis may be your consent; performance of the ClickrSpace service contract; compliance with law or legal obligations; protection of life and health; response to lawful authority; or legitimate interests that do not override your constitutional and statutory rights.

Purposes include account creation and verification, delivering feeds and communications, operating safety and moderation systems, securing sessions, preventing fraud and abuse, providing support, processing authorized payments, improving reliability, enforcing policies, and complying with lawful orders. We will seek fresh consent when required for a materially different purpose.

4. Visibility and sharing

Information you publish may be visible according to your privacy settings. Private messages are visible to participants and may be accessed by authorized personnel only when necessary for support, security, abuse investigation, or legal compliance.

We may disclose limited data to contracted infrastructure, hosting, database, media-storage, email, SMS, analytics, moderation, identity-verification, livestreaming, and payment providers acting under written instructions and appropriate safeguards; to other users as directed by platform features; to professional advisers; or to competent authorities when required or permitted by Philippine law. ClickrSpace does not sell personal data.

5. Cross-border processing

Some service providers may process data outside the Philippines. ClickrSpace remains accountable for transferred personal data and must use contracts, access controls, security measures, and provider reviews appropriate to the risk, while informing users of material recipients or categories of recipients.

6. Retention and deletion

Personal data is kept only as long as necessary for the stated purpose, account operation, safety, dispute handling, or legal obligations. Account data ordinarily remains while the account is active. Deleted content and account data should be removed from live systems within a reasonable operational period, while encrypted backups may persist for a limited rotation period. Security, transaction, moderation, and legal-hold records may be retained longer where necessary and lawful.

Before launch, the owner must adopt and implement a written retention schedule with exact periods for every data category, backup deletion, legal holds, and secure disposal. Users may request deletion through the privacy contact, subject to lawful exceptions.

7. Security and breach response

ClickrSpace uses organizational, physical, and technical safeguards appropriate to risk, including access controls, password hashing, encrypted sensitive fields, two-factor authentication, session revocation, upload validation, logging, backups, and provider controls. No internet service can promise absolute security.

A documented incident-response team must assess security incidents and notify the NPC and affected data subjects within the periods and conditions required by the DPA and NPC Circular No. 2016-03, including the applicable 72-hour notification rule for notifiable breaches.

8. Your data-subject rights

Subject to lawful limitations, you may exercise the rights to be informed; object; access; rectify inaccurate data; erase or block data; obtain data portability; claim damages; and lodge a complaint with the NPC. You may also withdraw consent where processing relies on consent, without affecting processing already lawfully performed.

Send requests to privacy@clickrspace.com. We may verify identity, explain any lawful limitation, and respond within the period required by applicable NPC rules. You may also contact or file a complaint with the National Privacy Commission.

9. Adults-only launch

ClickrSpace currently accepts accounts only from people aged 18 or older. We do not knowingly create accounts for minors. If a minor’s data is discovered, report it to the privacy contact so the account and data can be reviewed and handled according to law. A future service for minors would require a separate child-safety assessment and verifiable parent or legal-guardian consent process.

10. Changes and controlling law

Material changes will be presented through the service and renewed consent will be requested when required. This notice is governed by Philippine law, including the DPA, its IRR, and applicable NPC issuances. If translated, the English version controls unless Philippine law requires otherwise.