Last Updated / Effective Date:June 23 2026

CTT.Synergy Corporation ("we," "us," or "our") operates as the Personal Information Controller

(PIC) under the Philippines’ Data Privacy Act of 2012 (Republic Act No. 10173). We are

committed to protecting the privacy and securing the personal data of our delivery partners,

riders, and couriers ("Riders," "you").

This Privacy Policy outlines how we collect, use, store, share, and dispose of your personal

data, with a specific emphasis on the precise location tracking required to perform our logistics

services.

1. Core Principles of Data Processing

In compliance with the National Privacy Commission (NPC) guidelines, your data is processed

based on three foundational pillars:

● Transparency: We explicitly inform you about what data we track, why we track it, and

who sees it.

● Legitimate Purpose: We only process data necessary to facilitate the courier and

delivery services contract.

● Proportionality: We collect only the data that is adequate and relevant. We do not

track your location when you are off-duty.

2. Precise Location Tracking (GPS Data)

Because BuiltaMart Rider App supports an on-demand delivery for BuiltaMart App, processing

your precise real-time location is a contractual necessity. Without it, the app cannot function.

A. When We Collect Location Data

● Foreground Tracking (App Open): We collect your precise location via GPS, Wi-Fi,

and cell towers when the app is open and visible on your screen.

● Background Tracking (App Minimised/Screen Locked): We collect your precise

location in the background only when your status is toggled to "Online," "Offline," or

during an active delivery shift. This allows our system to allocate nearby delivery

requests to you and calculate accurate delivery ETAs.

● No Off-Duty Tracking: The moment you toggle your status to "Offline" or log out, all

background location tracking ceases immediately. We respect your right to privacy

outside of your service hours.

B. Purpose of Location Tracking

● Order Matching & Dispatching: To send delivery requests to the closest available rider,

reducing your travel time.

● Real-Time Navigation: To provide optimized routing and turn-by-turn directions.

● Customer & Merchant Updates: To allow the merchant and the end-customer to view

your real-time position on a map for delivery transparency.

● Distance & Earnings Calculation: To precisely compute your distance-based fees,

incentives, and total payouts.

● Safety & Incident Response: To locate you in case of road accidents, disputes, or

emergencies during an active delivery.

3. Other Personal Information We Collect

To manage your account and comply with Philippine regulatory laws, we also collect:

● Account Profile: Full name, mobile number, email address, and profile photo.

● Identity Verification Documents: Government-issued IDs (e.g., UMID, Passport, SSS),

Professional Driver’s License, Vehicle Registration (OR/CR), and NBI/Police Clearances.

● Financial Details: Bank account or e-wallet info (e.g., GCash, Maya) for disbursement

of earnings.

● Proof of Delivery (POD) Protocols: Photos taken upon successful delivery.

Important NPC Compliance Note: When taking a Proof of Delivery photo, Riders

must only take photos of the package or the location, and never take photos

showing the faces of minors or unauthorized individuals.

4. How We Share and Disclose Your Data

We do not sell your data. In line with the DPA, data sharing is restricted to what is necessary to

fulfill the delivery service:

● To Customers: Once you accept an order, the customer sees your first name, vehicle

type, license plate number, and live GPS location until the booking is tagged as

complete.

● To BuiltaMart: BuiltaMart’s Internal system will display your name and distance to track

your arrival for pickup.

● To Third-Party Processors: We utilize trusted service providers (such as cloud hosts

like AWS/Google Cloud, map APIs like Google Maps, and payment gateways) bound by

strict Data Sharing Agreements (DSAs) that mirror our privacy standards.

● To Law Enforcement / Government Agencies: We may disclose location history or

identity details if legally compelled by a valid subpoena, court order, or formal request

from agencies like the NPC, LTO, or PNP.

5. Data Security, Retention, and Secure Disposal

We implement strict organizational, physical, and technical security measures (including

end-to-end encryption and restricted access controls) to prevent unauthorized access,

alteration, or leaks.

● Retention: We do not retain your location logs for as long as you maintain an active

account with us.

● Disposal: Historical location logs are anonymized or permanently deleted after 1 year,

unless required for active legal disputes or tax audits. In compliance with the NPC,

disposal is executed via secure digital shredding to ensure data can never be recovered.

6. Your Rights as a Data Subject

Under Chapter IV of the Philippine Data Privacy Act of 2012, you hold specific rights which you

can exercise at any time:

1. Right to be Informed: Knowing how and why your location and data are being

processed (fulfilled via this policy).

2. Right to Access: Requesting a copy of the personal information we hold about you,

including your account details.

3. Right to Rectification: Mandating the correction of any inaccurate or outdated

information in your profile.

4. Right to Erasure or Blocking: Requesting the deletion or suspension of your account

and personal data from our systems.

5. Right to Object: The right to refuse location tracking, though doing so will mean you

cannot go "Online" to receive orders.

6. Right to Data Portability: Obtaining your data in a secure, electronic, and structured

format for your personal use.

7. Right to File a Complaint: If you believe your privacy rights have been violated, you

have the right to file a formal complaint directly with the National Privacy Commission

(NPC) (www.privacy.gov.ph).

8. Right to Damages: Seeking indemnity for any financial or personal harm suffered due

to inaccurate, false, or unauthorized use of your data.

7. Contact Our Data Protection Officer (DPO)

If you wish to exercise any of your rights, or if you have questions regarding our GPS tracking

policies, you may directly contact our designated Data Protection Officer:

● Attention: Data Protection Officer

● Company Name: CTT.Synergy Corporation

● Email Address: dataprotection@builtamart.com

● Office Address:UNIT 112B - 115B, FAME RESIDENCES, EDSA CORNER

MAYFLOWER ST. HIGHWAY HILLS, MANDALUYONG CITY, NCR, SECOND

DISTRICT, 1550, PHILIPPINES