Privacy Policy

Effective Date: March 22, 2026

This Privacy Policy describes how AJA SARAH INFORMATION TECHNOLOGY CONSULTANCY ("AJA Sarah Marketer", "AJA Digital Group", "Tour Command Center (TCC)", "we") collects, uses, and protects personal data within the Tour Command Center (TCC) platform under AJA Digital Group.

1. Legal Compliance

• Philippine Data Privacy Act of 2012 (RA 10173)
• GDPR (where applicable)
• Google API Services User Data Policy (Limited Use compliant)

2. Information We Collect

• Account Data: name, email, Google profile ID
• Tour Data: participant names, roles, school affiliations
• Service Data: CRM records, onboarding, workflows
• Technical Data: IP address, device, logs
• Uploads: waivers, IDs, consent forms (if applicable)

3. Purpose of Processing

• Authentication and account management
• Tour coordination and manifest generation
• Automation, workflows, and system operations
• Compliance, audit, and fraud prevention

4. Lawful Basis

• Consent
• Contractual necessity
• Legal compliance

5. Google API Data Usage

TCC uses Google OAuth strictly for login. We:

• Do NOT access Gmail, Drive, or sensitive scopes
• Do NOT sell or transfer Google user data
• Use data only for authentication and account linking

6. Automated Processing

We use rule-based automation (tags, workflows, routing). No decisions with legal or significant impact are made solely by automation.

7. Data Sharing

• Authorized personnel
• Cloud providers (e.g., Firebase)
• Clients/agencies within isolated environments
• Legal authorities if required

8. International Transfers

Data may be processed outside the Philippines via secure cloud systems with safeguards.

9. Data Retention

Data is retained during service and up to 5 years after last interaction unless legally required otherwise.

10. Security Measures

• Encryption in transit and at rest
• Role-based access control
• Tenant isolation
• Audit logs and monitoring

11. User Rights

• Access, correction, deletion
• Withdraw consent
• Object to processing

12. Children's Data

Student data is processed under partner institutions. We act as Data Processor.

13. Cookies

We use cookies for authentication, analytics, and performance.

14. Updates

Policy updates will be posted with revised dates.

15. Contact

Data Protection Officer (DPO)
AJA Sarah Marketer / AJA Digital Group / Tour Command Center (TCC)
Email: arthor@ajadigitalgroup.com

16. Compliance Notice

This site is not endorsed by Meta (Facebook). Google API data is handled per Limited Use requirements.

17. Platform Role & Responsibility

Tour Command Center (TCC) operates strictly as a technology platform that enables coordination, data management, and communication between tour operators, agencies, schools, and participants. We do not organize, manage, or execute tours.

18. No Liability for Tour Operations

AJA Digital Group and TCC shall not be liable for any incidents, losses, damages, injuries, delays, cancellations, or disputes arising from:

• Tour execution, logistics, or transportation
• Actions or omissions of tour operators, schools, or third parties
• Inaccurate or incomplete data provided by users

19. Responsibility of Tour Operators & Agencies

Tour operators and agencies are solely responsible for:

• Tour planning, safety, and execution
• Compliance with government regulations and permits
• Accuracy of participant data uploaded into TCC
• Insurance coverage and risk management

20. Responsibility of Schools & Institutions

Schools and institutions are responsible for:

• Obtaining parental consent and required documentation
• Verifying participant data accuracy
• Ensuring student supervision and safety

21. User Warranties

By using TCC, users represent and warrant that:

• All data submitted is accurate and lawful
• They have authority to upload and process such data
• They comply with applicable laws and regulations

22. Indemnification

Users agree to indemnify and hold harmless AJA Digital Group, its officers, and affiliates from any claims, damages, liabilities, or expenses arising from:

• Misuse of the platform
• Violation of laws or third-party rights
• Tour-related incidents outside platform control

23. Limitation of Liability

To the maximum extent permitted by law, AJA Digital Group’s liability shall be limited to the amount paid (if any) for use of the platform. We shall not be liable for indirect, incidental, or consequential damages.

24. Third-Party Services

TCC integrates with third-party services (e.g., Google, Firebase). We are not responsible for the performance, security, or policies of these external providers.

25. Force Majeure

We shall not be liable for failure or delay in performance due to events beyond our control, including natural disasters, network failures, or government actions.

26. Risk Acknowledgment

Users acknowledge that tours inherently involve risk, and TCC serves only as a coordination tool, not a risk management authority.