Privacy Policy

Dragonpine Corporation and Pineyard Industries

Effective date: November 9, 2026

1. Introduction

Dragonpine Corporation and Pineyard Industries (the "Companies") use authorized digital systems and workflow automation technologies to support business operations, improve administrative efficiency, and manage information securely. This Privacy Policy explains how personal information and business data may be collected, accessed, processed, stored, and disclosed through the Companies' internal automation systems.

2. Scope

This policy applies to authorized automation systems operated for the Companies, including:

3. Information Processed

Depending on the workflow, information may include:

Only information reasonably necessary for the authorized purpose should be processed.

4. Purpose of Data Processing

Information is processed to support legitimate and authorized business operations, including financial reporting, SOA preparation, employee timekeeping, payroll administration, data validation, record management, and operational monitoring. Automated processing may include calculations, document generation, notifications, reporting, and approved integrations. The applicable legal basis for processing must be established according to the type of data and purpose involved.

5. Google API Services

The Companies' automation systems may access Google Sheets and Google Drive using Google OAuth authorization. Depending on granted permissions, these integrations may read, create, update, organize, copy, or delete authorized spreadsheet and document files. Google data is accessed and used for the business functions described in this policy. Access is intended to be limited to authorized workflows and personnel. Information obtained through Google APIs will be handled in accordance with the Google API Services User Data Policy, including applicable Limited Use requirements. Google user data will not be sold or used for advertising. It will not be used to train generalized artificial intelligence models by the Companies without an independently established, permissible basis and any required authorization.

6. Automation Infrastructure and Third-Party Services

The Companies may use self-hosted workflow automation software, cloud infrastructure, databases, Google services, and other approved technology providers. Some workflows may transmit necessary information to external services for tasks such as notifications, document management, or AI-assisted processing. Such transfers must be assessed and authorized before implementation, with appropriate security and contractual safeguards where required.

7. Information Security

The Companies aim to apply reasonable organizational, physical, and technical safeguards, such as authenticated system access, encrypted HTTPS connections, access restrictions, secure credential management, and controlled infrastructure administration. No information system can guarantee absolute security. Security measures must be periodically reviewed and updated according to operational risks.

8. Data Retention and Deletion

Information will be retained only for as long as necessary for legitimate business purposes, applicable legal obligations, and approved recordkeeping requirements. Retention periods may vary depending on whether information relates to financial transactions, employment, payroll, or technical system operations. Upon the expiry of applicable retention periods, records should be securely deleted, anonymized, or otherwise disposed of according to approved company procedures.

9. Access and Disclosure

Personal information may be accessed by authorized personnel and approved service providers only to the extent necessary for their legitimate functions. Disclosure to third parties must have an appropriate legal basis and comply with applicable privacy and contractual requirements.

10. Rights of Data Subjects

Individuals whose personal information is processed may exercise applicable rights under Republic Act No. 10173, the Philippine Data Privacy Act of 2012, and related regulations. These may include rights to be informed, access personal data, request corrections, object to certain processing, and request erasure or blocking where legally applicable.

11. Privacy Inquiries

Questions or requests concerning personal information may be directed to the Companies' designated privacy contact or authorized representative.

Privacy contact: lars@dragonpine.com.

12. Changes to This Policy

The Companies may revise this Privacy Policy to reflect changes in legal requirements, technology, operational activities, or approved automation systems. Material changes involving personal data processing will be communicated as required by applicable law.

Effective date: November 9, 2026.