We take your privacy seriously. This policy explains what personal information Fluffyn collects, why we collect it, how it is used and protected, and what your rights are under Philippine law.
Fluffyn 168 Cleaning Inc. under the name of “Fluffyn” is a premium cleaning service operating in Metro Manila, Philippines. We are the Personal Information Controller as defined under the Philippine Data Privacy Act of 2016 (Republic Act No. 10173) and its Implementing Rules and Regulations.
Business name: Fluffyn 168 Cleaning Inc. under the name of “Fluffyn”
Registered address: UB 111 Paseo de Roxas Building, Legazpi Village, Barangay San Lorenzo, Makati City, Metro Manila, Philippines
Contact email: compliance@fluffyn.ph
We follow a two-stage data minimization approach — we collect only what is needed at each step, in the right channel for the sensitivity of the data.
| Category | Information collected |
|---|---|
| Identity | First name, last name |
| Contact | Mobile number, email address |
| Service area | City / district only (e.g. Makati, BGC, Ortigas) — not exact address |
| Service preferences | Unit size, service type, preferred date and time, add-on selections, notes |
Once we receive your booking request, we contact you via WhatsApp or Viber (end-to-end encrypted) to confirm your slot and collect the operational details needed to deliver the service:
| Category | Information collected |
|---|---|
| Address | Building / condo name, street address, unit number |
| Access | Parking arrangements, doorman instructions, key handover |
| Service details | Pets on site, mattress type, specific focus areas, any special requirements |
We deliberately keep sensitive details (your exact home address) out of email and form systems. WhatsApp and Viber use end-to-end encryption, meaning these details are only visible on your device and ours.
| Category | Information collected | How collected |
|---|---|---|
| Expansion interest | Name, contact, city — if you register for expansion notification | Expansion notification form |
We do not collect payment card numbers, government ID numbers, or sensitive personal information as defined under RA 10173. Payments are processed peer-to-peer via GCash, Maya, or bank transfer — we never receive or store your payment credentials.
Under the Data Privacy Act of 2012 (RA 10173), we process your personal information on the following lawful bases:
Separate consent for marketing audiences (Section 12[a]): Only if you opt in separately, we may share a hashed version of your email address and mobile number with Meta so that it can find new people who resemble our clients. This is a distinct consent from the one above, is never required in order to book, and can be withdrawn at any time.
You may withdraw your consent at any time by emailing us (see Section 11). Withdrawal does not affect the lawfulness of processing carried out before your withdrawal.
We use your personal information strictly for the following purposes:
We do not sell, rent, or trade your personal information to any third party. We do not share your information with other businesses without your explicit consent.
We do not show you advertising based on your personal data. If you are already our client, we contact you directly on the channel you already use with us — we do not pay a platform to reach you.
Finding new clients. If, and only if, you have separately opted in, we may share an irreversibly scrambled (hashed) version of your email address and mobile number with Meta Platforms. Meta uses this solely to identify people whose characteristics resemble our clients, so that our advertising reaches people more likely to want this kind of service. Hashing converts your details into a fixed string that cannot be reversed back into your email or number. We never provide Meta with your name, address, access instructions, service history, booking details, or payment information for this purpose. This consent is optional, is never a condition of booking, and you may withdraw it at any time by emailing us (see Section 11); on withdrawal we remove you from any such audience.
If you message us on Facebook or Instagram. A conversation held on Messenger or Instagram takes place on Meta’s own platform and is processed by Meta under its privacy policy. We cannot control or limit what Meta collects from a conversation on its own service. Anything you send us there — including an address, access instructions, or photographs of your home — is held by Meta as well as by us. Some clients prefer to complete their booking there, and we accept that — which means the address and access details for that booking are held by Meta too. Where you are willing, we will offer to move those details to WhatsApp, which is end-to-end encrypted, but we will not insist. Payment is never made through any messaging platform.
Measuring our advertising. Where you first reached us through one of our advertisements, we record in Meta’s advertising tools whether that conversation went on to become a booking. This tells us which advertisements bring genuine clients rather than only messages, so that we spend sensibly. We rely on our legitimate interest in understanding the effectiveness of our own advertising (Section 12[f], RA 10173). It does not involve giving Meta your booking details, address, or payment information, and you may object at any time by emailing us (see Section 11).
We apply data minimization by design — collecting only the information needed at each stage, in the channel most appropriate for its sensitivity. This approach significantly reduces the risk and impact of any potential data exposure.
While we take reasonable technical and organizational measures to protect your data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach, we will notify affected individuals and the National Privacy Commission (NPC) as required under RA 10173 and NPC Circular 16-03.
We use the following third-party services to operate our website and booking system. These are our Personal Information Processors under RA 10173. They process data on our behalf and are bound by their own privacy policies and data processing agreements.
| Processor | Purpose | Data processed | Location |
|---|---|---|---|
| HubSpot Privacy Policy ↗ |
Booking form submission, CRM storage, customer communication | Name, contact, area (city only), service preferences, consent records. No address details. | United States / EU |
| Google (Gmail) Privacy Policy ↗ |
Receipt of booking emails | Same as HubSpot above — no address details | United States / global |
| Meta (Messenger & Instagram) Privacy Policy ↗ |
Enquiries and conversations you choose to start on Messenger or Instagram, including completing a booking there if that is the channel you prefer; recording whether an advertisement led to a booking | Whatever you send us in that conversation, which may include your address and access details if you complete your booking there. Held on Meta’s platform under Meta’s own policy. We would rather take addresses and access details on WhatsApp. | United States / global |
| WhatsApp (Meta) Privacy Policy ↗ |
Booking confirmation, address collection, service coordination | Address details, access instructions, service-specific info (end-to-end encrypted) | United States / global |
| Viber (Rakuten) Privacy Policy ↗ |
Alternative confirmation channel | Same as WhatsApp above (end-to-end encrypted) | Japan / Luxembourg |
| Meta Platforms Privacy Policy ↗ |
Marketing audiences — only where you have separately opted in | Hashed email address and mobile number only. No name, address, service history, or booking details. | United States / global |
| Google Fonts Privacy Policy ↗ |
Website typography | IP address (standard web request) | United States / global |
All processors listed above operate under data processing terms that are compatible with international data protection standards. The transfer of personal data to processors outside the Philippines is conducted under reasonable assurances that recipient organizations implement adequate data protection measures, as permitted under Section 21 of RA 10173.
We retain your personal information only for as long as it is necessary to fulfill the purposes described in this policy.
| Data type | Retention period | Reason |
|---|---|---|
| Booking records (HubSpot CRM) | Retained while you are an active customer; deletable on request | Service delivery, customer history, follow-up |
| Booking records in email inbox | 12 months from date of service | Service history, dispute resolution |
| Booking records (canceled / no-show) | 3 months from booking date | Operational records |
| WhatsApp / Viber conversations | 12 months from last interaction | Service coordination, address details |
| Expansion notification leads | 24 months or until notified, whichever is first | Expansion planning |
| Support / inquiry emails | 6 months from resolution | Quality assurance |
When the retention period expires, we will delete or anonymize personal data in a manner that makes re-identification impossible. You may request earlier deletion at any time (see Section 8).
As a data subject under the Philippine Data Privacy Act of 2016, you have the following rights. To exercise any of these, please email us at compliance@fluffyn.ph with your full name and the nature of your request. We will respond within 15 business days.
You have the right to know that your personal data is being collected, the purposes for collection, and your rights as a data subject. This Privacy Policy fulfills that obligation.
You have the right to request a copy of the personal information we hold about you, including how it has been processed.
You have the right to request correction of any inaccurate or incomplete personal information we hold about you.
You have the right to request deletion of your personal information when it is no longer necessary for the purposes collected, when you withdraw consent, or when it has been unlawfully processed. Requests will be fulfilled within 15 business days, subject to our legal obligations to retain certain records.
You have the right to object to the processing of your personal data for purposes other than those you originally consented to.
You have the right to obtain a copy of your personal information in a structured, commonly used, and machine-readable format.
If you believe your data privacy rights have been violated, you may file a complaint with the National Privacy Commission (NPC):
National Privacy Commission
3F Core G, DICT Building, C.P. Garcia Ave., Diliman, Quezon City
Email: complaints@privacy.gov.ph
Website: privacy.gov.ph ↗
Our services are intended for adults who are at least 18 years of age. We do not knowingly collect personal information from individuals under 18. If you believe a minor has submitted personal information to us, please contact us immediately and we will delete that information promptly.
We may update this Privacy Policy from time to time as our services evolve or as required by law. When we make material changes, we will update the effective date at the top of this page and, where appropriate, notify existing customers by email.
Continued use of our website or services after changes are posted constitutes your acceptance of the updated policy. We encourage you to review this page periodically.
For any questions, requests, or concerns about this Privacy Policy or your personal data, please reach us at:
Fluffyn 168 Cleaning Inc.
UB 111 Paseo de Roxas Building, Legazpi Village, Barangay San Lorenzo, Makati City, Metro Manila, Philippines
We aim to respond to all data privacy requests within 15 business days as required under RA 10173.