Privacy Notice

Preamble

This Privacy Notice applies to both the StudyBooster (www.studybooster.ph) and COLPUNO (www.colpuno.com) platforms, which are operated by ProCare International AG (“ProCare”; "we/us/our"). By registering with StudyBooster, users automatically create a single sign-on account that also establishes their registration with COLPUNO. As a result, users gain access to the features and services of both platforms under one unified account.

Accordingly, all provisions of this Privacy Notice shall apply equally to activities and processing operations carried out on COLPUNO. This ensures that the rights and obligations described herein extend consistently across both platforms, given that they form part of the same integrated service offering of ProCare International AG.

Privacy Statement

Data protection and data security are important to ProCare. Upholding the fundamental right to privacy for all individuals whose personal data we process is our priority. Thus, it is our commitment to employ reasonable and appropriate security measures to ensure the confidentiality, integrity, and availability of the personal data entrusted to us. Our aim is to ensure that all personal data is handled with utmost care, transparency, and integrity.

What is in this Privacy Notice

In this Privacy Notice, we inform you about how we collect and process your personal data when you visit our website www.studybooster.ph or www.colpuno.com ("Websites") or social media pages, contact us or use our Services.

This Privacy Notice does not cover the practices of companies we do not own or control or people we do not manage and this Privacy Notice does not apply to any third-party sites that may link to or be accessible from our Sites.

We collect, use, store, share, and protect ("process") your personal and sensitive personal information (collectively "personal data") in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other relevant issuances by the National Privacy Commission (NPC) and other applicable laws (data protection laws).

Insofar as we use certain terms in this Privacy Notice, such as 'personal information', 'sensitive personal information', 'personal data' and 'process', these are used synonymously with the specific terms of the applicable data protection laws.

Table of Contents

Personal data we collect and process

When you avail of our Services, we collect the following personal data:

  • Your personal identifiers such as: full name, address, country location and region, mobile number, email, social media profile link, language spoken, copy of your CV/resume which you submit to us as part of your profile.
  • Your sensitive personal information such as: date of birth, gender, nationality.
  • Work experience such as: current nurse carrer status, job title, company name, company country and region, start and end date, job description
  • Job preference: position applied, job seeking status, preferred location, area of interest, preferred start date, employment type, shift type, benefits.
  • Qualification: title, type of license, country issued, start and end date, copy of license or certification, and description: passing rate, date of passing, license number
  • Educational background such as: school, course, year you graduate.
  • Your personality test response and result using the the tool based questionnaires during your self-assessments (hereinafter collectively referred to as "Self-Assessment Tools").
  • Personal data that we receive from third parties that we receive in correspondence with you, members of COLPUNO/StudyBooster, suppliers or other business partners, e.g. your name and details of your activity as an employee with the respective Employer / candidate of the respective recruiter / job agency.
  • Other personal data that you or other users enter, upload, generate, store and process when using COLPUNO/StudyBooster.

We collect personal data when:

  • you contact us for any inquries or request for assistance;
  • you provide us with personal data of third parties (e.g., references or recommendation contacts), by doing so, you confirm and provide that such data is accurate and you adhere to and obtained the personal data in compliance with applicable data protection laws and where necessary, you have obtained their consent to share this information with us;
  • you set up your profile in COLPUNO and upload your CV or resume;
  • you enter the Website to browse and check for Job opportunitie, use features related to career support or register to COLPUNO/StudyBooster, or contact a matching Employer via our Website; or
  • to the extent necessary to achieve the purposes described in this Privacy Notice, we collect general personal data from publicly accessible registers, websites or platforms (e.g. publicly available information about your institution (hospital / company) or by obtaining information from third parties, for reference purposes in the application process, if you consent to this.

Use of our Websites and Online Platforms

Use for information

You can find out about ProCare and our range of Services on the Website without telling us who you are if you do not register with COLPUNO/StudyBooster.

As with any connection to a web server, the server on which we have the Website or COLPUNO/StudyBooster automatically provides logs and stores certain technical data for a short time. This includes the IP address and operating system of your device, the date and time of use, and the type of browser you use to access the Websites or COLPUNO/StudyBooster.

Use of cookies

We use cookies, tags, and similar technologies on the Website to provide you with the best possible user experience and to help us improve the Website. Cookies are text files that are downloaded to your computer or mobile device when you visit a website or use an app.

Some of the cookies we use are necessary to provide certain functions or content of the Website (e.g. the integration of videos or map functions). In addition, we use cookies to enable the analysis of the use of the Website, the optimization of our Services and the use of advertising technologies.

You can instruct your browser not to accept cookies or to prompt you each time before a cookie is set. You can also delete cookies on your device by using the corresponding function of your browser.

In addition, you have the option of informing us of your preferences regarding the acceptance of cookies via the Cookie Preferences tool used on the Website.

Use of our social media pages

On our company pages in social media you will find posts about current developments at COLPUNO/StudyBooster as well as our range of services.

The social media providers collect and analyze usage data such as the number of visitors and demographic information about the visitors to our social media pages. We receive evaluations from the social media providers based on this data. These contain only aggregated or otherwise sufficiently anonymized data. Only the respective provider can identify you based on the usage data collected. Therefore, please observe the data protection information of the respective provider.

Use and optimization of our newsletters

When you sign up for our newsletter we collect the information you provide to us. This includes general personal data such as first name, last name and email address.

We use analytics services to measure and analyze the use of our newsletter. The analytics services collect and analyze usage data such as the number of newsletter recipients who have opened the newsletter or clicked on certain articles. We receive evaluations based on this data. These allow us to optimize our newsletter and provide you with content that interests you.

You can inform us at any time that you do not wish to receive our newsletter in the future. Please use the unsubscribe link at the end of the newsletter.

Our purpose for processing your personal data

We only collect the personal data reasonably necessary to provide our Services, to carry out our operations, as required by law, and for the other legitimate business purposes, under applicable laws.

For the provision of our Services:

  • To facilitate the use of the COLPUNO/StudyBooster, to maintain and administer your account, to continuously provide you with our Services through your use of the COLPUNO/StudyBooster, which includes sending notices and other documents necessary for the continued use of COLPUNO/StudyBooster and for other purposes that would be necessary or beneficial to administer your use of the same ("Servicing").
  • To respond to your queries, comments, feedback, or requests and address your complaints and provide customer support or to communicate with you for the purpose of providing our Services. ("Servicing").
  • To verify or ascertain your identity, uniquely identify you and identify potentially fraudulent activity ("Fraud Prevention").
  • To conduct research and gain an understanding of the users of COLPUNO/StudyBooster, their experiences and preferences to further improve COLPUNO/StudyBooster ("Quality Improvement").
  • To assist in business development, compile statistics regarding how COLPUNO/StudyBooster or our Service is used in order to improve our them, for example, we may use your personal data to improve the layout of our Website based on the click path you utilized to access certain information within the Website ("Quality Improvement").
  • To run system diagnostics to ensure that COLPUNO/StudyBooster is functioning properly and to improve the user experience ("Quality Improvement").
  • To detect or prevent security incidents or other illegal activity, debug, verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us ("Security").

For our marketing and advertising activities ("Marketing"):

  • To communicate with you regarding Services, activities, programs, trainings, promotions or other offers in which you have indicated an interest or to which you've subscribed.
  • To provide information we think you may find useful, may be interested with, or which you have requested from us such as information about new developments and about new services
  • To personalize your experience and allow us to deliver individualized content and product offerings according to your specific interests.
  • To provide you with the marketing materials of third parties which we think may interest you.
  • To optimize our posts on our company pages in social media
  • To organize and carry out events in which you participate.

For compliance with our legal obligations, regulatory requirements and for other legal purposes ("Legal"):

  • To process any complaints, implement preventive measures and to investigate act, omission, or misconduct that would constitute a violation of our contracts and of the applicable laws.
  • To verify your identity or conduct internal audits or reviews.
  • To enforce our Terms & Conditions and other agreements.
  • To gather the necessary information required by law, record keeping and good business practices.
  • To comply with our legal obligations and other regulatory requirements.
  • To protect our lawful rights and interests in court proceedings and to establish, exercise or as defense from legal claims.

If you register with COLPUNO/StudyBooster we use technology to optimize your search results and thereby the outcome of our Services.The technology helps us to evaluate your professional profile and yield distinct features of your skills and expertise.We then use the results of the Self-Assessment Tools as prompts we submit to an automated AI based matchmaking with Artificial Intelligence such as ChatGPT ("AI technology / service") for identification of your distinct qualifications and preferences based on which we then provide the matchmaking between Nurses and Employers.

If you upload any files such as your CV/resume for the purpose of assessment directly via ChatGPT any personal data and information contained in your CV/resume will be processed for identification of your distinct qualifications and preferences by such automated AI.

Our lawful basis for processing how we store and protect your personal data

We store your personal data only to the extent and for as long as necessary to fulfill the purposes described in this Privacy Notice or to comply with legal obligations.

Once it is ascertained that the retention is no longer necessary, we will securely dispose your personal data in accordance with our internal procedure such as shredding the physical records, deletion or purging of electronic data including its backups, and through such other means that would prevent further processing.

In the interest of the integrity, availability and confidentiality of personal data, we take appropriate physical, technical and organizational security measures. While we cannot guarantee the absolute security and impenetrability of our database, we take all the necessary measures, according to reasonable industry standards and practices to keep your data safe through the establishment of security controls, such as, but not limited to:

  • We implement data privacy and protection policies to provide standards and guidelines on how we handle personal data we process with procedures for regular review to assess, and evaluate the effectiveness of the measures in accordance with our risk assessment.
  • We ensure that our data processing systems are secured against unauthorized access through regularly review, monitoring and testing to ensure that the security and integrity of the system is not compromised.
  • We regularly monitor security incidents and implement process for taking appropriate preventive, corrective and mitigating action.
  • Ensuring physical security measure where records are stored in a secure storage facility/data center through physical and logical access controls.
  • We ensure that our employees, agents, vendors and anyone who is involved in the processing of your personal data shall operate under strict confidentiality.

Place of processing

We store and process your personal data on our Amazon servers in Singapore.

However, we may also transfer your personal data to recipients in countries outside Philippines – e.g. US-based providers such as OpenAI, Google, Meta. When transferring data to countries that do not provide an adequate level of data protection, we apply appropriate safeguards, including recommended contractual clauses, or rely on legally recognized exceptions, such as the necessity for the performance of a contract.

To whom we disclose your personal data

In order to achieve the purposes described in this Privacy Notice, it may be necessary for us to disclose your personal data to third parties. These are the following categories of recipients:

  • Employers you are matched with.
  • Third-party service providers engaged by us who may process personal data on our behalf as a result of the service they perform. These service providers will only process your personal data upon our instructions:
    • Hosting, cloud, and IT service providers;
    • Providers of AI technology / services such as OpenAI (ChatGPT);
    • Marketing service providers (e.g., Google Ads, Meta/Facebook); and
    • Third-party providers of web and analytics technologies.
  • To law enforcement agencies, government authorities, or other third parties if we believe your actions are inconsistent with our policies, or if we believe there is a need to protect the rights, property, or safety of the public and of Procare.
  • To competent supervisory or tax authorities as required by law or to comply with our legal obligations.
  • Strategic partners for professional qualification or placement support.

Rest assured that, in sharing your personal data, we will ensure that your rights as a data subject are protected and respected. We will only share your personal data upon your consent, when necessary, or when allowed by or in accordance with the data prection laws. We ensure the personal data being shared to the above listed recipients is not excessive in relation to the declared and specified purpose.

Your rights in relation to your personal data

You have the following rights in relation to personal data relating to you:

  • the right to be informed about the collection and use of your personal data, including the purpose, scope, and method of processing;
  • the right to access the personal data we hold about you and obtain information on how it is being processed;
  • the right object to the processing of your personal data, particularly in cases of direct marketing, automated processing, or profiling;
  • the right to have your personal data corrected if it is inaccurate or outdated;
  • the right to have your personal data deleted or blocked if it is incomplete, irrelevant, excessive, unlawfully obtained, or no longer necessary for the purposes it was collected;
  • the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another personal information controller, where technically feasible;
  • the right to be indemnified for any damages sustained due to the misuse, unauthorized use, or inaccurate processing of your personal data;
  • the right to lodge a complaint with the proper data protection authority if you believe your rights have been violated
  • the right to be informed promptly in the event of a data breach that may pose a serious risk to your rights and freedoms

Please note that legal requirements and exceptions apply to these rights. To the extent permitted by law, we may refuse your request to exercise these rights.

If you want to exercise any of your data subject rights, please email our Data Protection Officer at: dpo@colpuno.com

In accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and fair processing practices, appropriate consent forms will be provided to individuals whose personal data is collected and processed through our Services. The Consent Forms will be provided in Addendum 1 of this Privacy Notice. By using our platform or engaging with our offerings, users will be asked to read and accept a dedicated Consent Form outlining the specific purposes for which their personal data is being collected, how it will be used or disclosed, and their rights under the law. These consent forms are designed to promote transparency and empower you to make informed choices regarding your data. By agreeing to this Privacy Notice I declare that I have read, understood and agree to the provided Consent Form(s) in Addendum 1.

Controller of the data processing

ProCare is the controller of the data processing described in this Privacy Notice.

If you have any questions or would like to exercise your statutory data protection rights, please contact our Data Protection Officer.

Registration of Data Processing Systems

This is to certify that the data processing systems, particularly those that involve the personal data of Filipino citizens and residents, are duly registered with the National Privacy Commission.

NPC Seal of Registration

Designation of a Data Protection Officer

ProCare has designated a Data Protection Officer (DPO) responsible for ensuring that your personal data is handled in accordance with applicable data protection laws. The DPO oversees our data processing activities and serves as the point of contact for all data privacy-related concerns. If you have any questions about how your personal data is processed or wish to exercise your rights under this Privacy Notice, you may contact our DPO at the contact details provided below.

dpo@colpuno.com
+41 41 244 07 07
ProCare International Ltd. Baarerstrasse 95, 6300 Zug, Switzerland.

Changes to this Privacy Notice

We may change this Privacy Notice at any time, especially if we change our data processing practices or if new legislation becomes applicable. The version provided on the Website StudyBooster and COLPUNO applies. Any such changes will be posted on our Websites.

Version Date: 27. August 2025
Version No.: 1.0

ADDENDUM 1

Consent Form

I have read and understood ProCare International AG's (hereinafter referred to as the "Company") Privacy Notice and voluntarily provide my informed consent for the Company to collect, process, and store my personal data for the purposes described therein. These purposes include enabling my participation in the COLPUNO and StudyBooster platform and its related community features, verifying my identity and qualifications for matching with potential Employers, and using my data to support communication, career development, fraud prevention, legal compliance, and other operational or contractual purposes relevant to the services provided by the Company.

I understand that my personal data may include, but is not limited to, my name, contact details, professional and educational background, nationality, immigration status, and any additional information I provide as part of my resume, online profile, or self-assessment submissions. I acknowledge that my data may be processed through automated technologies, including AI tools such as ChatGPT, to support personalized matchmaking with prospective Employers and improve service outcomes.

I consent to the transfer and disclosure of my personal data to authorized third parties, including prospective Employers, licensed recruitment agencies, cloud hosting providers, analytics platforms, AI service providers, and regulatory authorities, whether located in the Philippines or abroad. I understand that when my data is transferred to countries that may not offer an adequate level of data protection, the Company ensures the use of appropriate safeguards, such as Standard Contractual Clauses, or relies on legally recognized exceptions in accordance with applicable laws.

I am aware of my rights under Republic Act No. 10173 or the Data Privacy Act of 2012, including the right to be informed, to access and correct my personal data, to object to or restrict its processing, to request deletion or data portability, to be indemnified in case of misuse, and to be notified of any data breach that may pose a risk to my rights and freedoms. I also have the right to lodge a complaint with the National Privacy Commission should I believe that my data privacy rights have been violated.

Should I have any concerns or wish to exercise my data privacy rights, I may contact the Company's Data Protection Officer at:

dpo@colpuno.com
+41 41 244 07 07

By agreeing to this Privacy Notice I declare that I have read and understood this document and that the Consent Form is given freely, voluntarily, and with full knowledge of my rights under the law.