The National Privacy Commission (NPC) has taken notice of media reports and user complaints about the “Buo ang Saya ng Pasko” Christmas campaign of Jollibee Foods Corp. on the messaging platform Viber, citing concerns over how branded content appeared inside private chats.

The commission said branded marketing materials, including automated greetings and digital stickers, appeared within private chat interfaces, raising questions about the limits of digital marketing and whether personal data may have been processed without consent.

The National Privacy Commission has asked both Jollibee and Viber to explain how the campaign was carried out. The commission is now determining whether the campaign involved the processing of personal data under the Data Privacy Act of 2012.

Under the law, personal information controllers must ensure that any processing of personal data for direct marketing follows the principles of transparency, legitimate purpose, and proportionality.

The commission said that if the campaign involved personal data processing, consent must be specific and freely given. Data subjects must also be given the right to object to the use of their information for direct marketing.

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