Privacy Policy

Valleys & Bytes โ€” transparent by design, secure by default.
๐Ÿ“… __version__ = "2026.2.26" ยท build 3.1

def scope_approach():

This privacy statement applies to all services, websites and products of Valleys & Bytes where this document is referenced. We process your personal data in a lawful, fair and minimised way โ€” designed to protect your rights while delivering intelligent functionality.

I act as a data controller for the information collected from you. This policy is governed by the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. For questions or to exercise your rights, see the Contact section at the bottom of this page.

๐Ÿ“‹ RA 10173 โ€” Data Privacy Act of 2012 ๐Ÿ“‹ RA 8792 โ€” E-Commerce Act ๐Ÿ“‹ RA 10175 โ€” Cybercrime Prevention Act

class DataCollection:

I collect only what is necessary for the purposes described. The categories below reflect our current data map โ€” intelligent by design, not by excess.

๐Ÿ“‡ Identity & contact

Name, email, phone, organisation โ€” to communicate, authenticate and provide support.

retention: 24 mo

โš™๏ธ Usage & device

IP address, browser data, session interactions, anonymised analytics to improve our services.

retention: 13 mo

๐Ÿ’ณ Payment / billing

Billing address, transaction ID โ€” never raw payment details, processed by PCI-DSS compliant partners.

retention: 7 yrs (legal)

๐Ÿ“ฌ Communications

Records of correspondence, preferences, and opt-in choices โ€” to respect your inbox.

retention: active + 2y

def sensitive_data():

I do not request or process sensitive personal data (racial origin, political opinions, health, biometrics) unless you voluntarily provide it within a support ticket โ€” in which case we ask you to avoid sharing it, and if received, we will delete or anonymise it within 7 days in accordance with RA 10173 Section 13.

Under the Philippines Data Privacy Act of 2012 and its Implementing Rules and Regulations, we rely on the following criteria for lawful processing:

def data_sharing():

I do not sell your personal data. We share only with trusted subprocessors under strict data processing agreements. Categories of recipients:

๐ŸŒ international_transfers: Data may be processed outside the Philippines but always under National Privacy Commission (NPC) guidelines, contractual safeguards, or equivalent protections. You may request a copy of the applicable transfer mechanism by contacting us.

subprocessors = [...]

Full transparency: below is our current list of third-party subprocessors. All are bound by a Data Processing Agreement (DPA) and must meet our security and privacy standards. We update this list whenever a subprocessor is added or removed.

Processor Purpose Country Safeguard
Amazon Web Services Cloud hosting, storage, compute Singapore / Sydney NPC-aligned DPA
Zendesk Customer support ticketing United States Contractual Safeguards
SendGrid (Twilio) Transactional & marketing email United States Contractual Safeguards
Stripe Payment processing (PCI-DSS L1) United States Contractual Safeguards
Plausible Analytics Privacy-first web analytics (self-hosted) Philippines (self-hosted) Local Instance
PagerDuty Incident response & on-call alerting United States Contractual Safeguards
1Password Secrets & credential management Canada DPA + Encryption

Last reviewed: 26 Feb 2026. To be notified of subprocessor changes, contact us via the Contact section.

class AIDecisionMaking:

I believe in explainable, human-supervised AI. This section details how automated processing and profiling operates within our platform โ€” and where humans always remain in the loop.

๐Ÿค– Anomaly detection

Automated signals flag unusual login patterns or potential fraud. No account is suspended solely by algorithm โ€” a human agent reviews all flags.

โœ“ Human review

๐Ÿ“Š Usage personalisation

Feature recommendations are generated from aggregated usage patterns, not individual profiling. You can opt out in account settings.

โœ“ Opt-out available

๐Ÿ” Content classification

Automated classifiers scan uploaded content for policy violations. Decisions triggering access restrictions are always reviewed by a human within 24 h.

โœ“ 24 h review SLA

๐Ÿงฎ Pricing models

Subscription tier recommendations use usage volume only. No profiling based on demographics, location, or identity attributes is used for pricing.

โœ“ No demographic data

โš–๏ธ RA 10173 โ€” Automated Decision Rights: You have the right to object to decisions made solely on the basis of automated processing that significantly affect you. Contact us and we will conduct a manual review within 5 business days.

class YourRights:

Under the Philippines Data Privacy Act of 2012 (RA 10173), you have the following rights as a data subject:

To exercise your rights, use the contact details in the Contact section. We respond within 15 business days as required under RA 10173.

def response_timeline():

Day 0 โ€” Request received
I send an acknowledgement and begin identity verification. No unnecessary hoops required.
Day 1โ€“3 โ€” Identity confirmed
I verify your identity using information already on file. We may ask one clarifying question for complex requests.
Day 3โ€“12 โ€” Processing
My page locates, retrieves, or acts on relevant records. You will receive interim updates for complex requests.
Day 12โ€“15 โ€” Response delivered
I deliver the outcome in plain language with supporting documentation. If we cannot comply, we explain why and outline your next steps.

I use cookies and local storage to make our sites work, analyse traffic, and personalise content. You can manage your preferences using the panel below. Categories:

cookie_preferences.update()

def privacy_by_design():

Privacy is not an afterthought โ€” it is baked into our engineering and organisational culture from day one. Below are the concrete technical and organisational measures (TOMs) we operate.

๐Ÿ” Encryption everywhere

TLS 1.3 in transit. AES-256 at rest. Keys managed with annual rotation and per-key access auditing.

FIPS 140-2

๐Ÿ—๏ธ Zero-trust architecture

No implicit trust for any internal service. Every request is authenticated, authorised, and logged โ€” regardless of network origin.

mTLS + SPIFFE

๐Ÿ” Least privilege access

Customer data is accessed only via audited, time-limited procedures. All access is logged and reviewed quarterly.

SOC 2 Type II

๐Ÿงช Pen tests & DAST

Annual third-party penetration tests plus continuous Dynamic Application Security Testing. Critical findings are patched within 48 h.

OWASP Top 10

๐Ÿ—‘๏ธ Automated deletion

My data lifecycle engine auto-deletes or pseudonymises records when retention windows close โ€” no manual intervention required.

Cron-verified

๐Ÿ“‹ Privacy impact reviews

Every new feature or vendor that touches personal data undergoes a Privacy Impact Assessment (PIA) before release, per NPC guidelines.

NPC PIA

def breach_response_sla():

I operate a documented incident response plan. In the event of a personal data breach:

0โ€“1 h โ€” Triage
On-call engineer assesses scope and severity using our pre-defined playbook.
1โ€“24 h โ€” Containment
Affected services isolated, evidence preserved. Data Privacy Officer briefed. Legal counsel engaged if required.
24โ€“72 h โ€” Notification
If notifiable, the National Privacy Commission (NPC) is informed within 72 h of awareness per NPC Circular 16-03. Affected individuals notified without undue delay.
Post-incident โ€” Remediation
Root-cause analysis completed within 14 days. Corrective measures implemented and transparency report updated if significant.

class SecurityProtocol:

I apply modern cryptographic controls (TLS 1.3, AES-256 at rest), regular access audits, and penetration tests. Our retention policy deletes or anonymises data when the purpose ends โ€” unless Philippine law requires longer retention.

In the event of a notifiable breach, we will inform affected individuals and the NPC within 72 h as required by NPC Circular 16-03. See the Privacy by Design section above for the full SLA.

A+
SSL Labs Rating
TLS 1.3 only, HSTS preloaded
99.9%
Uptime SLA
Multi-region failover
48 h
Critical patch SLA
OWASP Critical severity
0
Data sales
We never sell personal data

class PrivacySnapshot: # tl;dr

Too long to read right now? Here's the short version โ€” tap any question to expand.

def children_privacy():

My services are not directed to individuals under 18 years of age. Under Philippine law, minors cannot give valid consent to data processing without parental or guardian authority. If we become aware that we have collected data from a minor without verifiable parental consent, we will delete it promptly โ€” typically within 48 hours of discovery โ€” and notify the NPC if required. Parents or guardians may contact us via the Contact section to request deletion.

def policy_updates():

I may revise this page to reflect legal or product changes. Material updates will be notified via email or prominent website notice at least 14 days before they take effect. The __version__ date at the top reflects the latest revision. We keep an archived changelog of past versions โ€” request it from us via the Contact section.

class Contact:

If you have any concerns, wish to exercise your data subject rights, or need to speak with our Data Privacy Officer, reach out through any of the following channels. We aim to respond within 15 business days.

๐ŸŒ
website
๐Ÿ“ฎ
postal address
CODE SENSE
Tinongtongan, Diplahan
Zamboanga Sibugay Province
Philippines
๐Ÿ›๏ธ
supervisory authority

โšก try: intelligent_design() except: transparency โ€” This notice is governed by the Philippines Data Privacy Act of 2012 (RA 10173). I am committed to protecting your personal information as a fundamental right. We minimise collection at the source โ€” the best privacy control is one you never had to grant in the first place. If anything here is unclear, contact us and we will always respond.

โ†‘