Privacy Policy

Team Venus Elite Advisors (Pru Life UK — TUSLIA Branch) ("we," "us," or "our") operates the internal operations dashboard at ops.intentionalthrive.com (the "Dashboard"). This Privacy Policy explains what personal information we collect, how we use it, and how we protect it. By using the Dashboard or submitting information through any of our forms, you agree to the practices described here.

1. Information We Collect

We collect the following categories of personal information:

• Client policy data — name, policy number, plan type, coverage details, premium amounts, due dates, billing cycle, and mailing address sourced from PRISM Policy Information Reports.
• Contact information — email address, phone number, and birthday collected manually or provided by clients.
• Feedback submissions — satisfaction ratings, open-text responses, and optional name/session date submitted via the Policy Review Feedback form.
• Agent and team data — agent codes, names, Pru Life email addresses, production figures, and licensing details used for internal team management.
• Uploaded files — identity documents, proof of payment, and signed forms submitted through the New Business Follow-up and OTF email flows.
• Usage and activity logs — records of actions taken inside the Dashboard (e.g., logins, data syncs, email sends) for audit and accountability purposes.

2. How We Use Your Information

• Managing and servicing active insurance policies.
• Sending premium due reminders and policy review follow-ups.
• Processing New Business applications and OTF (Orphan Task Force) requests.
• Generating internal reports and tracking team production metrics.
• Improving the quality of client service through feedback analysis.
• Maintaining audit logs required for insurance regulatory compliance.

We do not sell, rent, or share personal information with third parties for marketing purposes.

3. Legal Basis for Processing (Philippines)

We process personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. Our lawful bases include:

• Contractual necessity — to fulfill obligations under insurance policies you hold with Pru Life UK.
• Legitimate interests — to manage team operations, prevent fraud, and maintain internal records.
• Consent — where you voluntarily submit feedback or contact information through our forms.

4. Data Storage and Security

• All data is stored in a Turso (libSQL) database hosted on encrypted infrastructure. Files are stored in Cloudflare R2 with private access controls.
• Access to the Dashboard requires authentication. Role-based access controls limit what each user can view or modify based on their role (Manager, Assistant, or Agent).
• All Dashboard traffic is encrypted in transit via HTTPS/TLS.
• Session tokens are encrypted using iron-session and are valid for 7 days.
• We maintain access and activity logs to detect and investigate unauthorized access.

5. Data Retention

We retain personal information for as long as the underlying insurance policy is active and for the period required by Pru Life UK compliance guidelines thereafter. Feedback submissions and activity logs are retained for a minimum of one (1) year. You may request deletion of your data at any time subject to legal and regulatory retention obligations.

6. Your Rights

Under the Data Privacy Act of 2012, you have the right to:

• Access — request a copy of the personal data we hold about you.
• Correction — request that inaccurate or incomplete data be corrected.
• Erasure — request deletion of your personal data, subject to legal requirements.
• Object — object to processing based on legitimate interests.
• Portability — receive your data in a structured, commonly used format.
• File a complaint — lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

7. Cookies and Session Storage

The Dashboard uses a single encrypted session cookie (ops-session) to authenticate logged-in users. This cookie does not track you across third-party sites. No analytics cookies, advertising cookies, or fingerprinting scripts are used.

8. Third-Party Services

We use the following third-party services to operate the Dashboard:

• Vercel — hosting and serverless functions (United States)
• Turso / libSQL — database storage
• Cloudflare R2 — file storage
• SMTP email provider — transactional email delivery

Each provider maintains their own security and privacy standards. We do not share personal data with these providers beyond what is required to deliver the service.

9. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page will reflect any changes. Continued use of the Dashboard after changes are posted constitutes acceptance of the updated policy.

10. Contact Us

For questions, data access requests, or complaints, contact us at: