The National Privacy Commission said it is investigating complaints on a holiday marketing campaign by Jollibee Foods Corp. after users reported receiving unsolicited branded greetings and digital stickers within private Viber chats.
The “Buo ang Saya ng Pasko” campaign, which included an emotional brand film and nationwide activations, was designed to deepen customer engagement across digital and physical channels.
The appearance of automated festive greetings and stickers in one-on-one and group messaging interfaces prompted a backlash from users who described the content as an intrusion into personal spaces.
Critics and business leaders said the placement of brand content in private messaging transcends conventional advertising and violates user expectations of privacy.
The privacy regulator said it sought formal explanations from Jollibee and the platform provider to determine if the campaign implementation involved the processing of personal data under the Data Privacy Act of 2012.
Under the law, personal information controllers must ensure all data processing for direct marketing is anchored in transparency, legitimate purpose and proportionality.
If the campaign utilized personal data, the company should prove that consent was specific and freely given, while ensuring subjects had the right to object to such marketing.
National Privacy Commission officials said individuals who believe their rights were violated by the Viber campaign may file formal complaints under the existing legal framework.
Jollibee has not yet issued a public statement on the specific technical mechanisms used to deliver the stickers within the messaging app.
