MANILA, Philippines — Jollibee Foods Corp. and messaging platform Viber have been cleared by the National Privacy Commission (NPC) over their 2025 Christmas campaign, which triggered festive stickers automatically in private chats. The NPC announced on Tuesday that its investigation found no violation of the Data Privacy Act.
The probe, initiated in January following public complaints, examined the 'Holiday Gems Christmas Campaign' that ran on Viber. The campaign caused branded stickers reading 'Have a Jolly Christmas!' with the Jollibee logo to appear when users typed the word 'Christmas' in conversations.
The NPC's Complaints and Investigation Division determined that the campaign operated through 'contextual, on-device matching mechanisms using predefined keywords stored locally within the application.' This meant animated visuals were deployed at the device level without sending message content to external servers for keyword detection.
'Furthermore, the investigation confirmed that campaign delivery parameters were based on country codes rather than geographic tagging or user location data,' the commission added.
Had the campaign involved personal data processing, the NPC would have assessed compliance with the Data Privacy Act of 2012, particularly regarding direct marketing. However, the investigation found 'insufficient indicators of personal information processing.'
The NPC commended public vigilance and urged continued reporting of suspicious data processing activities to protect personal information.