All information stored in the CashPapa Finance Inc. website, mobile application, or other related digital medium or media (individually and collectively the “Site”) has been designed in the same degree and in line with the laws of the Republic of the Philippines, and is for the sole utilisation of CashPapa Finance Inc. (the “Organization” or “CashPapa”), its relegates, members and related organizations in the lead of its business in the Philippines.
This Statement of Policy constitutes the approaches laid out by the company, its relegates, members and related organizations in connection to any forms of individual personalised data, as characterized under Republic Act No. 10173, also known as the Data Privacy Act of 2012 (hereinafter referred to as the “Information Privacy Act”), which may be given to individuals, regardless of whether as planned lenders or borrowers (the “Client” or “Clients”), for the gathering and utilization of the Organization, its relegates, members and related organizations, whereby the identity of the individual might be obvious or can be sensibly and easily found out.
The Organization esteems the protection of its Clients and any client and guest of the Site. The Organization is focused and strives for the safeguarding of any and all personalised data which might be given by its Clients or any Site guest.
INDIVIDUAL DATA GATHERED AND PROCESSED
At any point when a Client makes or enrols an account in the Organization’s Site, or utilises the Organization’s digital channel or programs, or when the lenders and borrowers go into an agreement, or when a Client draws in the administrations of the Organization, the Organization may gather the accompanying individual data (thereafter alluded to as “Individual Data”):
- Complete name, permanent and housing address, contact number/s, email address, date of birth and/or age, occupational information, bank account details, credit card information and/or financial records, financial history, past transactions, history of acquisition and government identification details
- Other data from which the Client’s personality may not be evident or which may not be sensibly or easily found out, for instance, but not restricted to accounts of visits and data provided by the Client when utilising the Site
- Data from third parties including data acquired, upon Client’s approval, from Client’s employers, previous and present (“Employment Details”), and transaction, financial and loan history, previous or present, acquired by third parties (“Transaction and Loan History”) in accordance with the Client’s Authorization appropriately highlighted and confirmed by the Client; and
- Traffic and Client data created from the Client’s visits and utilization of the Site. The Personal Information may be gathered through different methods including: cookies, flash cookies, general log information, Client browsing habits, Client searches and exchanges and other third-party data.
The Individual Data might be collected for the benefit of the Organization by individual data processors, in each situation aware of your privileges and our commitments under the Data Privacy Act of 2012.
The Personal Data shall be retrieved, reviewed, utilised, made open, saved and kept for the aforementioned uses:
- to distinguish Clients;
- to get in touch with Clients with regards to their registered account/s or
- to undertake registration of account/s as part of the course of monitoring the lenders, borrowers and loan applications;
- to upkeep internal records
- to go about digital advertising and marketing efforts with regards to the Organization, offers from members of the CashPapa Finance Inc., CashPapa’s associates, and CashPapa’s goods and services, whether by digital means, by email and post, or by phone, SMS or social media, or by broadcasting publications (for instance, for the Clients to keep abreast on new goods and features and to highlight events, contests, displays, rewards program, and other efforts organised by CashPapa), also by using digital means. Such transmissions are in relation to goods and features of the financial goods, features and other similar things. Moreover, CashPapa will review your data to conduct market research, statistical analyses or any other examination to enhance their goods, and overall customer satisfaction
- to keep track of Client behaviour, coming up with Client or credit score, or for Client profiling (e.g. with regards to funding goods available, given, seen and sought) for the purpose of providing suitable and beneficial services to lenders and borrowers; and
- to come up with a credit score, credit profile and Client model
DIVULGEMENT OF PERSONAL DATA
Your Personal Data might be given to CashPapa Finance Inc. in line with its business needs for evaluation which may likewise be needed during the enhancement and execution of its business activities and in the enhancement of its roles and obligations within the Site, in line with appropriate laws, rules and regulations. The CashPapa Finance Inc. may, whenever needed, be involved by CashPapa as subcontractors or data processors in any event with regards to the reasons listed above.
As a lender, your Personal Data may be exchanged with borrowers in the site.
As a borrower, your Personal Data will be exchanged with the lenders in the site to facilitate lenders to determine your credit history and credit score. Your data may also be exchanged with third party buyers of any Non-Performing Loans.
The Personal Data of a Client will likewise be exchanged with third parties (e.g. debt agents and financial institutions) who are called upon, utilized or is otherwise permitted by either the lender or borrower to render any service or help with regards to transactions exchanged between the lender and borrower.
The Personal Data of a Client may be exchanged and made known to the following: (a) CashPapa Finance Inc. and their members and affiliated agents (comprising collection agencies), and subcontractors, which are vital to the running of CashPapa’s business; (b) The lenders with regards to Personal Data of Borrowers, and the borrowers with regards to Personal Data of the lenders; (c) third party providers who need the data in order to process the loan, especially but not restricted to the payment, remittance, credit check (credit offices, service providers, administration history, bank history, financial history, spending history, among other things), background checking or processing of the borrower’s loan, payment to the lender, lender or borrower’s agent, transfer of the loan to a third party (i.e. funding corporation, new lender, monetary authority); (d) government, regulatory authorities, and pre-credit fraud agencies for the motivations behind recognizing, anticipating, identifying or handling misrepresentation, tax evasion, or different violations, and for other legitimate purposes; and (e) other agencies as might be legally necessary or as public interest may require.
All information preparing, subcontracting or information sharing understandings will be as per the conditions under the Data Privacy Act of 2012, or relevant laws and guidelines as might be in the future passed and executed. To the degree that such handling, subcontracting, or information sharing requires notice or assent, we will give or demand to such see as well as assent, for each situation, before any preparing or sharing of your Personal Data.
WITHHOLDING OF YOUR PERSONAL DATA
The Personal Data will be held by the Organization throughout the term of your operations and exchanges regarding the goods and services made available of/in this Site and/or for such timeframe required for lawful and administrative purposes, and will be discarded in a safe way that would hinder further handling, unapproved access or revelation to any other party or the public at large or discriminate your advantage, given that the Organization may hold duplicates of your Personal Data in the Organization’s records in order to establish its proceeding with commitments under this Agreement or in accordance with its bona fide retention or information back-up approaches, access to which will be confined on a need-to-know premise, as might be required under appropriate laws and guidelines.
SAFETY OF YOUR PERSONAL DATA
The Organization holds with high regard, the Personal Data retrieved, utilised, kept and saved within its Site, and assures that it is safeguarded from potential dangers, both online and offline. The Organization has the relevant professional, specialized and physical measures to make certain that the Personal Data remains safe and protected, along with avoiding unauthorized access or revealing of the retrieved and saved Personal Data.
ACCESS AND AMENDMENTS OF PERSONAL DATA
In the event that you wish to practice your rights to access, correct or cancel any of the rights as mentioned below, or for feedback and other suggestions, kindly send a registered letter with return receipt to Unit 1802 Cityland PASONG Tamo Tower 2210 Chino Roces Ave. Makati City or email email@example.com to the attention of Data Privacy Officer.
- to obtain information of the data source, the reasons and strategies for the handling, the rationale applied to the handling, or if the latter is implemented by the assistance of electronic means, of the identity of information controller and information processors, the elements or clauses to which the information may be made known and which may be mindful of the data;
- to refresh, rectify, complement or eliminate the data, to obstruct or provide anonymous information that have been reviewed unlawfully, including information whose withholding is unnecessary for the for the reason for which such information have been gathered or subsequently reviewed; to have a confirmation that the activities mentioned have been concluded, as likewise identified with their contents, to the agencies to which the information is made known, provided that this prerequisite renders itself impossible or includes an obviously unbalanced effort in contrast to the right to be protected; to obtain the personal information regarding you and duplicate or transmit it to another information controller (right to information portability); and
- to oppose, on genuine grounds, to the handling of information, regardless of the information being related to the reasons for which they were gathered or to disapprove, likewise partially (e.g. in connection to certain correspondence means), to the information being handled so as to send publicising materials or for direct sales, or market research, or business data, profiling purposes, or to get interchanges by conventional means only.
At the point when a Client or guest visits or potentially utilizes the Site, the Client or guest’s program/interface may send the Organization personal data which the Organization gathers for statistical and internal purposes for record keeping. The process of gathering this data is called “Log Data” and may incorporate data, for example, the computer’s Internet Protocol (IP) address, browser preference, browser version, search history, the time and date of visit, duration spent on the pages and other statistics.
A cookie is a tiny document which requests that authorization be put on the guest’s computer hard drive. Upon agreement of the guest, the document is included and the cookie helps to examine web traffic or offers usage data. A guest can customise his or her browser to deny all cookies or to show when a cookie is being sent. Nevertheless, if the guest does not allow cookies, the guest may be unable to utilize parts of the website. A cookie, does not, in any way provide the Organization entry to the guest’s computer or divulge any data pertaining to the guest, apart from the information the guest wishes to divulge with the Organization.
CONTROL OVER YOUR PERSONAL DATA
Guests still wield control over their Personal Data, and may alter their own data enlisted in the Site database.
The Client will be held accountable for up keeping the privacy of his or her own account details, along with all documentations delivered, responsibilities consented to or enrolled into along with all documents submitted, commitments consented to or registered into and every other activity that happens under the said account. The Client consents to promptly inform the Organization of any unapproved use or divulgement of the Client’s account or password, any unapproved activities within the Client’s account or any other security related offences.
The Organization will not be held accountable for any harm that the Client may face due to another party’s utilization of the Client’s account and password, regardless of whether it is with or without the Client’s consent, excluding the mistake or oversight with respect to the Organization. The Client may be held accountable for any harm or loss brought about by the Organization regarding or emerging from a third party’s utilization of the Client’s account or password, without issue or oversight with regards to the Organization.