SOFI FINANCING INC., its assigns, affiliates, and related companies conducting business in the Philippines (hereinafter referred to as the "Company") values the privacy of our Users. This Privacy Policy applies to any person who uses, accesses, downloads, browses, or registers for the Services via the peso flow website, its application, or other related digital media including social media (hereinafter referred to as the "Platform"), including prospective lenders or borrowers (hereinafter referred to as the "User", "you", or "Users") and visitors to the Platform.
This Privacy Policy is part of peso flow's commitment to respecting and protecting all personal data and information of individuals using the Platform. It is prepared in compliance with the laws of the Republic of the Philippines and is for the exclusive use of the Company. This Privacy Policy sets forth the policies of the Company, its assigns, affiliates, and related companies in relation to all types of Personal Data (as defined below) referred to herein, including sensitive personal information.
In this Privacy Policy, "Personal Data" means any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when combined with other information would directly and certainly identify an individual, as defined under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (hereinafter referred to as the "Data Privacy Act"). Personal Data may be provided by individual Users of the Platform for collection, use, and disclosure by the Company, its assigns, affiliates, and related companies.
All names and other Personal Data relating to Users shall be handled in the manner set out in this Privacy Policy. We only collect information where it is necessary to do so and only if it is relevant to our dealings with Users. We will retain Users' Personal Data only for as long as required by law or as relevant for the purposes for which the information was collected.
The scope of this Privacy Policy is limited to information collected or received by us through your use of the Platform. We are not responsible for the actions of third parties or companies, the contents of their platforms, the use of information you provide to them, the information they provide to you, or any products or services they may offer. Any link to such third-party sites does not constitute our partnership with, sponsorship, endorsement of, or affiliation with, those parties or companies or their brands.
By using the services provided by the Platform, whether via the website or application, you express your agreement to this Privacy Policy and the processing of your Personal Data in the manner provided herein. If you do not agree to these terms, please refrain from using and exit the Platform immediately.
Personal Information Collection Items and Collection Measures
We collect information to provide better services to Users and will not collect your personal data without your permission.
1.Information Provided by Users
>When registering as a member, we may collect the following information to provide personalized services:(1) Full name; (2) Email address; (3) Residential address; (4) Telephone number; (5) Emergency contacts; (6) Employment information; (7) Monthly income; (8) Date of birth; (9) Gender; (10) ID information; (11) Beneficiary's bank account information; (12) Facebook account name; (13) Urgency of Loan; (14) First Loan Year; (15) Current Total Debt; (16) Total Historical Loan Count; (17) Average Loan Amount; (18) On-time Repayment Rate; (19) Overdue Loans; (20) Have Credit Cards; (21) Social Security Status; (22) Have Bank Cards; (23) Phone Number Usage Duration; (24) Marital status; (25) Children; (26) Education; (27) Occupation Type; (28) Employer; (29) Work (Years); (30) Income Source.
2. Information Collected During the Use of Services
We collect information about the applications and devices you use to access the Platform's services to better provide you with services. The information and permissions we collect include:(1) Location (including android.permission.ACCESS_COARSE_LOCATION); (2) Contacts; (3) APP installed (QUERY_ALL_PACKAGES); (4) Camera; (5) Phone information; (6) com.google.android.gms.permission.AD_ID.
Objectives of Personal Information Collection and Its Legal Basis
1.LOCATION (including android.permission.ACCESS_COARSE_LOCATION)
We collect your geo-location information when the Platform is running in the foreground to auto-fill your address data. We endeavor to cease collecting your geo-location information when the Platform is in the background. You may at any time choose to temporarily disable geo-location tracking on your Mobile Device.
2.CONTACTS
We collect contact list information for risk assessment and identity verification, to safeguard the security of lending transactions and prevent fraudulent activities.
3.APP INSTALLED (QUERY_ALL_PACKAGES)
As a financial application, we need to collect information about the apps installed on your device to prevent fraud and protect the safety of your funds. This information will be used to assess your risk profile and recommend suitable financial products.
4. CAMERA
We request camera permission to provide you with a smooth user experience, enabling you to take photos of your KYC documents and other requisite documents and upload them to the Platform during your loan application process.
5.PHONE INFORMATION
Phone information includes device brand, model, operating system version, device unique identifier, device network environment, WiFi status, device status, International Mobile Equipment Identity (IMEI), International Mobile Subscriber Identity (IMSI), application software information, mobile phone number, and device memory information. Access to this information helps us build user portraits, analyze user preferences, and recommend suitable credit products for you.
6.AD_ID (com.google.android.gms.permission.AD_ID)
We request this permission to accurately analyze user needs, provide you with personalized recommendations for financial products and services, and optimize the Platform's advertising delivery strategy to enhance the effectiveness of marketing services. In compliance with Google Play policies, if you opt out of personalized advertising, we will only receive a string of zeros instead of the actual advertising identifier and will not use such data for personalized marketing activities.
Validity and Accuracy of Information Submitted
1.Submission of True and Accurate Information
You must submit to us information, including Personal Data, that is true, accurate, and not misleading. You must keep such information up to date and inform us of any changes as soon as practicable. We reserve the right to request documentation to verify the information provided by you.
2.Voluntary Submission of Personal Data
We will only collect your Personal Data if you voluntarily submit such information to us. If you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may be unable to provide you with some or all of the services available through the Platform.
Disclosure of Your Personal Data to Third Parties
You have the right to privacy with respect to your personal data. The Company will only disclose your personal data to third parties under the following circumstances, and the relevant institutions will collect, use, and/or disclose your personal data within the scope of your authorization and consent:
1. Disclosure to authorized employees of the Company and its affiliates, including the Company's internal auditors, external auditors, financial cooperative institutions, and/or third parties related to the Company;
2. Disclosure to enable you to conduct transactions and/or use the services you request;
3. Disclosure to the Credit Bureau (a credit reporting agency);
4. 4.Disclosure in connection with legal investigations or legal proceedings;
5. Disclosure in accordance with laws, government orders, or regulatory requirements.
To assist you in successfully applying for a loan, we will disclose your necessary personal data to third-party cooperative institutions, including fund lenders, payment partners, post-loan management partners, third-party verification service providers, message service providers, and call-out service partners
USE/PURPOSE OF PERSONAL DATA
Personal Data shall be processed, collected, used, disclosed, stored, and retained for the following purposes:
1. To identify Users;
2. To contact Users in relation to their registered account(s) or requested information;
3. To process account registration and to determine or assist in determining decisions as part of the screening of investors, borrowers, registrations, or loan applications, and/or to deliver our products and/or services to the User and for any directly related purposes;
4. To facilitate loan processing from application, review, monitoring, payment, collection, and other remedial measures;
5. To maintain internal records;
6. To market and offer new, related, or complementary products and services to the User;
7. To conduct background checks and identity verification;
8. To conduct and perform fraud monitoring, detection, analysis, and prevention;
9. To prevent, detect, and investigate actual or suspected crimes and to analyze and manage commercial risks;
10. To conduct data analytics and tracking;
11. To conduct market research to enable the Company to understand and determine customer location, preferences, and demographics to develop special offers, products, or marketing programs in relation to products and services, and to improve such products and services (e.g., customized offers and products);
12. To perform research on data to conduct investigations relating to disputes, payment, suspected illegal activities, or fraud;
13. To carry out marketing and promotion initiatives relating to the Company, local affiliates of the Company, the Company's partners, and other Company's products and services, whether by electronic means, email, post, telephone, SMS, social media, or by sending newsletters (e.g., to keep Users updated on new products or features and to publicize events, contests, demonstrations, loyalty programs, and other activities organized by the Company), including by automated means. Such communications shall relate to financial products and services and similar offerings;
14. To develop, enhance, and maintain an offline and online risk assessment process and model;
15. To develop and generate a credit score, credit model, and user model;
16. To enroll/participate the User in group credit and/or life insurance, and to conduct credit risk analysis, credit investigation, credit scoring, and credit collection in respect of the User;
17. To perform User location search;
18. To execute, monitor, manage, and analyze the Platform and to develop, enhance, and upgrade the features, functions, products, and services on the Platform, including promotions, loyalty, and reward programs;
19. To respond to User queries and requests;
20. To facilitate business asset transactions of the Company (which may include any mergers, acquisitions, or asset sales);
21. To facilitate and comply with any financing or capital raising activity (i.e., obtaining loans, credit facilities, mortgages, assignments, or assignments by way of security or mortgage of loans);
22. To initiate and maintain correspondence with the User via electronic mail (e-mail), SMS (short messaging service), in-app message/communication, registered mail, phone calls, or field visits;
23. To resolve complaints and handle requests and inquiries;
24. To monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation, and identity verification purposes;
25. To provide information to external parties such as government agencies as part of scientific research and/or studies;
26. For any other legal and/or regulatory purposes (including but not limited to obtaining legal advice and dispute resolution) and legitimate business purposes, and to carry out all mandatory administrative, operational, and legal duties.
SECURITY OF PERSONAL DATA
The Company attaches great importance to the security of Personal Data collected, used, retained, and stored through the Platform. The Company has adopted technical, organizational, and physical measures to protect your Personal Data.
We take reasonable measures to protect your information from unauthorized access, loss, misuse, or alteration by third parties.
Although we make good faith efforts to store the information collected on the Platform in a secure operating environment not available to the public, we cannot guarantee the absolute security of such information during its transmission or storage on our system. Furthermore, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally accessing this information. We do not warrant or represent that your information will be protected against loss, misuse, or alteration by third parties.
USER OBLIGATIONS
You agree to inform us promptly, and in any event within 14 calendar days, in writing of any changes to the information you have supplied to us from time to time, and to respond promptly to any requests from us for information.
Where:
1.1. You fail to provide promptly any user information or Personal Data that we have reasonably requested;1.2 You withhold or withdraw any consents that we may need to process, transfer, or disclose Personal Data for the purposes set forth in this Privacy Policy (except for purposes connected with marketing or promoting products and services to you); and/or1.3 We, or a member of the Company, have suspicions regarding financial crime or an associated risk.
We may:
2.1. Be unable to provide new services or continue to provide all or part of the services to you and reserve the right to terminate our relationship with you;2.2 Take such actions as are necessary for us or a member of the Company to meet compliance or regulatory obligations; and/or2.3 Suspend, transfer, or close your account(s) where permitted under local laws.
YOUR PRIVACY CONTROLS
You have the right to:
1. Access the personal data held by the Platform;
2. Revoke your consent to the processing of your personal data, revise and/or delete the personal data held by the Platform (unless the retention of such data is mandatory by laws and regulations). Such revocation, revision, and deletion shall not have retroactive effect. This shall not apply in cases where such revocation, revision, or deletion would make it impossible to fulfill obligations arising from an existing legal relationship between you and the Platform or for non-necessary purposes.
The exercise of the aforementioned rights must be carried out in writing by email to the designated email address of the Company. Upon receipt of your application submitted in the aforementioned manner, the Platform will issue a decision on the action taken and notify you accordingly.
MODIFICATION
This Privacy Policy may be updated from time to time and shall remain in effect unless otherwise amended. If changes are made to this Privacy Policy, such changes will be posted on the Platform and shall take effect on the date of posting. Users availing of the services and/or visitors to the Platform are advised to check the website regularly to remain informed of the policies and practices regarding the collection and use of information.
If significant changes to this Privacy Policy will affect certain Personal Data, the Company shall notify its Users via the email address provided by the User or by posting a public notice on the Platform.
The foregoing consents and authorizations shall remain in effect for the duration of any loan agreement(s) signed by the borrower with the Company and the lender through the services and/or the Platform, and shall survive the termination of any such loan agreement(s), or any other transactions, dealings, arrangements, and accounts that the borrower may have with, or avail from, the Company and the lender.
Contact Us
If you need our assistance regarding any information errors, doubts about unauthorized account changes, or any of your transactions, you shall notify our customer service center via email at the designated address or immediately write to the relevant department with the following information:
1. Your name and account name;
2. The time and date of such transactions or changes;
3. Error description and reference code (if applicable);
4. 4.Contact name and address, including email address (if any).
We will immediately investigate any reported errors or unusual activities and inform you of the results as soon as possible.