Privacy Policy

pera247 Lending Corporation Privacy Policy

Please read our privacy policy carefully to get a clear understanding of how pera247 Lending Corporation, our respective group companies, subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “pera247,” “Company,” “Corporation,” “We,” “Us,” or “Our”) collect, use, disclose, store, protect or otherwise handle your Personal Information.

General

pera247 Lending Company is committed to protect the privacy and security of all Personal Information and Sensitive Personal Information (“Personal Data”) that it processes. For this reason, uniform practice and procedure for collecting, using, recording, consolidating, updating, disclosing, storing, accessing, transferring, retaining, destructing, disposing or otherwise processing of Personal Data by the Company are hereby adopted in order to process Personal Data fairly, appropriately, and lawfully.

This Privacy Policy sets out the use, protection, and control of the company over the Personal Data it processes. The Company may change this policy from time to time by updating it in accordance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, NPC Advisories and issuances and other relevant laws (collectively, “Applicable Privacy Laws”). The terms of this Privacy Policy apply to all persons whose Personal Data is processed by pera247.

Scope

This Privacy Policy applies to all Data Subjects whose Personal Data is used, collected, shared, stored, disclosed or otherwise processed by pera247 Lending Company.

Definition of Terms

  • Data Subject” – refers to an individual whose personal, sensitive personal or privileged information is processed by the organization. It may refer to officers, employees, consultants, and clients of this organization.
  • Personal Data” – refers to all types of Personal Information and Sensitive Personal Information.
  • Personal Information” – refers to 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 put together with other information would directly and certainly identify an individual.
  • Processing” – refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
  • Sensitive Personal Information” refers to Personal Information: (1) About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;(2) About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;(3) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (4) Specifically established by an executive order or an act of Congress to be kept classified.

What do we collect?

pera247 Lending Corporation, with the consent of the Data Subjects (or in accordance with any other legal basis as permitted by Applicable Privacy Laws), collects Personal Information and Sensitive Personal Information through various channels (including but not limited to our website, social media pages, blog, mobile application, forms, your interactions with our customer support agents, participation in our social events and lucky draws, referrals etc.) for the purposes stated in this Privacy Policy. These includes the following Personal Information:

  • Name
  • Email Address
  • Mailing Address
  • Phone Number
  • Birthday
  • Place of Birth
  • Photo
  • Mobile device data
  • Employment details and income information
  • Other financial information (financial profile, credit standing, loan payment history)
  • Any other Personal Information necessary to provide you with our services and to gain access to our mobile application and website.

We collect your Personal Data when you provide it directly to us, for example, when you sign up for an account on our mobile application or when you apply for a loan, or through the normal operation of our mobile application and website when you use our mobile application and website. 

We may also collect your Personal Data from other sources and personal information controllers (such as from our group companies, subsidiaries, affiliates, associated companies and jointly controlled entities, our business partners, insurance and financial providers, credit bureaus, alternative credit scoring agencies and any other credit reporting organisations and marketing service providers or partners) to fulfil the Purposes, where required.

We also collect data from your mobile device via our mobile application (not including but not limited to data relating to your Contacts, Calendar, Registered Accounts, Storage) to generate segmented risk profile(s) and statistical information to assess your creditworthiness for a loan as well as to improve how we can better offer services to our customers (such as by enhancing our data analytics capabilities). For more information on how we use your mobile device data, click here.

In some situations, you may provide Personal Data of other individuals (for example, of your references, guarantor or co-maker (wherever applicable) or when making referrals) to us while using our services. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Policy.

If you are a reference person, guarantor or co-maker (if applicable), we may need to contact you to request for (i) additional information about our customer who listed you in their application, (ii) verify any information provided in the customer’s application, and/or (iii) request for any other information that we may deem necessary (such as for updated contact details of our customer), in the event that we need to communicate important updates to our customer (for example, if the customer defaults on his/her payment obligation to us) and where we are unable to reach the customer using the contact information that was provided at the point of application.

How do we use your personal data?

With your consent, we may use the Personal Data we collect from you when you download the mobile application and register, apply for a loan, sign up for our newsletter, respond to a survey or marketing communication, surf the website, use certain site features requested for our services, or otherwise directly or indirectly provide your Personal Data to us. Your Personal Data shall be processed for the specific purposes made known to the Data Subjects such as but not limited to the following:

  • Credit profile assessment - as part of our decision process to assess your creditworthiness for a loan with us.
  • Credit background investigation - to determine if you are qualified for a loan and verify the information that you submitted 
  • Credit Scoring and Data Profiling - to carry out credit scoring and data profiling or the purposes of determining your eligibility for loans (“Facilitating Loans”) and for the purposes of offering you relevant products and marketing material (see “Customized Marketing”
  • Facilitating Loans - this includes customers loan application processing by the system and/or underwriter, carrying out know-your-customer and due diligence checks (such as verification of your age and identity, etc.), credit and risk management, disbursing the loans, and for the collection of any repayment of the loans, securing your loan applications, disbursing loans to you, and for the collection of any repayment of the loans.
  • Account creation and registration - to create an account for the purposes of receiving our services.
  • Database Input - to store and process the Personal Data collected for the loan lifecycle.
  • Account Termination - to facilitate the termination of your account with us should you no longer receive our services.
  • Customized Marketing -  to determine your eligibility and/or to pre-qualify you for new products and/or to cross-sell other products to you, and to send you relevant alerts, newsletters, updates, promotional materials and other marketing material in accordance with your marketing preferences. We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification, by hand and by email.
  • Mobile Application Personalisation - enable features that personalise your mobile application to make your experience more seamless.
  • Research, Data Analytics, Development and Security - to carry out testing, research, analysis and product development (for example, to generate risk profiles and aggregated statistical information (via algorithms and mathematical modelling) of customers like you (for example, based on demographics). This allows us to better understand and analyse our customers’ needs and preference, protect your Personal Data, improve and enhance the safety and security of our assets, develop new features, products and services, and facilitate new loan solutions. . This would also help us  to better determine how we may better tailor our services to our customers and assess your interest in receiving other financial services that may be of interest to you.
  • Customer Support - we use Personal Data to resolve your support issues, such as to investigate and address concerns, complaints management, monitor and improve our user support responses and to respond to questions, comments and feedback.
  • Legal Purpose - to investigate and resolve claims or disputes, or as allowed or required by applicable law. We may also use Personal Data without consent, by relying on legitimate interests or other exemptions provided by the applicable data privacy laws, for purposes such as detection and prevention of fraud. We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.
  • Internal Operations - perform internal operations necessary to provide our services, prevention and detection of fraud or crime, including troubleshooting software bugs and operational problems, testing and research, monitoring and analysing usage and activity trends as well as to protect the security or integrity of our services and any facilities or equipment used to make our services available.
  • External Services - fulfil services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom Pera247 Lending Corporation is providing services on behalf of) for such services to be rendered.   
  • Incidental Services - Any other services provided by us incidental to the services above

(collectively, the “Purposes”)

Personal Data will be retained, shared, updated and disposed of according to internal policies like data privacy and other relevant record management processes and procedures to ensure high quality and secure information management.

How do we protect your information?

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

Rights of the Data Subject:

The Data Subject is entitled to certain rights under Applicable Privacy Laws, including the following rights:

  • Right to be informed;
  • Right to object;
  • Right to access;
  • Right to data portability;
  • Right to rectification;
  • Right to erasure or blocking;
  • Right to damages;
  • Right to file a complaint.

Cookies

Do we use ‘cookies’?

Yes. pera247 Lending Corporation, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (“Cookies”) in connection with your use of the our website and mobile application. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA). Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session. 

For instance, we use cookies to:

  • Understand your preferences based on previous or current site activity, which enables us to provide you with improved services. 
  • Help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

pera247 Lending Corporation may allow third parties to use Cookies on the website and mobile application to collect the same type of Personal Data for the same purposes pera247 Lending Corporation does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable information with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

If users disable cookies in their browser:

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browsers are a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you disable cookies, some of the features that make your site experience more efficient may not function properly. Some of the features that make your site experience more efficient and may not function properly.

Third-party disclosure

We take reasonable precautions to be sure that non-affiliated third parties and affiliates, to whom we disclose Personal Data are aware of our Privacy Policy and will treat the Personal Data in a similarly responsible manner. [Based on information sensitivity, Non-Disclosure Agreement and Data Sharing Agreement shall be signed between relevant authorities]. We do not sell or trade your Personal Data to third parties without your consent. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep the Personal Data confidential. We may also release Personal Data when its release is appropriate to comply with the law, enforce our site policies, or protect our rights and of others, property and safety.

Is the Personal Data collected shared with any third party?

Yes. We take reasonable precautions to be sure that third parties and affiliates, to whom we disclose Personal Data are aware of our Privacy Policy and will treat the Personal Data in a similarly responsible manner. We do not sell or trade your Personal Data to third parties without your consent. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep the Personal Data confidential. We may also release Personal Data when its release is appropriate to comply with the law, enforce our site policies, or protect our rights and of others, property and safety.

We may share your Personal Data with the following third parties:

Group Companies, Affiliates and Subsidiaries

We may share your Personal Data with our group companies, affiliates and subsidiaries.

Service Providers and Business Partners

We may share your Personal Data with Pera247 Lending Corporations’ business partners at your request. We may also share your Personal Data with our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This could include background check and anti-money laundering service provider, cloud and website hosting providers, and other service providers and partners who help us with carrying out the Purposes.

Credit Bureau

We may disclose your Personal Data to: 

(i) credit reporting agencies such as the Credit Information Corporation (CIC) (pursuant to Republic Act No. 9510 otherwise known as “the Credit Information System Act” and its Implementing Rules and Regulations Pera247 Lending Corporation is mandated to submit or disclose his/her basic credit data to the CIC as well as any updates or corrections thereof, and share said basic data with other lenders authorized by the CIC, credit reporting agencies duly accredited by the CIC and financial service providers); and

(ii) other credit bureaus, alternative credit scoring agencies and any other credit reporting organisations.

Data Analytics Providers

The Personal Data collected is shared with selected providers of data analytics services. The service providers are described below:

  • CredoLab Pte Ltd: pera247 uses CredoLab service to assess user’s credit worthiness. Metadata accessed, collected and shared with CredoLab are as follows: Contacts, Calendar, Registered Accounts, Storage. CredoLab’s privacy policy is available at https://www.credolab.com/privacy-policies/gdpr-privacy-policy.
  • To protect your identity, we remove all personal identifiers (if any) and pseudonymize such information provided to CredoLab. Any metadata processed in this way cannot be used to reproduce the original data collected.

Legal Advisors and Governmental Authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfill legal purposes or otherwise as permitted by law.

Google

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies), third-party cookies (such as the DoubleClick cookie) and / or  other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

 You can set preferences for how Google advertises to you via the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Do Not Track Signals

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites operate separately and independently from us. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Data Retention

As we are committed to comply with the Data Privacy Act of 2012 (R.A. 10173) and Anti-Money Laundering Act, as amended, the organization may retain your personal data under the following criteria:

  1. When it is provided for by existing laws pera247 shall retain your Personal Data for ten (10) years from the conclusion of your transactions with any member of the pera247;
  2. When it is mandated by a public authority pera247 Lending Corporation, as a lending corporation, follows the rules mandated by the Credit Information Corporation;
  3. When it is necessary to pursue the legitimate interests of  pera247 Lending Corporation; or 
  4. For any period necessary to fulfill the Purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. 

Once retention of your Personal Data is no longer necessary for the Services we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

Cross-Border Transfer of Personal Data

Your Personal Data may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

Applicable Law and Rights

Pera247 Lending Corporation upholds compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and other relevant policies, including issuances of the National Privacy Commission. The Company acknowledges your rights under Applicable Privacy Laws, such as the right to be informed, object to processing, access and rectify, suspend or withdraw Personal Data, and be indemnified in case of damages pursuant to the provisions of DPA.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we will no longer be able to provide services to you. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations (such as where there is are contractual obligations between you and Pera247 Lending Company).

 If you wish to make a request to exercise your rights, you can contact us through our contact details set out in the “Contact Us” section below. We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

Changes to Privacy Policy

The Company reserves the right to amend this Privacy Policy at any time, consistent with Applicable Privacy Laws. In such cases, an updated version will be posted on our Site. If we are going to use your Personal Data in a manner different from that stated at the time of collection, we will notify you, and you will have a choice as to whether or not we can use your Personal Data in such a way.

Contact Us

If you have any queries about this Privacy Policy or would like to exercise your rights set out in this Policy, please contact our Data Protection Officer at dpo@pera247.com. The contact details of our Data Protection Officer are

Name: Cristelle Alcaraz

Address: Unit LGCS07, D’ Ace Plaza, Brixton cor. United St., Kapitolyo, Pasig City, 1603 Philippines

Contact Details: dpo@pera247.com

Alternatively, you may reach out to us via the “Contact Us” section of our mobile application and choose the subject “Data Privacy”.

 



pera247 Lending Corporation is a duly registered lending company under SEC (SEC Registration No.: CS201734339 with Certificate of Authority No.: 2582)