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.
Definition of Terms
What do we collect?
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.
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:
(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:
Do we use ‘cookies’?
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.
Is the Personal Data collected shared with any third party?
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.
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:
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.
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.
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.
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.
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:
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.
Name: Cristelle Alcaraz
Address: Unit LGCS07, D’ Ace Plaza, Brixton cor. United St., Kapitolyo, Pasig City, 1603 Philippines
Contact Details: email@example.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)
pera247 Lending Corporation adheres to the strictest of standards in responsible lending as governed by its board of directors, including compliance with: 1) registration and certification with the National Data Privacy Commission (No.: PIC-001-172-2019); 2) Truth-in-Lending Act; 3) Fair Collection Practices; 4) Anti-Money Laundering; and 5) membership in Fintech Protects Community of Practice by The Smart Campaign, an initiative of the Center for Financial Inclusion (CFI) at Accion.