U-PESO.PH LENDING CORPORATION (“Pera4u”, “We”, “Us”, or “Our”, for brevity) hereby adopts this Privacy Policy in compliance with the provisions of Republic Act No. 10173, entitled: An Act Protecting Individual Personal Information In Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission, And For Other Purposes, otherwise known as the “Data Privacy Act of 2012”.
For this purpose, this Privacy Policy ensures that the personal data gathered from our clients in the course of transactions, and in accordance with the nature of our business, shall remain secured and protected.
This Privacy Policy describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You must read this Privacy Policy in its entirety.
(the “Pera4u App”) and your use of our services through the Pera4u App or otherwise. It does not apply to your use of the Company’s website, found at https://Pera4u.com/ (the “Website”). Please see here for the privacy policy applicable to your use of our website. This Privacy Policy applies in connection with your use of the Pera4u Android mobile application found here (“Pera4u App”, for brevity) and your use of our services through the same or otherwise.
1.1 Many of the services offered by the Company require us to collect Personal Data about you in order to perform our services, evaluate our marketing activities and offer our products and services.
1.2 We may collect and process the following Personal Data about you:
1.2.1 Information that you provide to us.
We have set out below a description of the types of information about you which we may collect and process in different situations when you interact with us. The nature of our relationship with you will determine the kind of Personal Data we might ask for;
1.2.1.1 “Personal Data” means any data which relates to a living individual who can be identified from that data or from other information which is in the possession of, or is likely to come into the possession of, the Company (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of the Company or any other person in respect of an individual.
1.2.1.2 Personal Data that we generally process regardless of how you contact us, or for whatever reasons (including any surveys which we use for research evaluation purposes, if you chose to respond to them), such as your: first name, family name, email address, phone number and/or correspondence address;
1.2.1.3 Personal Data that you submit online via our Website (including information on ethnicity and disability if you choose to provide it); and/or
* 1.2.1.4* Personal Data that you submit to us, or to one of our partners to become a customer, which, in addition to the above, may include: financial information, occupation and job details, any relevant income information, proof of identification or other identity documents, age and date of birth.
* 1.2.2* Information that we collect or generate about you. This includes (by way of non-exhaustive list):
1.2.2.1 Details of your visits to our Website and the resources that you access (which may include, amongst other things; traffic data and communication data);
1.2.2.2 Information about our business relationships with you, such as a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you, and/or;
1.2.2.3 Any Personal Data that you provide to us in correspondence and during our interactions with you (including Personal Data that you provide during telephone and email communications with us, and/or via our Website).
1.2.3 Information we obtain about you from other sources:
Cookies:
1.2.3 We also use ‘cookies’ to track technical information about the services that you use and how you use them on our Website. For full information on how we use the data, please read the Cookie Policy on our Website;
1.2.3.2 information from publicly available sources (including third party agencies such as credit reference agencies, fraud prevention agencies, law enforcement agencies and public registers), such as your credit history; and/or
1.2.3.3 information obtained from sanctions checking and background screening providers and information, such as your reasons for being on the sanctions list.
Other information: We may collect some of your other personal information only after obtaining your additional explicit consent.For example,the phone nunmbers you add to your contacts application may be collected for risk control purposes;and your location information(IP address,longitude and latitude information) may be collected for anti-fraud purposes.
1.2.4 Anonymized data:
In addition to the categories of Personal Data described above, we will also process further Anonymized information and data that is not processed by reference to a specific individual.
1.3 When you register an account on Pera4u or use any kind of service on Pera4u, you will need to provide your personal information which may include but are not limited to Name, Gender, place and date of birth, domicile, telephone number, email address, employment information, phone contact, call history, SMS, call history, social media accounts.
We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description and the amount of transaction to perform credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored or shared.
1.4 In order to quickly log in to Pera4u using phone number and verification code, we will gain information through text message and when you log in to the applications or use Pera4u, the system will automatically gain access code, and enables you to log in immediately. You can also choose to log in using your password. For safety measures and data storage, Pera4u stores your account information, password and other information related to you on Pera4u’s server.
1.5 To fully protect the safety of your account, when you visit Pera4u’s website or other related websites, or Pera4u application or use our services, we are able to track/record your login information, this information can help us better understand your account’s safety, which may include, but is not limited to IP address, permanent device recognition (ie: SSAID, MAC address, IMEI, etc).
1.6 Other than the above information, we also collect additional information in order to raise our service quality, including information that you give when you contact our customer service, and your information which we collect from our affiliated companies.
1.7 Pera4u collects your application list, including package name, package version, app installed time to build and complete our risk management model. Without the model, we would not be able to provide financial service to you. Your data will be transmitted and stored to our server: ( http://Pera4u.com ) over a secure encryption technology. We will not share your data to third parties for any reasons, such as for the purposes of analysis and sale.
1.8 Phone Number We will upload you and your contact phone number to http://api.pera4u.com/ .com to verify the authenticity of your identity. Identity verification is done through the contact to ensure the security of loan funds and the phone number will be removed once your risk profile is determined.
1.9 Images During the process of filling in the information, you need to transmit ID photos/selfies and other pictures to complete the entry of identity information to ensure that it is your own operation. This information will be uploaded to https://pera4u.com/ and will be deleted once your risk profile is determined.
2.1 When you visit our website or our customer mobile service facility, or if you use other services of Pera4u, you are obliged to provide a certain amount of information to us we will also collect your information from our affiliates and business partners to complete our data, to provide services to you. We will use an encrypted safety system to store and collect your sensitive personal information.
2.2 We use your information to provide financial services and customer services from Pera4u, which may include but is not limited to: application verification, loan disbursement, loan payment. Compare information accuracy, and verify it with a third party. For example, to verify personal data and identity card that you have provided to an organization that does verification.
3.1 We do not use vulnerability scanning and/or scanning to PCI standards. We do not use Malware Scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you provide is encrypted via Secure Socket Layer (SSL) technology.
3.2 We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. The Company respects your privacy and assures that your personal data will be kept securely according to the local PDPA or equivalent.
You, when download the Pera4u App and/or indicate that you want to apply for a loan;
Your other interactions with us, including Information you may voluntarily share with our customer support team or other Pera4u employees or agents;
Your mobile device (e.g., mobile device data, location data, transaction data, Pera4u App usage and/or phone data as more fully described above);
Credit reference agencies (who may check your Information against other databases – public and private – to which they have access) or fraud prevention agencies; and/or
Third parties and other publicly available sources, with your consent, when necessary (e.g., we may receive Information from financial rails (or other disbursement channel vendors) or other business partners that may assist us in providing services to you).
Collection and processing of your Information by Pera4u is necessary for the provision of Pera4u’s products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Pera4u is subject. Aside from such cases, we do not collect Information without your specific prior consent.
We need to obtain call records to ensure that real users are using the app in a normal environment, rather than maliciously logging in through the use of emulators. We need to obtain your call history. Include phone number, name, and call time. Call record information will be uploaded to https://api.pera4u.com/ And it will not be shared with third parties. We will not disclose or share your information.
To assess your eligibility to use our products or services (including, but not limited to, by assessing your creditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product);
To service your loan with Pera4u (including, but not limited to, by processing your transactions and processing disbursement of your loan and collecting repayment of your loan);
To verify your identity and/or other information you have provided to us;
To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;
To analyze customer behavior;
To administer out systems, maintain service quality and compile general usage statistics;
To analyze and improve our services;
To troubleshoot any problems you or other customers encounter with Pera4u’s services;
To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and/or anti-money laundering;
To the extent you have not objected to the use of your information for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers;
To provide service updates;
To provide staff training (where we may monitor or record customer interactions);
To interface with credit reference or fraud prevention agencies;
To provide customer service or support;
To contact you by telephone using autodialled or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.
In connection with the nature of our business in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date;
To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you); and/or With your prior consent.
General
Pera4u shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Pera4u’s products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Pera4u will only share your Information with third parties in an anonymized format.
You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to:
A subsidiary, affiliate or parent company of Pera4u (collectively, the “Pera4u Group”);
Employees, subcontractors, agents, service providers, or associates of the Pera4u Group (including directors and officers);
Intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, credit reference agencies or credit bureaus;
Service providers with contractual or fiduciary relationships with Pera4u (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer);
External collection agencies (to assist in the collection of any unpaid obligations to us);
Tax authorities;
A party in connection with any merger, acquisition or sale of all or substantially all of the assets of Pera4u and/or any company within the Pera4u Group;
To other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Pera4u, the Pera4u Group and/or our customers.
The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy.
Further, Pera4u may also share your information with law enforcement or other government agencies pursuant to a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you.
Referrals
To promote its products and services, Pera4u administers and services a referral program (“Pera4u Referral Program”, for brevity) for its current and future customers. If you choose to accept a referral from another Pera4u customer and accept a Pera4u loan in connection with that referral, Pera4u will provide a bonus to the customer who refers you upon your successful repayment of your Pera4u loan.
If you choose to participate in the Pera4u Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the imbedded referral link and subsequently applying for and accepting a Pera4u loan through such referral.
Sharing of your Information in connection with the Pera4u Referral Program shall be limited to the information described above and shall remain anonymized – Pera4u will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Pera4u. More information on the Pera4u Referral Program is available within the Pera4u App.
Your Information will be stored or retained by Pera4u and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services.
We may also retain your Information (i) as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defences.
We may transfer your Information outside of the Philippines, either to the United States, or Singapore, and/or to the extent we provide prior notice to you, to jurisdictions that may have data protection laws that are less stringent than those of the Philippines. When we do so, we will ensure that adequate safeguards are in place in accordance with applicable law and/or the Philippines’ data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your Information. Your Information may be processed by any of the parties described in Section 5. Pera4u will use all reasonable and appropriate efforts as required by applicable law to protect your Information.
We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.
When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.
Our credit and underwriting models utilize machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure.
Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Pera4u also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behaviour consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.
In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through Cs01@pera4u.com.
You may contact us to exercise your rights at Cs01@pera4u.com
We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Pera4u App and in this Privacy Policy.
You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request.
You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the thereof.
You may ask us to delete your personal data (as defined under applicable law) from our system:
If you believe it is no longer necessary for us to retain such personal data;
If you do not believe we have legitimate ground for processing it;
If you think we are using such personal data unlawfully; and/or
If you think applicable law requires that we do so.
You may ask us to stop using your personal data (as defined under applicable law):
If you think such personal data is inaccurate;
If you think it’s illegal for us to use such personal data;
If you don’t want us to destroy such personal data because you need it for legal proceedings;
If you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.
If we’re using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller.
You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data).
You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject, including the National Privacy Commission of the Philippines.
Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation).
You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through Cs01@pera4u.com and we will remove you from such communication lists.
You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Pera4u, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.
By downloading the Pera4u App, you:
Accept the terms of this Privacy Policy;
Give Pera4u consent to collect, use, share, or otherwise process your Information, which may include personal information, sensitive personal information or privileged information (in each case, as defined under applicable law), as outlined in this Privacy Policy;
Certify that all Information you have provided and will provide to Pera4u is true and correct to the best of your knowledge;
Authorize Pera4u to verify/investigate the accuracy of your Information; and
Acknowledge that Pera4u may be required to disclose your Information to the Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, credit bureaus and/or any other governmental body, in compliance with its legal obligations.
If you to contact us, please do so at: Cs01@pera4u.com
To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Pera4u App or by email.
The provisions of this policy shall have full force and effect beginning 16 January 2020.