Firstpeso PRIVACY POLICY

FIRSTPESO LENDING INVESTORS CORP. REGISTRATION NO. CS202013043 & Certificate of Authority No.4073 ("Firstpeso", "We", "Us", or "Our", for brevity) hereby adopts this Privacy Policy in compliance with the provisions of Republic Act No.4073, 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 "Firstpeso App") and your use of our services through the FirstpesoApp or otherwise. It does not apply to your use of the Company's website, found at https://www.firstpeso.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 Firstpeso Android mobile application found  ("Firstpeso App", for brevity) and your use of our services through the same or otherwise. It does not apply to your use of the Company's website, found at https://www.firstpeso.com/ ("Website", for brevity). Please see the privacy policy applicable to your use of our website. 

When you use our Platform, we collect and store your information which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience and Services. This allows us to provide services and features that meets your needs, and to customize our Platform to make your experience safer and easier and to improve the Services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose. In general, you can browse the Website or App without telling us who you are or revealing any information about yourself. However, to create an account on the Platform, you must provide us with certain basic information required to provide customized services. The information we collect from you, inter alia, includes:

1. your full name;

2. email;

3. gender;

4. photograph;

5. mailing address;

6. postal code;

7. emergency contact;

8. university/college details;

9. phone number;

10. National Identity Card;

1. What data does Firstpesocollect and process?
   • Identification data (e.g., first name, surname, data and place of birth);
   • Data provided by you through your loan application (e.g., information about your income or employment, your proposed use of your loan proceeds, customer-provided information about your mobile device);
   • Installed applications.We collect each installed applications' metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and provide you with pre-approved customized loan offers
   • Phone number.(We collect your phone number so that we can call you to confirm your personal information, help us review your information quickly, and help us prevent fraud. We will not disclose your information to other third parties, please feel free to fill in your real information.This information will be uploaded to https://saas.firstpeso.com/. We will delete this information after we have determined your risk profile.)
   • Contact list.Our app requires this permission to detect references and to auto fill the data during your loan application process for seamleass user journey. Also, app collect and monitor your contacts information including name, phone numbers, account type, contact last modified, favorites and other optionals which includes relationship, structural address, if available to enrich your financial profile and helps us determining the loan eligibility and risk assessment. We collect contacts information only after obtaining your additional explicit consent.The contacts information will be uploaded to https://saas.firstpeso.com/app/data/user-contact. We will delete the contacts information after we have determined your risk profile. ;
   • Mobile device data (e.g., SIM, IMEI, or other device identifiers, type of device, device  operating system, device settings, user account information for your mobile device or Google PlayStore account, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, etc.), information about network proximity);
   • Location data.We collect and monitor the information about the location of your device to provide serviceability of your loan application, to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us to verify the address, make a better credit risk decision and expedite your KYC process;
   • Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information);
   • Phone data (e.g., contact lists, types and nature of mobile applications found on your mobile device,phone number);
   • Firstpeso App usage (e.g., traffic (volume) data, information about your usage of the Firstpeso App);
   • Data related to your communications with Firstpeso(e.g., your communications with Firstpesovia in-app chat, email, telephone or other channels); and
   • Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies, mobile network providers).
   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.

   (collectively, your "Information")

   Firstpeso may collect your Information from:

   • You, when download the FirstpesoApp 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 Firstpeso employees or agents;
   • Your mobile device (e.g., mobile device data, location data, transaction data, Firstpeso 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 Firstpesois necessary for the provision of Firstpeso's products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Firstpesois subject. Aside from such cases, we do not collect Information without your specific prior consent. 

2. What are the purposes for which your Information is processed? How does Firstpesouse 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 Firstpeso(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 Firstpeso'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 autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

   We process your Information for the purposes set out above on the following grounds: 

   • 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. 
3. Who do we share your Information with?
   • General

     Firstpesoshall 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 Firstpeso'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, Firstpesowill 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 Firstpeso(collectively, the "Firstpeso Group");
     • employees, subcontractors, agents, service providers, or associates of the Firstpeso 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 Firstpeso(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 Firstpeso and/or any company within the FirstpesoGroup;
     • 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 Firstpeso, the FirstpesoGroup 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, Firstpesomay 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, Firstpesoadministers and services a referral program ("FirstpesoReferral Program", for brevity) for its current and future customers. If you choose to accept a referral from another Firstpesocustomer and accept a Firstpesoloan in connection with that referral, Firstpesowill provide a bonus to the customer who refers you upon your successful repayment of your Firstpesoloan. 

     If you choose to participate in the FirstpesoReferral 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 Firstpesoloan through such referral. 

     Sharing of your Information in connection with the FirstpesoReferral Program shall be limited to the information described above and shall remain anonymized – Firstpesowill 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 Firstpeso. More information on the FirstpesoReferral Program is available within the FirstpesoApp.

4. For how long will we retain your Information?

   Your Information will be stored or retained by Firstpesoand 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 defenses.

5. Where do we process, store or transfer your information?

   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 3. Firstpesowill use all reasonable and appropriate efforts as required by applicable law to protect your Information.

6. Automated decisions and profiling

   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.

   • Lending decisions

     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.

   • Detecting fraud

     Firstpesoalso 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 behavior 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.

   • Your rights in relation to automated decision-making

     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 cs@firstpeso.com.

7. Your rights as a data subject

   You may contact us to exercise your rights at cs@firstpeso.com.

   • Rights to notice and consent

     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 FirstpesoApp and in this Privacy Policy.

   • Right to access

     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.

   • Right to rectification

     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.

   • Right to erasure ("right to be forgotten")

     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.

   • Right to restrict processing

     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.
   • Right to data portability

     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. 

   • Right to object

     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).

   • Right to file a complaint

     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). 

8. Advertising and Marketing

   You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through cs@firstpeso.com and we will remove you from such communication lists.

9. Consequences of not providing us with your Information

   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 Firstpeso, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.

10. Consent and Authorization

    By downloading the FirstpesoApp, you: 

    • accept the terms of this Privacy Policy;
    • give Firstpesoconsent 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 Firstpesois true and correct to the best of your knowledge;
    • authorize Firstpesoto verify/investigate the accuracy of your Information; and
    • acknowledge that Firstpesomay 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.

11. General

    If you need to contact us, please do so at: cs@firstpeso.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 FirstpesoApp or by email.

12. Effectivity Date

    The provisions of this policy shall have full force and effect beginning 27 March 2020.