PRIVACY POLICY

Last Updated: [05/02/2025]

This Privacy Policy governs the collection, use, processing, and disclosure of your personal data by Loan Shop (the "App," "we," "us," or "our"). Loan Shop is a mobile application operated by [Loan Lending Group Corp] (SEC Registration No.: [CS201420799]), a lending company duly licensed by the Securities and Exchange Commission (SEC) of the Philippines.

We are committed to protecting your privacy and your personal data in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations (IRR), as well as the memorandum circulars and advisories of the National Privacy Commission (NPC) and the SEC .

By installing, using, or registering on the Loan Shop App, you signify your acceptance of the terms of this Privacy Policy and expressly consent to the collection, processing, and disclosure of your personal data as described herein.

Table of Contents

1. Definitions

2. What Personal Data We Collect

3. How We Use Your Data (Purposes)

4. Legal Basis for Processing

5. How We Share and Disclose Your Data

6. Data Security

7. Data Retention and Disposal

8. Your Data Subject Rights

9. Consent and Withdrawal of Consent

10. Contact Us

1. Definitions

· Personal Data: 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.

· Sensitive Personal Information: As defined under the DPA, this includes information about an individual’s race, ethnicity, marital status, age, religious affiliations, health, education, and government-issued identifiers (e.g., SSS, TIN).

· Processing: Any operation performed upon personal data, including collection, recording, organization, storage, updating, modification, retrieval, use, consolidation, blocking, erasure, or destruction .

2. What Personal Data We Collect

To provide you with our lending services and to assess your creditworthiness, we collect the following categories of personal data, subject to the permissions you grant on your device:

A. Information You Provide Directly

· Identity Information: Full name, date of birth, gender, nationality, and marital status.

· Contact Information: Mobile number, email address, and residential address.

· Government Identifiers: Details from government-issued IDs (e.g., Passport, Driver’s License, UMID, SSS, TIN) for Know-Your-Customer (KYC) and verification purposes.

· Financial Information: Employment details, income range, source of funding, and bank account details for loan disbursement and collection .

B. Information We Collect From Your Device (With Your Permission)
To operate effectively and assess credit risk, we request access to specific data on your mobile device. This data is collected via our Software Development Kit (SDK) integrated into the App:

· Contacts List (Phonebook): We collect the names and mobile numbers stored in your phonebook. This is used exclusively for credit scoring and risk assessment purposes, specifically to verify your identity and network stability. We do not store complete contact details for purposes of harassing or contacting your references. This practice is strictly regulated by NPC Circular No. 20-01 .

· Call Logs: We may collect data regarding your call history (e.g., call frequency, duration, and numbers contacted, but not the content of the calls). This data helps us validate your identity and detect fraudulent activity.

· Application List (Installed Apps): We collect a list of other applications installed on your device. This helps us verify your identity, assess risk (e.g., presence of known fraudulent apps), and improve our services.

· Device Information: We automatically collect device-specific information such as your hardware model, operating system version, unique device identifiers (e.g., IMEI, Advertising ID), mobile network information, and IP address. This is used for security, fraud prevention, and analytics .

· Camera: We require access to your camera to allow you to take photos of your government-issued IDs and for "selfie" verification as part of our KYC process and to prevent identity fraud .

C. Information from Third Parties
We may receive information about you from credit bureaus (such as the Credit Information Corporation - CIC), collection agencies, and other partners to verify credit standing and comply with regulatory requirements .

3. How We Use Your Data (Purposes)

We process your personal data only for legitimate and specified purposes:

· Loan Application and Processing: To evaluate your loan application, verify your identity, perform credit checks, process loan disbursements, and manage repayments.

· Credit Scoring and Risk Assessment: To create a credit score and assess your creditworthiness using the data collected (including contacts, call logs, and app list). This may involve automated decision-making .

· Verification (KYC): To comply with "Know-Your-Customer" regulations and anti-money laundering (AML) laws using your ID photos and selfie captured via the camera .

· Communication: To contact you regarding your loan application status, send payment reminders, and respond to your customer service inquiries.

· Debt Collection and Recovery: To facilitate the collection of past-due accounts. This is done strictly in compliance with SEC Memorandum Circular No. 4-2022, which prohibits unfair collection practices (e.g., harassment or public shaming) .

· Service Improvement and Analytics: To analyze usage trends and improve the functionality and security of our App.

· Fraud Detection and Prevention: To detect, prevent, and otherwise address fraud, security, or technical issues affecting the App or our services .

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under the DPA:

· Consent: You have given explicit, informed, and freely-given consent (e.g., when you grant device permissions or agree to this policy) .

· Contractual Necessity: Processing is necessary for the performance of a contract to which you are a party (i.e., the Loan Agreement) .

· Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject (e.g., reporting to the AMLC, BSP, or SEC) .

· Legitimate Interest: Processing is necessary for our legitimate interests (e.g., fraud prevention, IT security), provided such interests are not overridden by your fundamental rights and freedoms .

5. How We Share and Disclose Your Data

We do not sell your personal data. We may share your data only under the following circumstances:

· Service Providers and Processors: We engage third-party vendors (e.g., cloud storage, SMS gateways, credit bureaus, collection partners) who process data on our behalf, under strict contractual data processing agreements, ensuring they comply with the DPA .

· Regulatory Authorities: We may disclose your data when required by law or legal process, such as upon orders from the National Privacy Commission, Securities and Exchange Commission, Anti-Money Laundering Council, or courts of law .

· Corporate Affiliates: We may share data with subsidiaries or affiliates for business operation support, subject to the same privacy protections.

6. Data Security

We implement organizational, physical, and technical security measures to protect your personal data against accidental loss, unauthorized access, use, alteration, and disclosure. These measures include:

· Encryption: Data transmitted between the App and our servers is encrypted using TLS (Transport Layer Security). Data at rest is encrypted using industry-standard algorithms .

· Access Controls: Strict role-based access controls are implemented, limiting access to personal data to employees and agents who need it to perform their jobs.

7. Data Retention and Disposal

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the satisfaction of any legal, accounting, or reporting requirements (e.g., the Anti-Money Laundering Act requires retention of customer information for at least five (5) years after the account is closed) . When the data is no longer needed, we ensure its secure disposal or anonymization.

8. Your Data Subject Rights

Under the DPA, you have the following rights:

· Right to be Informed: To be notified of the purpose for which your data is being processed.

· Right to Access: To request a copy of the personal data we hold about you .

· Right to Rectification: To request correction of inaccurate or incomplete data.

· Right to Erasure or Blocking: To request the suspension, withdrawal, or blocking of your data from our systems under certain conditions (e.g., if data was unlawfully obtained) .

· Right to Object: To object to the processing of your data, including for direct marketing purposes.

· Right to Data Portability: To receive a copy of your data in a structured, commonly used, and machine-readable format.

To exercise these rights, please contact our Data Protection Officer (DPO) using the details below. We will respond within the timeframes prescribed by law (usually 15 to 30 calendar days).

9. Consent and Withdrawal of Consent

By clicking "I Agree" or "Allow" on the permission prompts and this policy, you confirm that you have read and understood this policy and consent to the processing of your personal data.

You may withdraw your consent at any time. However, withdrawing consent may affect your ability to use our services (e.g., you may not be approved for a loan if we cannot verify your data). Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal .

You can manage the App permissions (Contacts, Camera, etc.) through your mobile device settings at any time.

10. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data handling practices, or if you wish to exercise your data subject rights, please contact our Data Protection Officer (DPO):CARMEN-MONTANO-CALZADO

Company Name: Loan Lending Group Corp
Email: loanshopcustomersevrvice@gmail.com
Address: 5th Floor Carsib Building Orense Street Corner Del Carmen Street, Guadalupe Nuevo Makati, Metro Manila, 1246 Philippines