1. GENERAL TERMS
2. USER DATA
a. Collection of User Data is done through several sources:
i. by virtue of the registration on the Website;
ii. upon completing the online loan application form;
iii. by virtue of communication with OLP employees;
iv. by virtue of credit reports and data; and,
v. by virtue of navigation through the Website;
vi. upon completing the loan application form via Mobile App.
b. User Data are both Personal and Non-Personal Information:
i. Personal Information is any information from which the identity of a User can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, such as name, gender, date of birth, address, telephone/mobile number, email address, proof of identification, etc. It also includes information about:
1. the data that would help OLP evaluate the User's credit standing such as spouse details financial details, business details, and other data points whenever applicable;
2. the location of the User's device, whether desktop, laptop, or mobile devices, as used to access the Website; and
3. the User's navigation experience when accessing the Website to see activities done in the Website, the pages visited, and the sequence thereof.
ii. Non-Personal Information is any information that does not identify the User individually, and includes statistical and analytical data, and anonymous and aggregate reports.
iii. The User may also be requested to update Personal Information from time to time. Should the User be unable to supply the required Personal Information, OLP may be unable to provide the User with requested products and services and updates on the latest offerings. The User may also be unable to participate in OLP events, promotions or other activities.
v. The User has the duty to inform OLP of any change in the information provided, in order to keep it updated and avoid errors.
vii. Information our servers automatically collect when you access the App, such as your native actions that are integral to the App, actions taken when creating entries, editing entries and uploading media to the App. As such, we may also request access to your device’s photo roll or camera in order for us to upload your media to the App. Any media uploaded in this fashion, will be collected and stored on our servers. If you wish to change our access or permissions, you may do so in your device’s settings.
viii. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the App, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
ix. We may request access or permission to certain features from your mobile device, including the list of installed applications, your mobile device’s reminders, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
x. Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
xi. We may request to send you push notifications regarding your account or the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
xii. Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
3. USER CONSENT AND USE OF INFORMATION
a. User consent is a pre-requisite for the availment of the Services. If the User chooses not to provide OLP with any Personal Information required from User, OLP reserves the right to refuse User request for, or the continuation of, any of the Services.
b. The User may withdraw consent to the collection, processing and/or storage of any Personal Information, provided that any and all legal obligation is settled.
c. Having accurate information about the user permits us to provide the user with a smooth, efficient, and customized experience. Specifically, we may use information collected about the user via the App to:
i. Generate a personal profile about the user to make future visits to the App more personalized.
ii. Monitor and analyze usage and trends to improve your experience with the App.
iii. Notify you of updates to the App or Site.
iv. Request feedback and contact user about user’s use of the App.
v. To improve our website and product
vi. We may periodically send promotional emails about new products, special offers or other information which we think user may find interesting using the email address which user have provided.
4. ANTI-MONEY LAUNDERING COMPLIANCE
a. The Anti-Money Laundering Act (hereinafter referred to as "AMLA"), as amended, requires all Covered Institutions to obtain, verify, and record information that identifies each person who applies for a loan.
b. Being a Covered Institution under AMLA, OLP will ask for the User's name, address, date of birth, business, tax identification number, Social Security System or Government Service Insurance System numbers, and other information that will allow OLP to identify the User.
c. OLP may also ask to see the User's driver's license, passport, or other competent evidence of identity bearing the User photograph and signature in order to comply with AMLA and other applicable laws and regulations.
5. USER DATA PROCESSING
a. Without limitation to the foregoing, User data may be processed by OLP among others for the following purposes:
i. Verify the User's identity;
ii. Manage the provision of services being offered by the Website, such as processing the loan application or rendering the loan credit decision, among others;
iii. Evaluate the User's credit standing through external credit report providers and bureaus;
iv. Contact the User;
v. Transfer the loan proceeds;
vi. Manage and recover outstanding debt;
vii. Update the information regarding the loan granted;
viii. Enhance the User's customer experience and improve, develop and determine customized products to meet customer preferences and needs;
ix. Send commercial communications on the products and services;
x. Improve the service and contents of the service through statistical analysis and market research;
xi. Abide by any safety, security, public service or legal requirements and processes;
xii. Process information for statistical, analytical, and research purposes;
xiii. Any other purpose expressly provided in the Loan Application Form and/or in the General Terms and Conditions as well as in the Promissory Note / Disclosure Statement; and
xiv. Other specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after collection of the Personal Information
b. OLP also uses the User's Non-Personal Information for statistical, analytical, and research purposes to create anonymous and aggregate reports.
c. User consents that OLP maintains the data provided even when the loan application has not been accepted, in order to ensure compliance with legal obligations and avoid duplication in the new applications treatment.
e. OLP does not share User Personal Information with any third parties for their business purposes, such as, including without limitation, marketing and advertising without User's express consent and authorization.
6. THIRD-PARTY LINKS AND OTHER COMPANIES / ORGANIZATIONS
7. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
OLP may share your Personal Information with third-parties, which includes, but is not limited to the following entities:
a. Affiliates and/or Members of the corporate family, including subsidiaries, to assist in providing the Services listed in the Website, to help detect and prevent potentially illegal acts and violations of our policies, and to provide proper data analytics on the use of the Website, including marketing communications;
b. Courts of Law, government officials, law enforcement, or other regulators in relation to a subpoena, court order, or other legal process or requirement under Philippine law or regulation, when OLP needs to do so to comply with such law or regulation, or when OLP believes, in its sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, or to report suspected illegal activity or investigate violations of our Terms and Conditions;
c. Credit bureaus and collection agencies to report account information, as permitted by law.
d. Customer support for customer service purposes;
e. Banking or financial partners, as permitted by law or as required by the contractual business relationship;
f. Legal department, to ensure compliance with government rules and regulations and to protect us against harm to the rights, property, or safety, the other users of the Website or the public, as required or permitted by law;
g. Service Providers, to enable service providers under contract with OLP to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services.
h. The User agrees that OLP, directly or through its Partners, may collect, retrieve, process, use and store his/her personal data such as name, age, photographs, fingerprints, other biometric data (e.g., facial recognition and voice recognition), mobile number/s, mobile phone usage data, employment details, income, financial data, financial profile, credit standing, loan payment history, installed mobile applications list (in the case of OLP Mobile App usage), and other information required in the application form for the purpose of reviewing and processing the User's loan application. The User consents to the collection of his/her personal data from the User her/himself, or from other personal information controllers such as, but not limited to, telecommunications companies like GLOBE and SMART, for credit scoring purposes. The User's personal data such as mobile number, email address, address, and telco score, will be shared to a credit scoring service provider for credit investigation, credit scoring, data analytics, and data profiling, which includes the regular updating of the User's credit score. The personal data secured may also be used for direct marketing of products and services of Partners.
Throughout the processing of the User's personal data, his/her rights under the Data Privacy Act of 2012, such as the (1) right to be informed, (2) right to object, (3) right to access, (4) right to rectification, (5) right to erasure or blocking, and (6) right to damages, shall be upheld. Entities to whom we share your data will also respect the same rights.
8. COOKIES AND WEB BEACONS
9. THIRD-PARTY WEBSITES
10. SPECIAL NOTICE – MINORS
Use of the Website is not aimed at persons under 18 years old and OLP will not collect, use, provide or process in any other form any personal information of persons under the age of 18 deliberately.
We therefore also ask the User, if under 18 years old, please do not send us personal information (for example, your name, address and email address). If User is under 18 years old and nevertheless wish to ask a question or use this Website in anyway which requires you to submit personal information please get your parent or guardian to do so on your behalf.
11. ACCURACY OF PERSONAL INFORMATION
If the User would like to review, change or delete any Personal Information supplied to OLP, please contact OLP immediately using the contact of the Data Protection Information officer listed below.
12. PERSONAL INFORMATION STORAGE
OLP will retain your Personal Information as long as you are a User or no longer that it is necessary and relevant for the Services. OLP may also retain Personal Information to comply with the requirements of any laws and regulations, to prevent fraud, to resolve disputes and various troubleshoot problems, and to take other actions permitted or required by applicable laws and regulations. Under our data policies, we will dispose Personal Information in a secured manner and in accordance with applicable laws and regulations, after such Personal Information is no longer necessary and ceases to be relevant for our Services, unless applicable laws and regulations require otherwise, or unless the requested by the user in writing.
14. MOBILE ACCESSIBILITY
OLP may request access or permission to certain features from your mobile device, including the list of installed apps, user mobile device’s reminders, and other features. If you wish to change our access or permissions, user may do so in user device’s settings.
15. USER CONFIDENTIALITY
To further secure the privacy of your Personal Information, we advise to keep your any account details confidential at all times.
17. INQUIRIES AND COMPLAINTS
If the User believes his account or any personal data may have been misused or abused, or if the User believes that the security and protection of his/her respective personal data may have been compromised, User may lodge inquiries and complaints to the Contact Information below and briefly discuss such matter, together with User's contact details for reference.
If the User is not satisfied with the manner of how the complaint was handled, or if User still believes that there exists a threat of breach of his/her Personal Information, User may directly lodge your complaint with the National Privacy Commission.
For any concern regarding the User's personal data, the duly-designated Data Protection Officer of OLP may be contacted, as follows:
Email: [email protected]
Address: 601 Summit One Office Tower, 530 Shaw Boulevard, Barangay Highway Hills, Mandaluyong City