PRIVACY NOTICE of ONLINE LOANS PILIPINAS FINANCING INC.

Users (hereinafter referred to as "User", individually, and "Users", collectively) of the website onlineloanspilipinas.ph (hereinafter referred to as "Website") are provided with the suitable technical resources so that, prior to the voluntary completion of User Data, Users can access this Privacy Notice and any other relevant information on the Protection of User Data.

This Privacy Notice is applicable to any User of the Website through any of its features processes, functions and its related services including, but not limited to, loan applications ("Services") to ONLINE LOANS PILIPINAS FINANCING INC. (hereinafter referred to as "OLP"), hence Users are instructed to review it from time to time for updates that are effected on a regular basis.

The User is advised to read this Privacy Notice carefully because use of the Website indicates that the User consents to the Website's usage of the User's Data.

1. GENERAL TERMS

  1. This Privacy Notice is binding in relation to all User Data received by OLP from the natural person holding such User data at the time of using or attempting to use the services of OLP, including contracting loans.
  2. User accepts this Privacy Notice through the use of the website and gives consent for the collection, processing, storage and transmission of the User's Data in the formats prescribed by the applicable Philippine laws and regulations as well as this Privacy Notice.
  3. The purpose of this Privacy Notice is to inform the Users of their right to privacy to the User Data in relation to the collection, use, storage, processing, disclosure, security and eventual destruction of such Data by OLP.

2. USER DATA

  1. Collection of User Data is done through several sources:
    1. by virtue of the registration on the Website;
    2. upon completing the online loan application form;
    3. by virtue of communication with OLP employees;
    4. by virtue of credit reports and data;
    5. by virtue of navigation through the Website;
    6. by virtue of downloading the App
  2. User Data are both Personal and Non-Personal Information:
    1. 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, government-issued ID numbers (such as but not limited to TIN, SSS, GSIS, PhilHealth, UMID, Passport), biometric data (such as fingerprints or facial images), employment details, or financial information (such as bank account or credit card details)It also includes information about:
      1. the data that would help OLP evaluate the User's credit standing which may include spouse or beneficiary information, employment details, declared income, business ownership or source of livelihood, credit history, existing loan obligations, and bank account or e-wallet information, 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.
      4. all personal information related to your App profile, which you voluntarily give us either upon sign-up or through continued use of the App, including your first and last name; Nickname; Email address; date of birth ; Demographic location; Timezone; Photos uploaded, contact number and account preferences.
    2. Non-Personal Information is any information that does not identify the User individually, and includes statistical and analytical data, and anonymous and aggregate reports.
    3. 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.
    4. Depending on the Users' device or Internet browser settings, when Users access the Website and electronically communicate with OLP, OLP may use cookies, web beacons, small data text files or similar technologies to identify the Users' devices and record the Users' preferences, with the Users' consent.
    5. The User has the duty to inform OLP of any change in the information provided, in order to keep it updated and avoid errors.
    6. If the User uses our Website or Services in place of other people, such as family, friends or employees, User must ensure that he is authorized to provide OLP with their Personal Information. Use of the Website in this manner automatically presumes that User has obtained proper authorization from the owner/s of the Personal Information and have informed said person/s of this Privacy Notice. User hereby represents and warrants that all family, friends or employees whose personal information User has provided to OLP have agreed to the use, processing, storage and/or disclosure of their data in accordance with this policy and all applicable laws.
    7. 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.
    8. The App may - if you choose to sign in with Facebook - access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
    9. User information from social networking sites, such as Facebook, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the App.
    10. 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.
    11. We may request access or permission to certain features from your mobile device, including 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.
    12. 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.
    13. 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.
    14. Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

3. USER CONSENT AND USE OF INFORMATION

  1. By continuing to use the website, User consents to the collection, processing and/or storage of any Personal Information and thus such 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.
  2. 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.
  3. Having accurate information, the user permits us to provide the him/her with a smooth, efficient, and customized experience. Specifically, we may use information collected about the user via the App to:
    1. Generate a personal profile about the user to make future visits to the App are more personalized.
    2. Monitor and analyze usage and trends to improve your experience with the App.
    3. Notify you of updates to the App or Site.
    4. Request feedback and contact user about user's use of the App.
    5. To improve our website and products.
    6. 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 has provided.
  4. We will also require user to link either his/her Google Play Account with our App if user wish to purchase one of our Premium subscriptions. This does not give us access to user credit card or banking information, but is needed so that we can process user's purchases/subscriptions.

4. RIGHTS OF THE USER

  1. The User shall have the following rights as a Data Subject:
    1. Right to be Informed — You have the right to know when and how your personal data is collected, processed, and shared. This includes being informed of the purpose, scope, and extent of processing, as well as the identity of the personal information controller (PIC).
    2. Right to Object — You may object to the processing of your personal data, including cases where the processing is based on consent or legitimate interest, or where your data may be used for direct marketing, profiling, or automated processing.
    3. Right to Access — You have the right to reasonable access to your personal data, including information about its source, recipients, and manner of processing, subject to applicable regulations.
    4. Right to Rectification — You may request correction of any personal data that you believe is inaccurate, outdated, incomplete, or misleading.
    5. Right to Erasure or Blocking — You may request the suspension, withdrawal, blocking, removal, or destruction of your personal data if it is found to be unlawfully obtained, unnecessary, excessive, or no longer relevant to the purposes for which it was collected.
    6. Right to Damages — You are entitled to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
    7. Right to Data Portability — Where technically feasible, you may request a copy of your personal data in an electronic or structured format that allows for further use or transfer to another entity.
    8. Right to File a Complaint — You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your personal data has been misused, mishandled, or otherwise not processed in accordance with the Data Privacy Act.
  2. Inquiries and requests regarding the rights of the User, including any objections to or complaints regarding the OLP's Processing of your Personal Data, can be sent to the DPO via email [email protected]
  3. If you feel that the OLP has not responded in an appropriate manner to the requests of the User or complaints regarding the Processing of User's Personal Data, User shall have the right to complain to the National Privacy Commission through their website or email [email protected]

5. ANTI-MONEY LAUNDERING COMPLIANCE

  1. 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.
  2. Being a Covered Institution under AMLA, OLP will ask for the User's name, gender, date of birth, address, telephone/mobile number, email address, proof of identification, government-issued ID numbers (such as but not limited to TIN, SSS, GSIS, PhilHealth, UMID, Passport), biometric data (such as fingerprints or facial images), employment details, or financial information (such as bank account or credit card details), that will allow OLP to identify the User.
  3. OLP may also ask to see the User's TIN, SSS, GSIS, PhilHealth, UMID, Passport or other competent evidence of identity bearing the User's photograph and signature in order to comply with AMLA and other applicable laws and regulations.

6. USER DATA LEGAL BASIS OF PROCESSING

  1. Without limitation to the foregoing, User data may be processed by OLP among others for the following purposes:
    1. Verify the User's identity;
    2. Manage the provision of services being offered by the Website, such as processing the loan application or rendering the loan credit decision, among others;
    3. Evaluate the User's credit standing through external credit report providers and bureaus;
    4. Contact the User;
    5. Transfer the loan proceeds;
    6. Manage and recover outstanding debt;
    7. Update the information regarding the loan granted;
    8. Enhance the User's customer experience and improve, develop and determine customized products to meet customer preferences and needs;
    9. Send commercial communications on the products and services;
    10. Improve the service and contents of the service through statistical analysis and market research;
    11. Abide by any safety, security, public service or legal requirements and processes;
    12. Process information for statistical, analytical, and research purposes;
    13. 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
    14. Other specified and legitimate purposes determined and declared before, or as soon as reasonably practicable after collection of the Personal Information
  2. OLP also uses the User's Non-Personal Information for statistical, analytical, and research purposes to create anonymous and aggregate reports.
  3. 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.
  4. OLP outsources or contracts the processing of User Data to third parties, such as but not limited to the following parties: vendors, service providers, partners or other telecommunications operators, to fulfill any of the above purposes. These parties are only authorized to use User Data for such contracted purposes. These parties may have access to User Data for a limited time under reasonable contractual and technical safeguards to limit their use of such information. OLP requires these parties to protect User Data in compliance with this Privacy Notice.
  5. 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.

7. THIRD-PARTY LINKS AND OTHER COMPANIES / ORGANIZATIONS

  1. Links to other websites (i.e. third-party links) may appear on which have its own Privacy Notice and are understood as accepted by clicking on them. This Privacy Notice does not apply to such third-party links that may appear on the Website. The responsibility of OLP with regard to the User's Data extends only to the Website proper.
  2. This Privacy Notice also does not regulate the data processing activities of other companies and organizations that advertise OLP's services.
  3. The Company may share the following personal information, only as necessary and permitted by law:

8. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

OLP may share only the relevant and necessary Personal Information with authorized third-party, partners and service providers for legitimate business and regulatory purposes. These may include:

  1. Regulatory Agencies (e.g., SEC, BIR, NPC, BSP) — basic identification details, government-issued registration numbers, and transaction records as required by law.
  2. Credit Bureaus and Credit Information Systems — name, date of birth, contact information, credit history, and loan repayment records.
  3. Payment Partners (e.g., banks, e-wallet providers, remittance centers) — account number, transaction amount, and reference details needed to process payments or disbursements.
  4. IT and Cloud Service Providers — account identifiers, login credentials, and usage logs necessary for system hosting, maintenance, and security.
  5. Collection Agencies (if applicable) — contact information, outstanding balance, and repayment history for legitimate collection activities.
  6. Legal, Audit, and Compliance Consultants — only the records necessary for compliance review, dispute resolution, or audit purposes.

Please note that some of these third parties may be located in other countries with different rules and regulations on processing personal information. By agreeing to this Privacy Notice you acknowledge that Personal Information can be transferred cross-border to other countries and you are consenting to such transfer.

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, 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.

OLP may share information OLP has collected about user in certain situations. User information may be disclosed as follows:

OLP will not sell, distribute, or lease user personal information to unrelated third parties unless OLP has user permission or are required by law to do so. OLP may need to send user personal information to our third-party vendors, who are under contractual obligations to keep this information confidential. OLP may also use user personal information to send user promotional information about third parties which OLP thinks user may find interesting if user tell us that user wish this to happen. Finally, if OLP ever sell or participate in a merger or consolidation, and our User data is one of the assets involved in the sale, user personal information will be part of this sale or transfer.

OLP may also disclose user personal information:

9. COOKIES AND WEB BEACONS

OLP may use cookies, web beacons, tracking pixels, and other tracking technologies on the App to help customize the App and improve user experience. For more information on how OLP use cookies, please refer to our Cookie Policy posted on the App, which is incorporated into this Privacy Notice. By using the App, user agree to be bound by our Cookie Policy.

10. THIRD-PARTY WEBSITES

The App may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with OLP. Once user have used these links to leave the App, any information user provide to these third parties is not covered by this Privacy Notice, and OLP cannot guarantee the safety and privacy of user information. Before visiting and providing any information to any third-party websites, user should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary, in your discretion, to protect the privacy of your information. OLP is not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the App. User should exercise caution and look at the privacy statement applicable to the website in question.

11. 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.

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.

12. 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.

13. PERSONAL INFORMATION STORAGE

OLP will retain your Personal Information as long as you are a User, has not withdrawn User's consent or no longer necessary and relevant for the Services. OLP may also retain Personal Information to comply with the requirements of any laws and regulations for a minimum period of at least five (5) years, to prevent fraud, to resolve disputes and various troubleshoot problems, and to take other actions permitted or required by applicable laws and regulations.

  1. Manner of Storage and Access

  2. Under our data policies, we will securely dispose of Personal Information in accordance with applicable laws and regulations once it is no longer necessary or relevant for our Services. As required by the Securities and Exchange Commission (SEC), certain records and personal data will be retained for a minimum of five (5) years. Beyond this period, data will only be retained if laws require a longer retention period or if disposal is specifically requested in writing by the User, subject to applicable legal requirements.

14. SECURITY

Security of User's Personal Information is OLP priority. Except as indicated in this Privacy Notice, OLP will not disclose User's Personal Information to third parties without User's express consent. Further, OLP will take all reasonable procedures and exert our best efforts to ensure all Personal Information received shall be kept confidential and secure, whether online or offline. OLP will protect User's Personal Information using a variety of technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. OLP may use and amend from time to time various security measures, as new technology becomes available, as appropriate, such as firewalls and data encryption, access controls to data centers.

The Company employs administrative, technical, and physical security measures designed to protect personal data from unauthorized access, use, disclosure, alteration, or destruction. Access to the data storage portal is restricted through the use of a secure Virtual Private Network (VPN), and any request for access is subject to prior approval by management. Only duly authorized personnel are granted such access, subject to strict role-based limitations, and no individual may alter or modify the personal data provided by users without proper authorization and documented justification. While reasonable safeguards have been implemented in accordance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and issuances of the National Privacy Commission, the Company acknowledges that no security system is infallible and that data transmission over the internet carries inherent risks of interception or misuse. Notwithstanding these limitations, the Company remains committed to enforcing robust security protocols and continuous monitoring to ensure the integrity and confidentiality of all personal data under its custody.

15. MOBILE ACCESSIBILITY

OLP may offer User the ability to connect with our Services using a mobile device, either through a mobile application or via a mobile optimized website. The provisions of this Privacy Notice apply to all such mobile access and use of mobile devices.

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.

16. USER CONFIDENTIALITY

To further secure the privacy of your Personal Information, we advise to keep your any account details confidential at all times.

17. PRIVACY NOTICE UPDATES

OLP may update or amend this Privacy Notice from time to time by posting a revised version on the Website. User is advised to review this Privacy Notice periodically for the latest information. Changes to this Privacy Notice are effective from the date of posting. If OLP makes any substantial changes to this Privacy Notice and the way in which OLP will use your Personal Information, OLP will post these changes on the Website and will do its best to notify User of any significant changes. By continuing to use our Services, User accepts and consents to the updated terms of this Privacy Notice.

18. 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 via email [email protected].

19. COMPLIANCE WITH LEGAL OBLIGATIONS

We may process and disclose your personal information when required to comply with applicable laws, rules, and regulations, or when directed by government authorities, courts, regulatory bodies, or law enforcement agencies. This includes, but is not limited to, compliance with requirements of the Securities and Exchange Commission (SEC), Bureau of Internal Revenue (BIR), Bangko Sentral ng Pilipinas (BSP), National Privacy Commission (NPC), and other government agencies with jurisdiction over our operations.

20. CONTACTS

User can review and change user personal information by logging into user profile through the website or App and visiting user account profile page or settings page. User may also send us an e-mail at [email protected] to request access to, correct or delete any personal information that user have provided to us. We may not be able to delete user personal information except by also deleting your user account. We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect. Upon user request to terminate user account, we will deactivate or delete user account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

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: Unit 601, Summit One Office Tower, 530 Shaw Blvd. Brgy. Highway Hills, Mandaluyong City