Disclosure Statement and Privacy
Policy
About us:
Company information:MICRODOT LENDING CORPORATION
SEC Registration Number:CS201951287
Certificate of Authority to Operate a Financing/Lending (CA) Company Number
:
No.: 2921
registered office:6/F Aster Business Center Mandala Park, 312 Shaw Boulevard,
Mandaluyong City Metro Manila 1550.
Credit Peso ("Credit Peso", "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 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.
1. What Personal Information We Collect
When you use Credit Peso, in order to process and handle your use, Credit Peso
shall in accordance with the law only collect information that is strictly necessary and shall not
use it for other purposes. The specific information collected is as follows:
1)SMS
With your consent, we will only access your financial SMS list and other personal
SMS will not be accessed.
By collecting the number of financial SMS and transaction records, we use it to
identify and analyze your behavior and risks when taking multiple loans, assess whether the loan can
be processed in a fraud-proof manner, and verify the user's financial transactions within the
platform, making accurate credit limit decisions based on the user's spending budget and payment
ability. This helps us identify different bank accounts and cash flow patterns that users may have,
and help you as a customer process transaction amounts.. It's also used for the purposes of risk
analysis.SMS data will be encrypted anduploaded to our servers
https://mic.microdotlending.top/
2
)CAMERA
With your consent, we will obtain your permission to take photos. This permission
will allow you to upload photos. This permission needs to be manually confirmed by you before we can
obtain it.We require the camera information permission to provide you an easy/smooth experience and
to enable you to click photos of your KYC documents along with other requisite documents and upload
the same on the Platform during your loan application journey.Photos are stored encrypted on our
servers at https://mic.microdotlending.top
Credit Peso 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 Credit Peso'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, Credit Peso will only share your information with third parties on an
anonymous basis.
3
)IMAGE INFORMATION
We will collect photos taken by users during the loan application process and
photos actively selected and uploaded by customers for KYC verification and anti-fraud inspection
purposes only. We will not access, retrieve and collect any other photos from your device's
gallery.We are committed to encrypting the information and ensuring the security of the
information,so this information will be encrypted and uploaded to https://mic.microdotlending.top/
4
)APP INSTALLED
We are a financial application. We need to collect the App installed in your device
so as to protect your fun d safety and to prevent frauds. We need this information for your risk
assessment and to recommend
suitable products.
5
)PHONE INFORMATION
The device information includes the phone number of the SIM card, device brand,
model, operating system version, de vice unique identifier, device network environment, WiFi, device
status, identification international mobile device, international mobile subscriber identification,
application software information, mobile phone number, device memory information. The authorization
to access this information help us to identify your user portrait and preferences and to recommend
the suitable credit products. We collect the phone number of the SIM card to facilitate the login
process. When we have identified the phone number of the SIM card from the user
’
s
phone, the user can log in directly. without requiring an OTP code. The information
is also used to prevent frauds that act on your behalf.
The phone number data will beencrypted and uploaded to our
https://mic.microdotlending.top/
6)Location data (e.g., mobile device location, time zone setting);Other
information:We may collect some of your other personal information only after obtaining your
additional explicit consent.
Credit Peso reserve the right to request for additional documentation to verify the
information provided by you. Your submission of any information to us, our authorized agents or the
Platforms expressly contains your warranty that such information is accurate and not misleading.
2.How We Use Your Personal
Information
One of our primary purposes in collecting Personal Information is to
establish a safe, smooth, efficient and customized experience that allows our users to take full
advantage of the products and services available through
Credit Peso
. During the course of your availment of our service,
Credit Peso
may utilize, process and/or disclose your Personal Data to
Credit Peso
’s affiliates, subsidiaries and partner companies for any of the following purposes
(“Permitted Purpose”):
1) to authenticate your identity;
2) to assess and process your applications for
Credit Peso
’s products and/or services;
3) to handle complaints and queries, to communicate with you
including
but not limited to sending you updates and reminders, responding to your inquiries and/or complaints and
resolving disputes;
4) to manage and maintain your accounts/facilities with
Credit Peso
;
5) to conduct credit checks/credit evaluation to assess or verify
your
credit/financial worthiness and to assist other financial institutions to conduct credit
checks;
6) to evaluate your financial needs;
7) to utilize the same for marketing and promotions;
8) to maintain your credit history for present and future
references;
9) to detect and investigate crime, fraud or illegal activities, and
to
utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions,
including know your customer (KYC);
10) to respond to the requirements of a civil or criminal legal
process
and/or for regulatory compliance purpose and/or as required by law or regulation;
11) to collect any debt due or owing by you, and to enforce your
obligations to
Credit Peso
;
12) to compile, use, research, analyze, and generate data analytics
reports to better understand our customer with the aim of improving our products and services and
product development;
13) to provide you with the information on our and third-party
products
and services which may be of interest to you;
14) to compare information/data for accuracy of our record, and to
verify the same with third parties;
15) to utilize the same for customize and enhance user experience and
improvement of our products and services, operational and business processes;
16) to support our business, financial and risk monitoring, planning
and decision-making and to utilize and disclose the same for audit and compliance, no matter from
outsourcing of business and internal operations;
17) to transfer or assign our rights and duties under any governing
terms and conditions between
Credit Peso
and yourself;
18) to transfer your Personal Data to local and/or foreign
jurisdictions for the purpose of processing and storage and to enable any transactions, for the
performance of a contract, products and/or services, for the purposes of legal proceedings;
19) for any other purposes that is required or permitted by any law,
regulation, order and/or guidelines.
Credit Peso
may use "cookies" and other technologies such as pixel tags and
web beacons. These technologies help
Credit Peso
better understand user behavior, tell
Credit Peso
which parts of our products/services have visited or used, and
facilitate and measure the effectiveness of advertisements and searches.
3.
How does
Credit Peso
use your Information?
a. 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’ll use automated processing to decide
whether to lend to you and/or make other decisions about your eligibility for our products and services,
based on the Information collected. 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 data science and
machine-learning technology to process your Information and assess your creditworthiness. 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
Credit Peso
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 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
If you apply for a loan and your loan is declined (or you are
informed
that you are ineligible for other or associated products or services) as a result of an automated
credit, underwriting or fraud decision, you may request that one of our underwriters review this
decision. You may contact us through the contact information shown on the mobile app
b. Develop and manage our relationships with you
and
our Business Partners. This may include: (i) delivering services or carrying out
transactions
that you or our Business Partners have requested; (ii) providing information about
Credit Peso
products, services, and transactions, and advertisements, that
may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in
interacting with
Credit Peso
, including by learning more about you and how you use and interact
with
Credit Peso
Internet Sites, Apps, products, and services; and (iv)
planning,
managing, and performing under our contractual relationships with our Business Partners.
c.
Communicate with you. This may
include: (i) informing you of
Credit Peso
products, services, and promotional activities that may be of
interest to you; (ii) providing information about relevant
Credit Peso
products, services, and transactions, including, for example,
pricing, information about product or service improvements; (iii) responding to questions or inquiries
that you make, including customer service requests; and (iv) inviting you to participate in, or
informing you of the results of, customer satisfaction or market research surveys.
d. Provide and improve our Internet Sites, Mobile
Application, products, and services. This may include: (i) customizing them to your preferences or
interests, making them more compatible with your technology, or otherwise making them easier to use;
(ii) maintaining the security of and otherwise protecting them; and (iii) and developing new
Credit Peso
Internet Sites, Mobile Application, products and
services.
e. Address legal issues. This may
include: (i) complying with our obligations to retain certain business
records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii)
complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and
responding to fraud, intellectual property infringement, violation of our contracts or agreements,
violations of law, or other misuse of
Credit Peso
Internet Sites, Apps, products or services; and (v) protecting
Credit Peso
’s rights or property, or yours or others’ health, safety, welfare, rights, or
property.
4. Who do we share your Information
with?
Credit Peso
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
Credit Peso
'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,
Credit Peso will only share your information with third parties on an anonymous
basis.
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
Credit Peso
(collectively, the "
MICRODOT LENDING CORPORATION
G
ROUP
");
employees, subcontractors, agents, service providers, or associates
of
the
MICRODOT LENDING CORPORATION
(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
Credit Peso
(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
Credit Peso
and/or any company within the
Credit Peso
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
Credit Peso
, the
Credit Peso
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,
Credit Peso
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.
5.
For how long will we retain your
Information?
Your Personal Data will be stored or retained by
Credit Peso
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 defenses.
Your Personal Data will be retained by the Company for the duration
of
your activities and transactions in connection with the products and services availed of in this
Microdot Lending Corporation Corp and/or for such period of time required for legal and regulatory
and/or other legitimate business purposes, and will be disposed of in a secure manner that would prevent
further processing, unauthorized access or disclosure to any other party or the public or prejudice your
interest, provided that the Company may retain copies of your Personal Data in the Company’s archives
for the purpose of determining its continuing obligations or pursuant to its bona fide record retention
or data back-up policies, access to which shall be restricted on a need-to-know basis, as may be
required under applicable laws and regulations.
The Personal Data may likewise be retained for the purpose of fraud
prevention, detection, and monitoring in accordance with the Company’s fraud detection and prevention
policies, and any requirement imposed by any credit agency, bureau or agency in order to prevent fraud,
identify theft, anti-money laundering, terrorist financing and other similar causes which are consistent
with public policy and the public good.
6. Where do we process, store or transfer your
information?
Your Personal Data including your transaction data is stored in the
secure third-party cloud service provided by our cloud service providers (Amazon and Alicloud) who are
among the best-of-breed cloud providers in the industry.
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.
Credit Peso
will use all reasonable and appropriate efforts as required by
applicable law to protect your Information.
We may use third-party Service Providers to monitor, analyze, support
and improve the use of our Service. In order to facilitate the process for you to obtain our services,
we use the following SDKs in our application:
Firebase Cloud Messaging
Firebase Cloud Messaging SDK, provided by Google LLC, has been
registered in the Google Play SDK Console. We use this SDK in our application to collect Firebase
installation ID, FCM registration token, application information, device information, notification
delivery status and notification interaction information in order to send push notifications, service
messages, repayment reminders, overdue reminders, account security alerts, coupons, promotional offers
and other information related to Credit Peso products and services. This SDK uses HTTPS to encrypt data
in transit to ensure the security of your personal data.
For more information on the privacy practices of Google, please visit
the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Facebook Android SDK
Facebook Android SDK, provided by Facebook, has been registered in
the
Google Play SDK Console. We use this SDK in our application to collect advertising identifier and
application activities, including webpage visits, clicks within the application and other actions,
solely to understand your actions in our app and measure the performance of our mobile application
ads.
Adjust SDK
Adjust SDK, provided by Adjust GmbH, has been registered in the
Google
Play SDK Console. We use this SDK in our application to collect advertising identifier, Android ID,
device type, device model, system type, application activities, including webpage visits, clicks within
the application and other actions, solely to record activations, app opens, sessions and in-app events.
In-app events mean user behaviors such as in-app registration or applying for a loan. We will use these
events to measure ROI and user quality. This SDK adopts encrypted transmission on data transmitted
through it to ensure the security of your personal data.
Liveness Detection SDK
We use Liveness Detection SDK in our application to collect device
type, device model, system type, app name, app version number and sensors, including gravity sensor,
magnetic field sensor, accelerometer and gyroscope sensor information, solely to efficiently identify
identity fraud and improve the accuracy of detection of retakes and deep fake frauds with close-up and
long-range images.
7. 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
Credit Peso
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 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
:
support@creditpeso.com
.
8. Your rights as a data subject
You may contact us to exercise your rights at
support@creditpeso.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
Credit Peso
App 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).
9. Advertising and Marketing
You may opt out from receiving advertising, marketing or promotional
messaging by contacting us and making such request through
support@creditpeso.com
and we will remove you from such communication lists.
10. Deletion of Personal
Information
If you want to stop using our service and delete your personal
information, it can be done in the following t
wo
ways:
a
. You can ask us to delete your personal information.
Please send us a request email to delete personal information at
support@creditpeso.com
, we will complete your request within five days.
b
. You can wait for us to automatically delete your personal
information.
When you stop using our services for more than 12 months, we will
automatically delete your personal information.
If you still have outstanding bills, you will not be allowed to
delete
your personal information.
Only when all your bills have been settled can you successfully
delete
your personal information through the above
two
ways.
11. Consent and Authorization
By downloading the
Credit Peso
App, you:
accept the terms of this Privacy Policy;
give
Credit Peso
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
Credit Peso
is true and correct to the best of your knowledge;
authorize
Credit Peso
to verify/investigate the accuracy of your Information;
and
acknowledge that
Credit Peso
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.
12. General
If you need to contact us, please do so at:
support@creditpeso.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
Credit Peso
App or by email.