Thank you for trusting CashPautang(“Application”) provided by Armorak Lending Inc. (“We”), a company with SEC Registration No.CS201908271. We hereby adopt this Privacy Policy in compliance with the provisions of Republic Act No.10173, an Act protecting individual personal information.This Privacy Policy ensures that the personal data gathered from our clients(“You”) 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 and so on. You must read this Privacy Policy in its entirety.
A.What information we collect from yog
a) As part of our operations, we collect and process certain types of information, including but not limited to:
Email address;
First name and last name;
Phone number;
Address, State, Province, ZIP/Postal code, City;
Usage Data;
Bank Verification Number (BVN);
National Identification Number (NIN);
additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers;
comments, questions, requests and orders you may make;
financial information needed to process loans and payments, such as credit card or account information or other banking information;
information regarding your location.b)While using our Application, in order to provide features of our Application, we may collect following information, with your prior permission:
Mobile phone/DeviceUpload and monitor the information about your device. The device information we need is the unique device identifier such as device name, model, region, status, language, device identification code, device software and hardware information, usage habits, IMEI, and serial number to confirm the uniqueness of the device and ensure the security of your account.ContactsPermission is needed for us to access your contact list in order to collect all your contacts, including contact name, phone number, and date of addition.
The purpose of using the contact list information is to confirm your credit rating and to support the add contact function when applying or borrowing.MediaThe identity authentication picture you upload will allow us to evaluate your credit, so you can obtain a credit limit and enjoy a smooth loan experience;LocationWe need your device location authorization to collect location-related information, which includes the location method of the user device, location time, longitude, latitude, current location, location area code, etc.
Using your location information, we will be able to check your credit rating as well as increase the security of your account. In the event that an abnormality is discovered, you will be notified promptly.CameraOnly for photographing document information.Application listWe will also read the list of applications installed on your device, which will be used to screen for malware and cheaters, so as to maintain the environment of the mobile phone system and the security of lending services.Phone numberWe will also obtain your local number to assist in identifying your identity to ensure the security of your account and funds. Once any abnormality is found, we will freeze your account in time and send you a notice in time.CalendarWe also need you to grant read and write access to the calendar, which will allow us to alert you in advance of the repayment date to avoid late fees; At the same time, we will not delete or modify the information you have written, but only evaluate the loan schedule to confirm your loan eligibility.c)We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor.d)With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your account, we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable laws.
B.What are the purposes for which your Information is processed and how we use your Information
a)We use your Personal Information to:
provide you with the required services;
pursue the repayment of loans made to you;
to maintain up-to-date records;
to attend and manage your requests to us;
for the performance of a contract between us;
to respond to your questions or requests;
to contact you by email, telephone calls, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications;
improve features, website content and analyse data to develop products and services;
address inappropriate use of our website;
prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools;
send you marketing content, newsletters and service updates curated by We, however, we will provide you with an option to unsubscribe if you do not want to hear from us;
verify your identity and the information you provide in line with We’s statutory obligations using internal and third party tools;
resolve disputes that may arise, including investigations by law enforcement or regulatory bodies;
any other purpose that we disclose to you in the course of providing We services to you;For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.b)Purpose LimitationWe collect Personal Information for identified purposes, and provision of loaning service, and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.c)Data MinimizationWe limit Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
We only collect and upload your data when the APP is running/opened. We do not collect and upload when not using the APP.
C.Who we share your Information with
We may share your personal information in the following situations:share with service providers to monitor and analyze the use of our services, to contact you;
share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company;
share Your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us;
share Your information with our business partners to offer you certain products, services or promotions;
disclose your personal information for any other purpose with Your consent.
D.The Data that We Retain
We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.We are statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.
Therefore, even after closing your account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by us where possible. For all Personal Data and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.The length of storage of Personal Information shall be determined by:the contract terms agreed between us and you or as long as it is needed for the purpose for which it was obtained;
whether the transaction or relationship has statutory implication or a required retention period;
whether there is an express request for deletion of Personal Data by you, provided that such request will only be treated where you are not under any investigation which may require us to retain such Personal Data or there is no subsisting contractual arrangement with you that would require the processing of the Personal Data;
whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
E.Where we process, store or transfer your information
In providing you with the services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in the Philippines and your personally identifiable information is treated in a safe and secure manner.a)Third Party Processor within the PhilippinesWe may engage the services of third parties in order to process the Personal Information of Data Subjects collected by us. The processing by such third parties shall be governed by a written contract with us to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.b)Transfer of Personal Information to Foreign CountryWhere Personal Information is to be transferred to a country outside the Philippines, we shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the White List of Countries with adequate data protection laws.Transfer of Personal Information out of the Philippines would be in accordance with the provisions of the Philippines Data Protection Regulation. We will therefore only transfer Personal Information out of the Philippines on one of the following conditions:
Your consent has been obtained;
The transfer is necessary for the performance of a contract between us and you.
The transfer is necessary to conclude a contract between us and a third party in the interest of you.
The transfer is necessary for reason of public interest;
The transfer is for the establishment, exercise or defense of legal claims;
The transfer is necessary in order to protect the vital interests of you or other persons, where you are physically or legally incapable of giving consent;
We will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside the Philippines shall be provided to you upon request.
F.Your rights regarding your information
You are entitled to reach out to us to exercise the following rights:Right to request for and access your Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, you have a right to receive that data in a common electronic format;
Right to objection or request for restriction;
Right to object to automated decision making;
Right to request rectification and modification of Personal Information which we keep;
Right to request for deletion of your data;
Right to request the movement of data from us to a third party.
Right to object to, and to request that we restrict the processing of their information.
Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your personal Information when it is requested by us, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.
G.Updates, modifications and amendments
We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. We reserve the right to make changes to this Privacy Policy from time to time and notify you of material changes. The Privacy Policy will apply from the effective date provided on our website.If you object to any of the changes to this Privacy Policy, you must cease using this Site, or terminate your account in the event that an account has been created.
H.Cookies
We use cookies to identify you as a User and make your user experience easier, optimize our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website.Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.
I.Contact us
If you need to contact us, please do so at: service@cashpautang.com