Privacy Policy

Effective: May 2019 | Last Updated: October 2023

1. LEGAL STATUS AND CORPORATE BACKGROUND

Philippine Microdot Financing Corp. ("Company", "we", "our", "us") is a financial entity duly incorporated under the laws of the Philippines, bearing SEC Registration No. CS201907350 and holding Certificate of Authority No. 1214 (CA No.). Our registered office is located at 5th Floor Rockwell Business Center Tower 1, Meralco Avenue, Ugong, City of Pasig, NCR, Second District, Philippines. This Privacy Policy ("Policy") is an electronic record in the form of an electronic contract formulated under the Indian Information Technology Act, 2000 and the Rules made thereunder, specifically the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. This Policy describes how we collect, store, share, process, and protect your personal data. By accessing our website or applying for our loan services, you signify your consent to this Policy. If you do not agree with any terms herein, please stop using our services immediately.

2. CATEGORIES OF DATA COLLECTED

To provide accurate credit assessment and related financial services, we collect and process the following data: A. Data Collected at Signup and Onboarding: Basic Identity Info: Full name, mobile number, email ID, gender, date of birth, and marital status. Statutory Identifiers: PAN number and verified identity documentation numbers. Contact and Geolocation: Residential address, pin code, and real-time geolocation data from your mobile device (subject to your permission) to mitigate credit risk and prevent fraud. B. Financial and Credit Assessment Data: Income Verification: Monthly income, employer name, official employment email, and tenure of employment. Financial Documents: Including but not limited to bank statements, salary slips, tax records (e.g., TIN), and other records reflecting your financial standing. KYC Information: Photograph, parents' names, bank account number, IFSC code, and Officially Valid Documents (OVDs) such as Driving License, Voter's ID, or Passport. C. Device and Technical Data: Unique Identifiers: Hardware model, operating system version, IMEI, serial number, SSAID, and SIM card information. Network Details: IP address, MAC address, Wi-Fi information, and mobile network operator details. App List: We may monitor the package names, installation time, and versions of applications installed on your device to enrich your credit profile. D. Multimedia and Sensor Access: Microphone: Permission required for two-way audio communication during Video KYC or identity verification journeys. Storage and Camera: To allow secure uploading of proof of employment, education, or identity documents to accelerate the approval process.

3. PURPOSES OF DATA PROCESSING

The data collected will be used for the following core business functions: Underwriting: To verify identity, assess credit risk, and determine eligible loan amounts, interest rates, and tenures. Service Operations: To manage your account, facilitate disbursements, track repayments, and process transactions. Security and Compliance: To detect and prevent fraud, identity theft, and illegal activities, ensuring compliance with AML regulations in India and relevant jurisdictions. Customer Support: To communicate via various channels (Calls, SMS, Email, WhatsApp) for issue resolution and service notifications. R&D and UI/UX: To conduct de-identified data analysis for improving product features, user experience, and automated decision-making systems.

4. SHARING AND DISCLOSURE

We are committed to protecting your privacy. We share data only under the following legitimate circumstances: Affiliates and Service Providers: Sharing with trusted partners (e.g., payment gateways, cloud providers, KYC vendors, and collection agencies) to ensure service delivery. Credit Bureaus: As per statutory requirements, credit information is reported to authorized Credit Information Companies (e.g., CIBIL, Equifax, Experian). Legal and Governmental Requests: Disclosure in response to court warrants, government orders, or regulatory inquiries related to investigations of illegal activities. Third-Party SDKs: Our application may link to registered third-party SDKs that collect data on our behalf for credit risk modeling, stored on secure servers.

5. DATA SECURITY PRACTICES

We implement robust technical and organizational measures to safeguard your information: Encryption: Best-in-class protocols for data in transit and at rest. Audits: Regular penetration tests, vulnerability assessments, and maintenance of firewalls and anti-virus solutions. Staff Compliance: Limiting access to authorized personnel only, all of whom are bound by strict non-disclosure agreements. User Responsibility: You are responsible for maintaining the confidentiality of your ID and password. The Company is not liable for leakages caused by user negligence or inherent weaknesses of the internet.

6. DATA RETENTION AND DELETION

Retention Period: Data is retained only as long as necessary for the purpose of collection. Financial and identity records are typically retained for at least ten years from the date of transaction to meet legal and audit requirements. Deletion Rights: You may request account deletion via support@philmicrodot.com. If you have outstanding loans, we reserve the right to continue processing your data until the debt is fully repaid. Archiving: Post-deletion, minimal fields (Mobile Number, User ID, Profession) will be archived for compliance purposes as per RBI and statutory guidelines.

7. YOUR LEGAL RIGHTS

Under applicable laws, you possess the following rights: Right to Rectification: To request updates to inaccurate or outdated personal data. Right to Withdraw Consent: To revoke authorization by uninstalling the app or providing written notice (may result in discontinuation of services). Right to Opt-Out: To unsubscribe from promotional communications, though essential non-promotional notices (e.g., repayment receipts) will still be sent.

8. MINORS' PRIVACY

Our services are not directed at individuals under 18. If we discover that personal information has been collected from a minor, we will take immediate steps to delete the data and terminate the account.

9. AMENDMENTS

We may update this Policy occasionally. Material changes will be published on our Website or App. Continued use of the services after such updates constitutes your acceptance of the revised Policy.

10. CONTACT AND GRIEVANCE REDRESSAL

For any privacy-related queries or complaints, please contact our Grievance Officer: Email: philmicrodot@gmail.com Phone: 02-7455340 / 09171640428 Address: 5th Floor Rockwell Business Center Tower 1, Meralco Avenue, Ugong, City of Pasig, NCR, Second District, Philippines.