DATA PRIVACY POLICY STATEMENT
DIGIDO FINANCE CORP.

Statement of Privacy Policy

Digido Finance Corp. (DFC) is committed to protecting the privacy of its data subjects, and ensuring the safety and security of personal data under its control and custody. This policy provides information on what personal data is gathered by DFC about its current, past, and prospective clients and employees; how it will use and process this; how it will keep this secure; and how it will dispose of it when it is no longer needed.

This information is provided in compliance with the Philippine Republic Act No. 10173, also known as, the Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations (DPA-IRR). It sets out DFC’s data protection practices designed to safeguard the personal data of individuals it deals with, and also to inform such individuals of their rights under the Act.

This Data Privacy Notice and Consent Form may be amended at any time without prior notice, and such amendments will be notified to you in via DFC’s website or by email.

For DFC Employment Applicants, Employees and/or Consultants

• Contact information, such as, name, addresses, telephone numbers, email addresses and other contact details;
• Personal information, such as date and place of birth, nationality, immigration status, religion, civil status, government-issued IDs, web information, recommendations and assessment forms from present1 and previous employees, etc.;
• Disclosures on family background, including information on parents, guardians, siblings, related DFC stockholders, directors, and/or employees, etc.;
• Photographic and biometric data, such as, photos, CCTV videos, fingerprints, hand writing and signature specimens;
• Employment Records, educational data, including data gathered using third party online tools or sourced from third party service providers;
• Financial data including but not limited to the disclosures from BAP, NFIS, CIC and other credit unions or reporting agencies, and/or transaction records/history with banks and/or other financial institutions;
• Records regarding their previous and pending court cases, if there are any;
• Health records, psychological evaluation results, disciplinary records, and physical fitness information;
• Contact information of the employees employment reference, including but not limited to the following personal data: name, address, phone numbers, email, employment details, and his/her connection with the client;
• Other personal and/or sensitive personal information, which was disclosed to DFCat any stage of the application or employment;

Channels of Data Collection

DFC shall collect information about the data subject in the following ways:

1. Information that the data subject provided DFC through communications with DFC employees or its application;
2. Information that the data subject authorized DFC to collect through its applications, such as photographs obtained via access to data subject’s smartphone camera or photo gallery, phone, email, or social media contact lists and metadata for the purpose of KYC and preventing fraud, or credit scoring and/or verification;
3. Information from outside sources such as credit bureaus and customer service providers to help us with customer verification and credit-related decisions.

Use of Information

For Clients

The collected personal data is used solely for the following purposes:

1. Processing of credit application of client and confirmation of the identity of prospective client and their reference or guarantors;
2. Processing of credit application, including verification and confirmation of all disclosed personal and sensitive information.;
3. Conduct of the ‘Know Your Client’ exercises to establish and verify the identity of the prospective client, prevent and/or detect possible attempts to commit fraud and other related criminal offenses, credit scoring, credit verification, and comply with the regulations of the Anti-Money Laundering Council;
4. Analyze disclosed personal data of the data subjects and data subject’s reference or guarantor/s, to be able to craft products and services tailored the needs and requirements of the data subjects;
5. Verifying authenticity of financial and personal records and documents;
6. Analysis, validation and evaluation of the financial documents, to establish credit worthiness of the client and determine potential risks. This includes sharing of client’s personal data and sensitive personal information to Third-Party Service Providers (TPSPs) such as JuicyScore (https://score.jcsc.online/), for risk profiling, risk scoring, identity verification and validation, and fraud detection and/or prevention, using automated-identity verification systems. TPSP such as JuicyScore uses these shared personal data and sensitive personal information, for and in behalf of DFC, only for the purposes specified in the Service Level Agreement and as described herein, to which the existing and prospective clients consents. JuicyScore and all other TPSPs DFC contracted to process personal data and/or sensitive personal information shall not keep, retain, and/or maintain DFC’s existing and prospective client’s personal data or sensitive personal information DFC shared to them;
7. Facilitate and complete the transaction applied, share it within our group of companies and offer the clients products suitable or relevant to their requirements and/or profile;
8. Protect personal information and sensitive personal information disclosed to secure accounts from fraud and other illegal activities;
9. Perform legal and regulatory duties to further improve due diligence in anti-money laundering and counter-terrorism efforts as well as other mandatory and required activities by the law or regulations by our supervising agencies;
10. Settle claims or disputes involving DFC’s products and services. The personal data or sensitive personal information may also be used for prosecuting or defending DFCor its employees when needed;
11. Share or disclose personal data and/or sensitive personal information to third-party service provider, as may be required by law, regulation, or by a court order;

For Employment Applicants and Employees

1. DFC uses employee data for variety of personnel administration, work and general management purposes, such as administration of compensation and benefits, performance evaluation and reviews, learning and development, promotion and succession planning and to maintain efficient and effective records management;
2. DFC may also use your information in confidential references in connection with your applications for employment (eg. data verification of school credentials and previous employers) or further education or financial references; and where an employee is undertaking a further study or training which DFC has paid for, or made a financial contribution towards specific information on such member of employee’s professional growth and development and achievement;
3. DFC may also use your information in order to publicly recognize your achievements, accomplishments and celebrations. Should you wish to opt out for this purpose, please contact the People and Culture Department;
4. DFC may also use your information to further enhance the policies, programs, compensation and benefits regime, and other services offered by the People and Culture Department;
5. DFC may also share your information with third party contractors who perform services on our behalf, such as reviewing and developing our business systems, procedures and infrastructure (including testing or upgrading our computer systems), the provision and administration of legal and accounting advice, insurance, retirement funds, and employee benefits. Finally, for human resources purposes DFC may also share your information with the client(s) to whom you may be or are assigned to perform services;
6. DFC may also share your information with other credit unions, government agencies and other regulatory bodies such as but not limited to accrediting agencies for the verification of your personal data held by the Corporation;
7. DFC may also share your information with banks, financial/credit companies, and other institutions conducting character or background investigation.

Information Sharing

All personal data and information collected and/or were disclosed by the data subjects by reason of their application, transaction, and/or any interaction with the Corporation will be uploaded and stored on our server (https://api.unacash.com.ph), and will not be shared with any third party.

DFC will not share your personal data with third parties unless necessary for the above-mentioned purposes and unless you give your consent thereto. Such third parties may include DFC’s business units, subsidiaries, affiliates, agents, outsourced service providers and other third parties.

We engage outsourced service providers to support us in delivering services to you. Our third parties include government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction. We engage third parties for the following reasons:

• Verify your personal information
• Assist in business operations
• Comply with legal requirements
• Enforcing our terms of use including, among others, our rights as creditor to customers availing of our loan or credit products, or such other applicable policies with respect to the services that we provide
• Addressing fraud, security or technical issues, to respond to an emergency or otherwise protect the rights, property or security of our customers or third parties
• Carrying out all other purposes set out above

Personal data shared with third parties shall be covered by the appropriate agreement to ensure that all personal data is adequately safeguarded.

DFC does not, will not, sell personal data to any third party. All our engagements with third parties shall be fully-compliant with our obligation of confidentiality imposed on us under applicable agreements and/or terms and conditions or any applicable laws that govern our relationship with you.

Personal data under the custody of DFC shall be disclosed only to authorized recipients of such data. Otherwise, we will share your personal data with third parties only with your consent, or when required or permitted by our policies and applicable law, such as with:

Data Transfer

Where DFC consider it necessary, indispensable or appropriate, for the purposes of data storage, enhanced security, account processing, providing any service or product on our behalf to you, or implementing new or enhanced system for our products and services, we may transfer the custody of your personal data to third parties within or outside of the Philippines, under conditions of confidentiality and similar levels of security safeguards.

Security

DFC strictly enforces data privacy and information security policies. It implements technological, organizational and physical security measures to protect your personal data against loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put safeguards such as the following:

• We keep and protect data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls
• We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality
• We train our employees to properly handle your data
• We require our third parties to protect personal data aligned with our own security standards.

We continue to implement organizational, administrative, technical, and physical security measures to safeguard your personal data. Only authorized personnel have access to your personal data, the exchange of which is facilitated through internal shared servers, email, and paper files.

Should third parties need access to your personal data, we require some form of data sharing agreement with them, in compliance with the DPA and the DPA-IRR.

The hard copy of the documents submitted to DFC and its digital files are securely stored: employing physical security in its principal place of business to safeguard the paper files and technical security to protect the digital files.

Retention of Information

DFC stores personal data and sensitive personal information in a data center (on premise and cloud) and physical document storage facilities.

It retains personal data only according to its operational needs and in compliance with legal and regulatory purposes or requirements. DFC’s data retention and disposal policy is in accordance withR.A. 9470 (National Archives of the Philippines Act) and AMLC and/or BSP regulations, if applicable. In general, DFC shall only retain your personal data and sensitive personal information for five (5) years after the processing relevant to the purpose has been terminated. However, DFC may retain your data when necessary to establish, exercise or defend legal claims, for legitimate business purposes, or when provided by law.

In compliance to NPC Circular No. 20-01, data subjects are given the option to disable features and functionalities relating to disclosure of personal data of reference and/or guarantors within the mobile app/platform, after the completion of the processes, where such personal data or information was collected. However, notwithstanding the aforementioned provisions of the law, DFC has the right to continue processing information about a person even without his consent in cases where this is necessary to protect the life, health or other vital interests of the data subject, the operator or third parties or where it is directly enshrined under Sec. 13 of the Data Privacy Act of 2012.

Completeness and Accuracy of Personal Data and Sensitive Personal Information

Data subjects should ensure that personal data submitted to DFC is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. Data subjects should inform DFC immediately of any change of facts or circumstances which may render any personal data or information previously provided inaccurate, untrue, or incorrect and provide any information or documentation DFC may reasonably require for the purposes of verifying the accuracy of the updated information or personal data.

DFC strongly encourage data subjects to be vigilant in protecting your personal data by ensuring that their account details, PINs, username and password are secured and not disclosed to others or written somewhere accessible to others. DFC advises the data subjects to exercise caution in protecting themselves against phishing, skimming and other electronic fraud and to remain alert for suspicious looking offers, pretending or representing from the Corporation. DFC advises its clients that DFC will only communicate through its official channels and applications.

Rights of the Data Subjects

Under the Data Privacy Act, data subjects have the following rights:

1. Right to be informed;
2. Right to object;
3. Right to access;
4. Right to rectify or correct erroneous data;
5. Right to erase or block;
6. Right to secure data portability;
7. Right to be indemnified for damages;
8. Right to file a complaint.

DFC’s decisions to provide access, consider requests for correction or erasure, and address objection to process data as it appears in its official records, are always subject to applicable internal policies, relevant laws and regulation.

Contact Digido Finance Corp.

For further inquiries or complaints, please visit our website at https://www.unacash.com.ph or get intouch with our Compliance Department at (02) 8539-2143 loc. 4002 or 4004 or email us at dpo@unapay.com.ph.

Data privacy requests and concerns

For data privacy requests and concerns, you may write to our Data Protection Officer at dpo@unapay.com.ph or

Data Protection Officer
Compliance Department
Digido Finance Corp.
15/F IBP Bldg., Jade Drive
Ortigas Center, San Antonio
1605 Pasig City

Changes in the Data Privacy Notice

DFC may amend this Data Privacy Notice in whole or in part to ensure that it is consistent with industry trends, legal and regulatory requirements applicable to how we handle your personal data and to ensure better protection of your personal data or information. Relevant updates will be posted on this site.

Consent

The submission of personal data and information by the data subject to DFC signifies that he or she have read and understood the above Privacy Notice and expressly agree and give his or he consent to the processing of his or her personal and/or sensitive personal information in the manner and for the purpose provided in this Notice. The data subject understands and accepts that this will include access to personal data and records submitted, which may be regarded as personal and/or sensitive personal data as provided under the Data Privacy Act of 2012.

DFC is also authorized to disclose the data subject’s data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign, in the following circumstances:

• As necessary for the proper execution of processes related to the declared purpose;
• The use or disclosure is reasonably necessary, required or authorized by or under law;
• Provided security systems are employed to protect the personal data or information;

Consenting to this Privacy Notice, however, does not waive any of the data subject’s rights under the Data Privacy Act of 2012.

For complete reference on the Data Privacy Act, please visit the National Privacy Commission website at https://www.privacy.gov.ph.