Statement of Policy

The information contained in the Cashalo facility (the “Facility”) on the website, mobile application, or other related digital medium or media (each and collectively the “Site”) has been prepared in accordance and in compliance with the laws of the Republic of the Philippines, and is for the exclusive use of Oriente Express Techsystem Corporation (the “Company” or “Oriente”), its assigns, affiliates, and related companies in the conduct of its business in the Philippines (the “Oriente Group”).

This Statement of Policy sets out the policies of the Company, its assigns, affiliates, and related companies in relation to any and all types of personal information, including sensitive personal information, as defined under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (hereinafter referred to as the “Data Privacy Act”), which may be provided by individuals, whether as prospective lenders or borrowers (the “User” or “Users”), for the collection and use of the Company, its assigns, affiliates, and related companies, and from which the identity of the individual may be apparent or can be reasonably and directly ascertained.

The Company values the privacy of its Users and any user and visitor of the Site. The Company is committed to the protection of any and all personal information which may be provided by its Users or any Site visitor.

Personal Information Collected and Handled

When a User creates or registers an account in the Company’s Site, or uses the Company’s digital channel or software, or when the lenders and borrowers enter into a transaction, or when a User engages the services of the Company, the Company may collect the following personal information (hereinafter referred to as “Personal Information”):

• Full name, permanent and residential address, contact number/s, email address, birth date and/or age, employment information, bank account details, credit card and/or financial account information, financial history, transaction history, purchase history and details of government-issued identifications;

• other information from which the User’s identity may not be apparent or which may not reasonably and directly identify the User, such as, but not limited to, records of the User’s visits and information submitted when using the Site;
• information from third parties including information obtained, upon User’s authorization, from User’s employers, past and present (“Employment Information”), and transaction, financial and credit history, past or present, stored by third parties (“Transaction and Credit Information”) pursuant to the User’s Authorization duly signed and approved by the User; and

• traffic and usage information generated from the User’s visits and use of the Site.
The Personal Information may be collected through various means including: cookies, flash cookies, general log information, User browsing behavior, User searches and transactions and other information from third-parties.
The Personal Information may be processed in behalf of the Company by personal information processors, in each case mindful of your rights and our obligations under the Data Privacy Act of 2012.

Use/Purpose

The Personal Information shall be collected, processed, used, disclosed, stored and retained for the following purposes:

• to identify Users;

• to contact Users in relation to their registered account/s or requested information;

• to process registration of account/s as part of screening of the lenders, borrowers, and loan applications;

• to maintain internal records;

• to carry out marketing and promotions initiatives relating to the Company, offers from affiliates of the Oriente Group, Oriente’s partners, and Oriente’s products and services, whether by electronic means, by email and post, or by telephone, SMS or social media, or by sending newsletters (for example, for the Users to be updated on new products or features and to publicize events, contests, demonstrations, loyalty programmes, and other activities organized by Oriente), also by using automated means. Such communications will relate to products and services of the financial products, services and the like. In addition, Oriente will process your data for market research, statistical analyses, or other research to improve its products, and customer satisfaction analysis;

• to analyse User behavior, generating user or credit score, or for user profiling, (e.g. in relation to financing products availed, provided, viewed, and searched) in order to provide appropriate and useful services to lenders and borrowers; and

• to generate a credit score, credit profile, and User model.

Sharing of Personal Information

Your Personal Information may be shared with Oriente Group in the conduct of its business for processing as may be required in the maintenance and performance of its business activities and in the performance of its duties and responsibilities under the Site, in accordance with applicable laws, rules and regulations. The Oriente Group may, as necessary, be engaged by Oriente as subcontractors or data processors in each case with respect to the purposes enumerated above.

As a lender, your Personal Information may be shared with borrowers in the site.
As a borrower, your Personal Information will be shared with the lenders in the site in order to allow the lenders to assess your credit history and such other information the lender will require to confirm your credit history and credit score. Your information may also be shared with third party purchasers of any Non-Performing Loans.
The Personal Information of a User will likewise be shared to third parties (e.g. collection agents and banks) who are engaged, used, or is otherwise authorized by either the lender or the borrower to provide any support or service with respect to any transaction concluded by the lender and borrower.

The Personal Information of a User may shared and disclosed to the following: (a) Oriente Group or the JG Group and their affiliates and subsidiaries, agents (including collection agencies), and subcontractors, which are necessary for the conduct of Oriente’s business; (b) The lenders with respect to Personal Information of borrowers, and the borrowers with respect to Personal Information of the lenders; (c) third party providers who require the information to facilitate the loan, including but not limited to the payment, remittance, credit check (credit bureaus, service providers, service history, bank history, financial history, spending history, among others), background check, or processing of loan to the borrower, payments to the lender, agent of the lender or the borrower, transfer of the loan to a third party (i.e. financing company, new lender, monetary authority); (d) the government, regulatory agencies, and fraud prevention agencies for the purposes of identifying, preventing, detecting or tackling fraud, money laundering, or other crimes, and for other lawful purposes; and (e) other entities as may be required by law or as public interest may warrant.

All data processing, subcontracting or data sharing agreements will be in accordance with the requirements under the Data Privacy Act of 2012, or applicable laws and regulations as may be hereafter passed and implemented. To the extent that such processing, subcontracting, or data sharing requires notice or consent, we will provide or request for such notice and/or consent, in each case, prior to any processing or sharing of your Personal Information.

Retention of your Personal Information

The Personal Information 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 Site and/or for such period of time required for legal and regulatory 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 Information in the Company’s archives for the purpose of determining its continuing obligations under this Agreement 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.

Security of your Personal Information

The Company values the Personal Information collected, used, retained and stored through its Site, and will ensure that it is protected from possible threats, both online and offline. The Company has the necessary technical, organizational and physical measures to ensure that the Personal Information is kept safe and secure, as well as to prevent unauthorized access or disclosure of the collected and stored Personal Information.

Access and Correction of Personal Information

If you wish to exercise your right to access, correction, cancellation, portability and objection rights as described below, or for complaints and other inquiries, please send a registered letter with return receipt to 16F World Plaza Building, 5th Avenue, Bonifacio Global City, Taguig City 1634, Philippines or email hello@cashalo.com to the attention of Data Privacy Officer:

• to receive details of the source of the data, the purposes and methods of the processing, the logic applied to the processing, or if the latter is carried out with the help of electronic means, of the identity of data controller and data processors, the entities or categories of entity to which the data may be communicated and which may become aware of the data;

• to update, correct, supplement, or delete the data, to block or render anonymous data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which such data have been collected or subsequently processed; to have a certification that the operations requested have been completed, as also related to their contents, to the entities to which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; to receive the personal data concerning you and copy or transmit it to another data controller (right to data portability); and

• to object, on legitimate grounds, to the processing of data, despite the data being relevant to the purposes for which they were collected or to object, also partially (e.g. only in relation to certain communication means), to the data being processed in order to send advertising materials or for direct sales, or market research, or commercial information, profiling purposes, or to receive communications by traditional means only.

Log Data

When a User or visitor visits and/or uses the Site, the User’s or visitor’s browser/interface may send the Company personal information which the Company collects for statistical and internal record-keeping purposes. The process of collecting this information is called “Log Data”, and may include information such as the computer’s Internet Protocol (IP) address, browser type, browser version, the visited pages of the Website, the time and date of the visit, time spent on the pages, and other statistics.

Cookies

A cookie is a small file which asks permission to be placed on the visitor’s computer hard drive. Once the visitor agrees, the file is added and the cookie helps analyze web traffic or provides internet usage information. A visitor can instruct his or her browser to refuse all cookies or to indicate when a cookie is being sent. However, if the visitor does not accept cookies, the visitor may not be able to use some portions of the website. A cookie in no way gives the Company access to the visitor’s computer or any information about the visitor, other than the data the visitor chooses to share with the Company.

Control over your Personal Information

Users retain control over their Personal Information, and may amend their personal information registered in the Site database.

The User shall be responsible for maintaining the confidentiality of his or her own account and password, as well as any and all applications submitted, obligations agreed to or entered into and all other activities that occur under the said account. The User agrees to immediately notify the Company of any unauthorized use or disclosure of the User’s account or password, any unauthorized activities under the User’s account or any other breach of security.

The Company will not be liable for any loss that the User may incur as a result of a third party’s use of the User’s account or password, either with or without the User’s knowledge, without fault or negligence on the part of the Company. The User may be held liable for any damage or loss incurred by the Company in connection with or arising from a third party’s use of the User’s account or password, without fault or negligence on the part of the Company.

Changes on our Privacy Policy

This Privacy Policy is in effect as of 23 May 2018 and shall continue to remain in effect unless otherwise amended.

The Company reserves the right to amend this Privacy Policy from time to time, upon due notification to its Users or visitors.

If significant changes to this Privacy Policy will affect certain Personal Information, the Company shall notify its Users through the email address provided or by posting a public notice on the Website.

Contact Us

For any questions, concerns or clarifications about the Company’s Privacy Policy, the Company may be contacted through the customer support system at hello@cashalo.com

ACCEPTANCE

I confirm having read and understood and agree to the foregoing Privacy Policy.