Privacy Policy

1. Compliance with Philippine Data Privacy Law

We comply with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. We process personal data fairly, lawfully, and transparently, and uphold the principles of transparency, legitimate purpose, and proportionality.

2. Data Protection Officer (DPO)

We have appointed a Data Protection Officer (DPO) responsible for overseeing our compliance with the Data Privacy Act and protecting your personal data. You may contact our DPO using the details below:

3. Information We Collect

We collect the following categories of personal and sensitive personal information:

3.1 Information You Provide Directly

• Full legal name, date of birth, gender, civil status, nationality
• Government-issued ID (e.g., SSS, GSIS, PhilHealth, Passport, Driver's License, UMID, Voter's ID)
• Residential and permanent address
• Mobile number and email address
• Employment information: employer name, position, monthly income, length of employment
• Bank account or e-wallet details for loan disbursement and repayment
• Loan application details: purpose, amount requested, preferred terms

3.2 Information Collected Automatically

• Device information: device model, operating system, unique device identifiers (Android ID)
• IP address, mobile network, and location data (with your permission)
• App usage logs and interaction data
• SMS metadata for income and repayment behavior assessment (only if you grant permission)

3.3 Information from Third Parties

• Credit bureau reports (e.g., Credit Information Corporation / CIC)
• KYC verification services for identity authentication
• Partner financial institutions and payment processors

4. Data Collection from Mobile Devices — Permissions

The App may request the following device permissions. Each permission is optional and will be requested separately with an explanation of its purpose:

4.1 SMS

We use the mobile number you voluntarily provide during registration or the loan application process solely to send you service-related, non-marketing notifications via SMS. These include One-Time Password (OTP) verification codes, account security alerts, loan application status updates, notifications regarding loan disbursement or repayment transactions, repayment reminders, and essential customer service information.

Subject to your explicit authorization, this app may collect SMS data from the past six months related to loan applications, identity verification, risk assessment, anti-fraud measures, account security, and repayment capacity assessment. The scope of collection may include the sender's number and name, message content, timestamps, and records related to financial transactions, income, repayments, billing, or account security.

We do not use SMS data for advertising or marketing, sell it to third parties, or use it for purposes unrelated to our loan services. We will not disclose your SMS data to unrelated third parties without your prior consent or unless permitted by applicable laws and regulations.

SMS data is transmitted via an encrypted connection to our server: https://www.makati-pesocashloan.com/

It is used exclusively for loan application review, identity verification, credit risk assessment, fraud prevention, account security, repayment reminders, and legal compliance.

You may revoke SMS-related permissions via your device settings. Revoking authorization may affect certain automated risk assessment, loan application review, or account security verification functions.

If you wish to delete your personal data, please contact our customer service team at [email protected]. We will process your request within 3–5 business days of receipt and verification, except where otherwise required by laws, regulations, loan record retention policies, risk audits, dispute resolution, or regulatory mandates.

4.2 Camera (Identity Verification and KYC)

To comply with the requirements of the Philippine Securities and Exchange Commission (SEC) and applicable laws and regulations regarding Know Your Customer (KYC) procedures, this app may request access to your device's camera during identity verification. Camera permissions are used solely for the following purposes:

1. Capturing and submitting photos of government-issued identification documents;

2. Taking selfies or performing facial liveness checks;

3. Verifying that the applicant matches the holder of the identification document;

4. Preventing identity theft, fake registrations, duplicate applications, and other fraudulent activities.

The camera is used only when you actively initiate identity verification, document capture, or facial liveness checks. This app does not use the camera in the background, does not record audio or video unrelated to identity verification, and does not access your photo albums, photo libraries, videos, external storage, or other local files.

Identity verification data collected via the camera is transmitted securely (encrypted) to our server: https://www.makati-pesocashloan.com/ and is used solely for identity verification, loan application review, fraud prevention, account security, and legal compliance purposes.

4.3 Approximate Location (Anti-fraud purposes only)

This app does not request, collect, or track your precise GPS location information, nor does it continuously track your location in the background.

To confirm service availability, ensure account security, and mitigate risks associated with irregular applications, we may use the residential address you voluntarily provide, the approximate region derived from your IP address, network status, or non-precise regional information you authorize us to access as supplementary data for assessment.

The aforementioned information is used exclusively for loan application review, determining service availability, account security, and fraud prevention; it is not used for advertising, marketing, continuous location tracking, or purposes unrelated to loan services. You may manage relevant permissions via your device settings; however, disabling these permissions may affect certain security checks or the application review process.

4.4 Installed Application Information

To detect potential financial fraud, automated bot activity, device cloning, emulator abuse, multi-instance tools, malicious tools, irregular application behavior, and other account security risks, this app may—upon obtaining your explicit authorization—scan and collect information regarding applications installed on your device.

Collected information may include application names, package names, version numbers, installation times, update times, and relevant device risk characteristics. We do not read in-app chat content, files, account details, photos, videos, transaction details, or other private data from other applications. This data is processed only when you use or launch the app, log in to your account, submit a loan application, enter the application process, or undergo a risk assessment; it will not be used for advertising or marketing, sold to third parties, or used for purposes unrelated to loan services.

Information regarding installed applications is transmitted via an encrypted HTTPS protocol to our risk assessment server: https://www.makati-pesocashloan.com/

It is used solely for identity verification, credit risk assessment, anti-fraud measures, account security, duplicate application detection, anomalous device identification, and legal compliance.

You may manage relevant permissions through your device settings. Refusing or revoking permissions may affect our ability to complete automated risk assessments, fraud detection, or the review of your loan application.

4.5 Emergency Contacts

To provide financial services and ensure the security of your loan application, we may request information on two emergency contacts or references, including their names, their relationship to you, and their phone numbers.

You may voluntarily submit emergency contact information by entering it manually. We collect only the contact information you actively fill in and confirm for submission; we do not read, scan, upload, or store your full address book or mobile contact list, nor do we collect contact information that you have not voluntarily submitted.

Before submitting emergency contact information, you should ensure that you have obtained authorization from the contact person or have a legitimate basis for providing such information. Emergency contact information is used solely for identity verification, loan application review, account security, fraud prevention, repayment reminders, or post-loan communication permitted by law; it will not be used for advertising, marketing, or any unauthorized purposes.

All data is securely encrypted and transmitted to our server via https://www.makati-pesocashloan.com/.

4.6 Device Model and Status

To ensure account security, maintain the proper functioning of the app, perform identity verification, prevent fraud, and meet compliance requirements, this app may collect necessary device and technical information. This includes device model, device brand, operating system version, app version, SDK version, language and region settings, network type, mobile carrier information, IP address, crash logs, diagnostic logs, login records, and security event records.

We do not collect non-resettable hardware identifiers such as IMEI, IMSI, or SIM serial numbers. Device and technical information is used solely for app operation and maintenance, account security, fraud prevention, detection of anomalous logins and duplicate applications, troubleshooting, customer support, and legal compliance; it will not be sold to third parties or used for advertising or marketing unrelated to loan services.

5. Purpose and Legal Basis for Processing

We process your personal data for the following purposes, each grounded in a lawful basis under the DPA:

• Loan application processing, credit scoring, and underwriting — based on contractual necessity and legitimate interest
• Identity verification and fraud prevention — based on legal obligation and legitimate interest
• Loan disbursement and collection — based on contractual necessity
• Customer support and communication — based on legitimate interest and consent
• Regulatory reporting and compliance with BSP and SEC requirements — based on legal obligation
• Service improvement, analytics, and product development — based on legitimate interest
• Marketing and promotional communications (only with your separate consent)

6. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

• Credit bureaus and the Credit Information Corporation (CIC) as required by law
• Third-party service providers: cloud hosting, payment processors, KYC/AML verification partners, SMS gateway providers
• Debt collection agencies, subject to strict data processing agreements and in accordance with SEC Memorandum Circular No. 18, Series of 2019
• Government regulators and law enforcement agencies when required by law, court order, or legal process
• Business successors in the event of a merger, acquisition, or corporate restructuring

All third parties we engage are required to handle your data in accordance with the DPA and our data processing agreements.

7. Loan Collection Practices

In line with SEC Memorandum Circular No. 18, Series of 2019 and Republic Act No. 11765 (Financial Products and Services Consumer Protection Act), we commit to the following:

• We will NOT contact persons in your contact list for collection purposes
• We will NOT send harassing, threatening, or abusive messages
• We will NOT publicly disclose your debt or personal information
• Collection will only be conducted through authorized and identified personnel
• Borrowers have the right to file complaints with the SEC regarding abusive collection practices

8. Data Retention

We retain your personal data for the following periods:

• Active loan records: duration of the loan and up to five (5) years after full settlement
• Declined applications: up to two (2) years
• Identity verification records: as required by applicable KYC/AML regulations
• Marketing data: until you withdraw consent

After the applicable retention period, your data will be securely deleted or anonymized.

9. Data Security

We implement appropriate technical and organizational security measures, including:

• AES-256 encryption for data at rest and TLS 1.2+ for data in transit
• Access controls and role-based permissions for internal staff
• Regular security assessments and vulnerability testing
• Incident response and breach notification procedures

In the event of a data breach that may affect your rights and freedoms, we will notify the relevant authorities within 72 hours and affected individuals without undue delay.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights:

• Right to be Informed — to know how your data is collected and used
• Right to Access — to request a copy of the personal data we hold about you
• Right to Rectification — to correct inaccurate or incomplete data
• Right to Erasure / Blocking — to request deletion or blocking of your data under certain conditions
• Right to Object — to oppose processing based on legitimate interest or for direct marketing
• Right to Data Portability — to receive your data in a structured, commonly used format
• Right to Lodge a Complaint — with the relevant data protection authority

You have the right to be informed if your loan application is processed via automated decision-making or credit scoring systems. If you disagree with the automated result, you have the right to request a human review by contacting our DPO.

To exercise your rights, please contact our Data Protection Officer at the details below. We will respond within fifteen (15) business days.

11. Cookies and Analytics

Our App does not use browser cookies. We may use third-party analytics tools (such as Firebase Analytics) to understand app performance and user behavior. These tools collect anonymized usage data. You may opt out by adjusting your device's advertising settings.

12. Children's Privacy

Our services are not directed to individuals under eighteen (18) years of age. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal information, please contact us immediately and we will take steps to delete such data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. We will notify you of material changes through the App or via email at least seven (7) days before they take effect. Continued use of the App after the effective date constitutes your acceptance of the updated Policy.

14. Contact Information

For questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

This Privacy Policy is written in English and Filipino (Tagalog). In case of conflict, the English version shall prevail.

Last Updated: July 5, 2026