PRIVACY POLICY
SULIT LENDING CORPORATION, its assigns, affiliates, and related companies in the conduct of its business in the Philippines (hereinafter referred to as "Company") value the privacy of our Users and any person who use, access, download, browse, or register with the Services on https://api.perasure.ph website, its application, or other related digital medium or media including social media (hereinafter referred to as "Platform"). This Privacy Policy is part of commitment of PeraSure to respect and protect the personal data and information belonging to the individual users of the Platform, including prospective lenders or borrowers (hereinafter referred to as "User", "you", or "Users") and visitors to the Platform.
This Privacy Policy sets out the policies of the Company, its assigns, affiliates, and related companies in relation to any and all types of Personal Data (as defined below) referred to in this Privacy Policy, including sensitive personal information. This Privacy Policy has been prepared in accordance and in compliance with the laws of the Republic of the Philippines, including Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (the "Data Privacy Act"), its Implementing Rules and Regulations (the "IRR"), the issuances of the National Privacy Commission (the "NPC"), Republic Act No. 9510 (Credit Information System Act), Republic Act No. 11765 (Financial Products and Services Consumer Protection Act), and all other applicable laws and regulations of the Securities and Exchange Commission (the "SEC") and Bangko Sentral ng Pilipinas ("BSP").
In this Privacy Policy, "Personal Data" means any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual. This includes sensitive personal information as defined under the Data Privacy Act, such as biometric data, government-issued identification numbers, and financial information.
The scope of this Privacy Policy is limited to information collected or received by us through your use of the Platform. We are not responsible for the actions of third parties or companies, the contents of their facilities, the use of information you provide to them, the information they provide to you or any products or services they may offer. Any link to those sites does not constitute our partnership with, sponsorship or endorsement of, or affiliation with, those parties or companies or their brands.
By using the services provided by the Platform, whether via the website or application, you are expressing your agreement to this Privacy Policy and the processing of your Personal Data in the manner provided herein. If you do not agree to these terms, please do not use and immediately exit the Platform.
We collect information to provide better service to our users. We will not collect your personal data without your permission. In accordance with the principle of proportionality under the Data Privacy Act, we endeavor to only collect personal data that is adequate, relevant, and not excessive in relation to the declared and specified purposes for which it is processed.
When joining as a member, we may collect the following information for the user's personal identification: (1) full name, (2) email address, (3) residential address, (4) phone number, (5) Guarantors (if any) and Character References (if any), (6) employment information, (7) monthly income, (8) date of birth, (9) gender, (10) government-issued ID information, (11) beneficiary's bank account information, (12) Social Media account, (13) biometric data consisting of facial recognition elements in order to corroborate your identity and (14) other information that users opt to provide through the Platform.
We collect information about the applications and devices you use to access the services of the Platform, which helps us to provide you with services. The information and permissions we collect include (1) location, (2) Guarantors (if any) information, (3) camera, (4) files, (5) device information and (6) phone number. We endeavor to only collect permissions that are necessary for a specified and legitimate purpose. When the purpose for an application permission has already been achieved, we may prompt you to turn off, disallow, or revoke such permission.
We collect your coarse-location information when the Platform is running in the foreground so as to auto-fill your address data in your loan application process. We will cease the collection of your coarse-location information when the Platform is running in the background. You can always choose to disable the coarse-location tracking information permission on your mobile device temporarily.
We require camera permission to enable you to take photos and upload the same on the Platform during your loan application journey.
The device information includes but not limited to device brand, model, operating system version, device unique identifier, device network environment, WiFi connection, device status, identification international mobile device, international mobile subscriber identity, application software information and device memory information. We collect information about your device to provide automatic updates and additional security so that others cannot use your account on your behalf. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our services and provide an enhanced customized user experience to you.
You must submit to us information including Personal Data which is true, accurate and not misleading, and you must keep it up to date and inform us of changes as soon as practicable. We reserve the right to request documentation to verify information provided by you.
We will only be able to collect your Personal Data if you voluntarily submit the information to us. If you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with some or all of the services available through the Platform.
You have the privacy right to your personal data. Our company will only disclose your personal data to third parties under the following circumstances. The relevant institutions will collect, use, and/or disclose your personal data within the scope of your authorization and consent, and subject to appropriate data sharing or outsourcing agreements as required under the Data Privacy Act:
(a) disclosure to our employees, agents, holding companies, subsidiaries and affiliates;
(b) disclosure to enable you to trade and/or use services that you desire with the specific written or recorded consent of the User;
(c) disclosure to the Credit Information Corporation (CIC) and/or CIC-accredited credit bureaus and special accessing entities (SAEs), for the purpose of obtaining, verifying, and updating your credit data or credit reports, as may be necessary for your loan application, account management, credit evaluation, monitoring, or as required by Republic Act No. 9510 (Credit Information System Act) and the Data Privacy Act;
(d) disclosure of information upon orders of a court of competent jurisdiction or any government office or agency authorized by law;
(e) disclosure to collection agencies, counsels and other agents engaged by us to enforce our rights against the User, provided that such collection agencies comply with SEC Memorandum Circular No. 18, series of 2019 on Prohibition on Unfair Debt Collection Practices;
(f) disclosure to third party service providers for the purpose of assisting or rendering services to us in the administration of our lending business (including fund lenders, payment partners, post-loan partners, third-party verification service providers, messages service providers, call-out service partners), subject to appropriate data sharing or outsourcing agreements; and
(g) disclosure to third parties such as insurance companies, solely for the purpose of insuring us against the User’s default or other credit loss and the User from fraud or unauthorized charges.
Personal Data shall be processed, collected, used, disclosed, stored, and retained for the following purposes, which are declared and specified in accordance with the principle of legitimate purpose under the Data Privacy Act:
(a) to authenticate the identity of Users and conduct background checks and identity verification;
(b) to contact Users in relation to their registered account/s or requested information, and to respond to User queries and requests, resolve complaints and handle requests and inquiries;
(c) to process registration of account/s and to determine or assist in determination of decisions as part of screening of the investors, borrowers, registrations or loan applications, and/or to deliver our products and/or services to the User and any directly related purposes;
(d) to facilitate loan processing from application, review, monitoring, payment, collection and other remedial measures;
(e) to maintain internal records;
(f) to request, obtain, and process your credit data or credit reports from CIC and/or its accredited bureaus, for credit evaluation, decisioning, risk assessment, account management, collections, dispute resolution, and other lawful purposes related to lending operations, with your express consent as required under Republic Act No. 9510 (Credit Information System Act) and the Data Privacy Act of 2012;
(g) to develop and generate a credit score, credit model and user model, including through automated decision-making and profiling; you shall be informed of the existence of such automated processing and its significance;
(h) to conduct and perform fraud monitoring, detection, analysis and prevention; to prevent, detect and investigate actual or suspected crime and analysing and managing commercial risks; and to perform research on data to conduct investigations relating to disputes, payment, suspected illegal activities or fraud;
(i) to conduct data analytics and tracking, and to conduct market research to enable the Company to understand and determine customer location, preferences and demographics to develop special offers, products or marketing programs in relation to products and services, and to improve (i.e. customized offers and products) such products and services;
(j) to market and offer new, related or complementary products and services to the User, and to carry out marketing and promotions initiatives relating to the Company, local affiliates of the Company, the Company’s partners, and other Company’s products and services, whether by electronic means, by email and post, or by telephone, SMS or social media, or by sending newsletters, including by using automated means, subject to your separate and freely given opt-in consent;
(k) to develop, enhance and maintain a risk assessment process and model, offline and online;
(l) to enrol/participate the user in group credit and/or life insurance, credit risk analysis, credit investigation, credit scoring and credit collection on the User;
(m) to perform User location search;
(n) to execute, monitor, manage and analyse the Platform and to develop, enhance, and upgrade the features, functions, products and services in the Platform, including promotions, loyalty and reward programs;
(o) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) of the Company;
(p) to facilitate and as may be required as part of any financing or capital raising activity (i.e. obtaining loans, credit facility, mortgage, assignment, assignment as a form of security or mortgage of loans);
(q) to initiate and maintain correspondence with the User via electronic mail (e-mail), SMS (short messaging service), in-app message/communication, registered mail, phone calls or field visits;
(r) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(s) to provide information to external parties such as government agencies, and other institutions as part of scientific research and/or study; and
(t) for any other legal and/or regulatory purposes (including but not limited to obtaining legal advice and dispute resolution) and legitimate business purposes and to carry out all mandatory administrative, operational and legal duties.
5.1 By proceeding with your loan application and using the facial recognition feature, you hereby give your express and unequivocal consent to the Company to collect, use, process, and store your biometric data (i.e., facial data). We collect your facial data by requesting you to take a live face photo during the facial recognition process and will use and process it for the following purposes:
(a) to verify your identification;
(b) to prove the loan is applied by yourself, at the time of loan application and any other time thereafter, including when there is a dispute regarding the loan; and
(c) to prevent loan fraud.
5.2 This information will be uploaded to our server https://api.perasure.ph. You expressly authorise us to hold your face photo until you fully repay the loan and other amounts payable, if any, or such longer period as may be required by applicable law, e.g., applicable statute of limitations, etc. If you need to delete your face photo data immediately, you shall notify us via email to help@perasure.ph.
5.3 We will not share your face photo with third parties except for the purpose of presenting evidence to a court or arbitral tribunal in the resolution of a loan-related dispute and when ordered to do so by a court of competent jurisdiction or any government office or agency authorized by law. You acknowledge and agree that these courts, tribunals and/or authorities will retain your data for the duration mandated by applicable law.
6.1 We will hold your Personal Data only for as long as is required by applicable law and necessary to allow the purpose for which the data is collected and used. We shall retain personal data of borrowers only for as long as necessary for the fulfillment of the purposes for which the data was obtained, for the establishment, exercise, or defense of legal claims, or as provided by law.
6.2 Thereafter, we shall endeavor to ensure the secure and proper disposal and destruction of personal data in a manner that would render further processing impossible. If you need to request immediate deletion of your data, you shall notify our customer service center via email to help@perasure.ph, subject to any legal obligations that may require us to retain certain data.
7.1 The Company values Personal Data collected, used, retained and stored through the Platform. The Company has adopted technical, organizational and physical measures to protect your Personal Data in accordance with the applicable laws and regulations.
7.2 We take reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration by third parties, including encryption of personal data during storage and while in transit.
7.3 Although we make good faith efforts to store the information collected on the Platform in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our system. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining access to this information. To the fullest extent permitted by law, we do not warrant or represent that your information will be absolutely protected against loss, misuse, or alteration by third parties.
8.1 In the event of a personal data breach that is likely to give rise to a real risk of serious harm to any affected data subject, we will notify the National Privacy Commission and the affected data subjects within seventy-two (72) hours upon knowledge of, or when there is reasonable belief that, a personal data breach requiring notification has occurred, in accordance with Section 38 of the IRR of the Data Privacy Act.
8.2 The notification shall describe the nature of the breach, the personal data possibly involved, and the measures taken by the Company to address the breach, including measures to reduce the harm or negative consequences of the breach.
9.1 By using the Platform and submitting your Personal Data, you hereby expressly consent to the transfer, storage, and/or processing of your Personal Data to a country outside the Philippines in connection with the purposes described in this Privacy Policy. We shall endeavor to ensure that any such transfer is made only to countries or organizations that provide an adequate level of protection for personal data, or pursuant to appropriate contractual safeguards, or with your consent as provided herein, in accordance with Section 21 of the Data Privacy Act and Rule XII of the IRR.
9.2 Where personal data is transferred to a third-party service provider outside the Philippines, we shall endeavor to ensure that such third party is bound by contractual obligations equivalent to those imposed on us under the Data Privacy Act. You acknowledge and agree that, notwithstanding such contractual safeguards, the laws of the country to which your Personal Data is transferred may differ from the laws of the Philippines.
9.3 To comply with regulatory Know-Your-Customer (KYC) requirements and ensure secure identity verification, the personal and sensitive identity information you provide (including but not limited to government-issued IDs, facial biometric data, and personal profiles) will be securely transmitted, processed, and stored utilizing cloud infrastructure. Specifically, this data will be uploaded to the Huawei Cloud Object Storage Service (OBS) at the following dedicated endpoint:
dxcloud-sg-ph-prod.obs.ap-southeast-3.myhuaweicloud.com
You agree to inform us promptly, and in any event, within fourteen (14) calendar days, in writing if there are any changes to your information supplied to us from time to time, and to respond promptly to any request from us, if:
(a) you fail to provide promptly any user information or Personal Data that we reasonably requested;
(b) you withhold or withdraw any consents that we may need to process, transfer or disclose Personal Data for the purposes of used disclosed above in this Privacy Policy (except for purposes connected with marketing or promoting products and services to you); and/or
(c) we have, or a member of the Company has, suspicions regarding financial crime or an associated risk,
we may:
(i) be unable to provide new, or continue to provide all or part of the services to you and reserve the right to terminate our relationship with you;
(ii) take actions necessary for us or a member of the Company to meet the compliance or regulatory obligations; and/or
(iii) suspend, transfer or close your account(s) where permitted under local laws.
11.1 Under the Data Privacy Act of 2012, you have the following rights as a data subject:
(a) Right to be Informed: You have the right to be informed whether your personal data is being, or has been, processed, including the existence of automated decision-making and profiling, before entry into any contract or agreement, or before your data is collected.
(b) Right to Access: You have the right to reasonable access to your personal data in the possession of the Company, including the sources from which personal data were obtained, the purposes for which they are processed, and the names and addresses of recipients.
(c) Right to Object: You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing, or profiling. When you object, we shall no longer process your personal data unless there is a legal ground or overriding legitimate interest for the processing.
(d) Right to Erasure or Blocking: You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our filing system upon discovery and substantial proof that the data is incomplete, outdated, false, or unlawfully obtained, or is no longer necessary for the purposes for which it was collected.
(e) Right to Rectify: You have the right to dispute the inaccuracy or error in your personal data and have us correct it immediately and accordingly.
(f) Right to Data Portability: Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of such data in an electronic or structured format that is commonly used and allows for further use.
(g) Right to Damages: You shall be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data, taking into account any violation of your rights and freedoms as a data subject.
(h) Right to File a Complaint: You may file a complaint with the National Privacy Commission (NPC) if your personal information has been misused, maliciously disclosed, or improperly disposed of, or if any of your data privacy rights have been violated. The NPC may be contacted at info@privacy.gov.ph or through its official website at www.privacy.gov.ph.
11.2 The exercise of the aforementioned rights must be carried out in writing by email to our Data Protection Officer at the following contact details:
help@perasure.ph
Attention: Data Protection Officer
11.3 After the application has been submitted, the Company will issue its determination within a reasonable period, and in any event within thirty (30) days from receipt of the request, unless a longer period is required by law or the complexity of the request.
12.1 The Company has appointed a Data Protection Officer ("DPO") who is responsible for overseeing the Company's data protection strategy and its implementation to endeavor to ensure compliance with the Data Privacy Act and applicable NPC issuances.
12.2 The DPO may be contacted at the details provided in paragraph 11.2 above for any queries, concerns, or requests relating to the processing of your personal data.
13.1 The Platform may use cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Cookies are small data files stored on your device when you visit our Platform.
13.2 You may control the use of cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Platform. By continuing to use the Platform, you consent to our use of cookies in accordance with this Privacy Policy.
14.1 This Privacy Policy may be updated from time to time and shall continue to remain in effect unless otherwise amended. If this Privacy Policy is changed, those changes will be posted on the Platform. The change will be effective when posted. Users availing services and/or visitors to the Platform are advised to check the website on a regular basis to remain aware of the policies and practices of how information is collected and used.
14.2 If significant changes to this Privacy Policy will affect certain Personal Data, the Company shall notify its Users through the email address provided or by posting a public notice on the Platform at least fifteen (15) days prior to the effectivity of such changes, where practicable.
14.3 The foregoing consents and authorizations shall continue for the duration of, and shall survive the termination of any loan agreement(s) signed by the borrower, or any other transactions, dealings, arrangements and accounts which borrower may have with, or avail from, the Company and the lender through services and/or the Platform, subject to the data retention and disposal provisions in Section 6 of this Privacy Policy.
This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of the Philippines. Any court action arising out of or in connection with this Agreement shall be filed in the proper courts of Manila City, to the exclusion of all other courts. By agreeing to this Agreement, you irrevocably submit to such venue.
16.1 If you need help from us when there are any information, errors, doubts about the changes in your account without your permission or any of your transactions, you shall notify our customer service center via email at help@perasure.ph or immediately write to the corresponding department with the following information:
(a) Your name and account name;
(b) The time and date of such transactions or changes;
(c) Error description and reference code (if applicable);
(d) Contact name and address, including email address (if any).
16.2 We will immediately investigate any errors or unusual activities reported and will inform you of the results as soon as possible.
16.3 For data privacy-related concerns, please contact us at help@perasure.ph. You may also file a complaint with the National Privacy Commission at info@privacy.gov.ph or through www.privacy.gov.ph.