U-PESO.PH LENDING CORPORATION
SEC Registration No.:CS201814908
Certificate of Authority No.: 2718

Hereby to certify that we will explain what information we will collect from you (users of the Service), with which relevant third parties we will share your information for better product experience, and in what ways you can prohibit us from sharing certain information about you with relevant third parties. The treatment of your personal information, including your login to the website or server information and all other personal information is also specified here in detail.
All the relative data/info reported/stored at https://upeso.ph/new/

1.Relative information collected

Borrower information, such as SSS, job information
Sensitive information, such as mobile ID, IP Base Station, Device infomation and other.
Other information, such as the user's approximate location information, etc.

2.Terms and Conditions:

Personally identifiable information

• By registering an account with us, you are accepting the terms of the Terms and Conditions and consenting to our collection, usage, disclosure, retention, and protection of your personal information as described herein;

• Personal data including your name, age, photos, fingerprints, and other biometric data. (e.g., facial recognition and voice recognition), mobile number/s, mobile phone usage data, employment details, income, financial data, financial profile, credit standing, loan payment history, and other information that may be required to process your loan application.

• Other information that you provide to us but that does not identify you personally, such as records of your visits and information that you submit when using the website;

• Other information that the record you click our app and operation,such as the record you change your ID NO or ID Type.

Upeso may collect your information from:

• You, when download the Upeso App and/or indicate that you want to apply for a loan;

• Your other interactions with us, including Information you may voluntarily share with our customer support team or other Upeso employees or agents;

• Your mobile device (e.g., mobile device data, transaction data, Upeso App usage and/or phone data as more fully described above);

• Credit reference agencies (who may check your Information against other databases – public and private – to which they have access) or fraud prevention agencies; and/or

• Third parties and other publicly available sources, with your consent, when necessary (e.g., we may receive Information from financial rails (or other disbursement channel vendors) or other business partners that may assist us in providing services to you).

• Collection and processing of your Information by Upeso is necessary for the provision of Upeso’s products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Upeso is subject. Aside from such cases, we do not collect Information without your specific prior consent.

• Obtain call records to ensure that real users use the application in a normal environment, rather than logging in using an emulator, we need to obtain your call history. Include phone number, name, and call time. Call record information will be uploaded to https://api.upeso.ph.com/ And it will not be shared with third parties. We will not disclose or share your information.

3.We collected the information for the following purposes, but not limited to:

a. To process your transaction;
b. To verify your actual identity;
c. To determine if you’re eligible for a loan;
d. To disburse loan and collect repayment for your service;
e. To have credibility built in your account;
f. To comply with applicable rules, regulations, and laws;
g. To detect and prevent fraud;
h. To rate your loan application history and confirm your job data;
i. To develop more apps feature that needs to meet clients needs;
j. To know our latest services provide, new notifications, and offers etc;
k. To assess your risk profile and to recommend suitable products.

Phone Number
We will upload you and your contact phone number to https://saas.upeso.ph/.com to verify the authenticity of your identity. Quickly writing the correct contact phone number and information through the address book can reduce your input operations. Identity verification is done through the contact to ensure the security of loan funds and the phone number will be removed once your risk profile is determined.

Application List
Upeso collects your application list, including package name, package version, app installed time to build and complete our risk management model. Without the model, we would not be able to provide financial service to you. Your data will be transmitted and stored to our server: ( https://upeso.ph/new/ ) over a secure encryption technology. We will not share your data to third parties for any reasons, such as for the purposes of analysis and sale.

4.How does Upeso use your information?

• To assess your eligibility to use our products or services (including, but not limited to, by assessing your creditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product);

• To service your loan with Upeso (including, but not limited to, by processing your transactions and processing disbursement of your loan and collecting repayment of your loan);

• To verify your identity and/or other information you have provided to us;
  To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;

• To analyze customer behavior;

• To administer out systems, maintain service quality and compile general usage statistics;

• To analyze and improve our services;

• To troubleshoot any problems you or other customers encounter with Upeso’s services;

• To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and/or anti-money laundering;

• To the extent you have not objected to the use of your information for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers;

• To provide service updates;

• To provide staff training (where we may monitor or record customer interactions);

• To interface with credit reference or fraud prevention agencies;

• To provide customer service or support;

• To contact you by telephone using autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

5.Who do we share your information with?

General
Upeso shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Upeso’s products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Upeso will only share your Information with third parties in an anonymized format.

You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to:

• A subsidiary, affiliate or parent company of Upeso (collectively, the “Upeso Group”);

• Employees, subcontractors, agents, service providers, or associates of the Upeso Group (including directors and officers);

• Intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, credit reference agencies or credit bureaus;

• Service providers with contractual or fiduciary relationships with Upeso (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer);
  external collection agencies (to assist in the collection of any unpaid obligations to us);

• Tax authorities;

• A party in connection with any merger, acquisition or sale of all or substantially all of the assets of Upeso and/or any company within the Upeso Group;

• To other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Upeso, the Upeso Group and/or our customers.

The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy.

Further, Upeso may also share your information with law enforcement or other government agencies pursuant to a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you.

Referrals
To promote its products and services, Upeso administers and services a referral program (“Upeso Referral Program”, for brevity) for its current and future customers. If you choose to accept a referral from another Upeso customer and accept a Upeso loan in connection with that referral, Upeso will provide a bonus to the customer who refers you upon your successful repayment of your Upeso loan.

If you choose to participate in the Upeso Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the imbedded referral link and subsequently applying for and accepting a Upeso loan through such referral.

Sharing of your Information in connection with the Upeso Referral Program shall be limited to the information described above and shall remain anonymized – Upeso will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Upeso. More information on the Upeso Referral Program is available within the Upeso App.

4.For how long will we retain your information?

Your Information will be stored or retained by Upeso and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services.
We may also retain your Information:
(i) As long as necessary to comply with any legal obligation;
(ii) Whenever such is authorized under the law;
(iii) For the establishment of legal defenses.

5.Where do we process, store or transfer your information?

We may transfer your Information outside of the Philippines, either to the United States, or Singapore, and/or to the extent we provide prior notice to you, to jurisdictions that may have data protection laws that are less stringent than those of the Philippines. When we do so, we will ensure that adequate safeguards are in place in accordance with applicable law and/or the Philippines’data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your Information. Your Information may be processed by any of the parties described in Section 4. Upeso will use all reasonable and appropriate efforts as required by applicable law to protect your Information.

6.Automated decisions and profiling

We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.

· Lending decisions
When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.

Our credit and underwriting models utilize machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

· Detecting fraud
Upeso also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.

·Your rights in relation to automated decision-making
In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through cs@upeso.ph.

7.Your rights as a data subject

You may contact us to exercise your rights at cs@upeso.ph.

· Rights to notice and consent

We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Upeso App and in this Privacy Policy.

• Right to access

  You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request.

• Right to rectification

  You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the thereof.

• Right to erasure (“right to be forgotten”)

  You may ask us to delete your personal data (as defined under applicable law) from our system:

• If you believe it is no longer necessary for us to retain such personal data;

• If you do not believe we have legitimate ground for processing it;

• If you think we are using such personal data unlawfully; and/or

• If you think applicable law requires that we do so.

• Right to restrict processing

You may ask us to stop using your personal data (as defined under applicable law):

• If you think such personal data is inaccurate;

• If you think it’s illegal for us to use such personal data;

• If you don’t want us to destroy such personal data because you need it for legal proceedings;

• If you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.

• Right to data portability

• If we’re using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller.

• Right to object

  You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data).

• Right to file a complaint

  You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject, including the National Privacy Commission of the Philippines.

Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation).

8.Advertising and Marketing

You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through cs@upeso.ph and we will remove you from such communication lists.

9.Consequences of not providing us with your Information

You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Upeso, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.

10.Consent and Authorization

By downloading the Upeso App, you:

• Accept the terms of this Privacy Policy;

• Agree that Upeso collects, uses, shares or otherwise processes your information, which may include personal information, sensitive personal information or privileged information (as defined under applicable law in each case), as outlined in this Privacy Policy;

• Certify that all Information you have provided and will provide to Upeso is true and correct to the best of your knowledge;

• Authorize Upeso to verify/investigate the accuracy of your Information; and

• Acknowledge that Upeso may be required to disclose your Information to the Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, credit bureaus and/or any other governmental body, in compliance with its legal obligations.

11.General

If you need to contact us, please do so at: cs@upeso.ph

To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Upeso App or by email.

12.Effectivity Date

The provisions of this policy shall have full force and effect beginning 27 March 2020.