Privacy Policy

This Privacy Policy (the “Policy”) applies when you access or use "PondoCash". Empire Peak Lending Investors Inc. (“PondoCash” or “we”), a corporation duly organized and existing in the Philippines as the administrator, is committed to protecting the information that collected from you. Before continuing, please read the Privacy Policy carefully. This Privacy Policy describes how PondoCash collects, stores, uses and protects information that you provide, directly in connection with your use of PondoCash or indirectly through third-parties, to obtain online services available through PondoCash. PondoCash shall only keep your information for as long as PondoCash is authorized by law or as is relevant for the purposes for which it was collected.

PondoCash shall therefor use your information you have disclosed to us, only in the manner and for the purposes set out in this Privacy Policy. PondoCash will only access and collect your personal information if you voluntarily submit the information to us or explicitly provide your consent for our access to the same. PondoCash shall only collect your personal information where it is necessary for us to do so and when such is relevant to our transactions with you. You may ask us to delete your personal data from our system.

We may amend this Privacy Policy from time to time by posting a revised, dated version on the Site, without any prior written notice to you. By accessing or using our products/services, you accept the practices described in this Privacy Policy.


1.What Personal Information We Collect

When you use PondoCash, in order to process and handle your use, PondoCash shall, in accordance with the law, only collect information that is strictly necessary and shall not use it for other purposes. The specific information collected is as follows:

Information to recognize your identity (eg. Name, ID number), background, addresses, contact and mobile numbers, email addresses, IP addresses, operating systems, browser types, contact details, Installed Application list, telecommunication usage data, credit worthiness information and other information and data generated by third party or that you provide in relation to using, accessing, or availing of PondoCash and/or services (“Personal Data”).

PondoCash may collect and obtain this Personal Data from yourself or from a variety of sources, including but not limited to:

1) your submission of your Personal Data;

2) your Installed Application Information to prevent fraudulent customers, and evaluate your credit score;

3) from mobile network operators/telecommunication companies;;

4) from any analysis of the way you use and manage your account/facility with PondoCash;

5) from publicly available sources or registries;

6) from government authorities, regulatory authorities and/or law enforcement agencies;

7) from third parties or other sources;

8) from any information that is supplied and/or collected when you use/visit our products which include your mobile device or from any information that is collected via cookies on some of our products. Provided that, the same shall only be collected once you have given your consent to disclose the Personal Data and/or where not otherwise restricted.

Provided that, the same shall only be collected once you have given your consent to disclose the Personal Data and/or where not otherwise restricted.

PondoCash reserves the right to request additional documentation to verify the information provided by you. Your submission of any information to us, our authorized agents or the Platforms expressly contains your warranty that such information is accurate and not misleading.


2.How We Use Your Personal Information

One of our primary purposes of collecting Personal Information is to establish a safe, smooth, efficient and customized experience that allows our users to take full advantage of the products and services available through PondoCash. During the course of your availment of our service, PondoCash may utilize, process and/or disclose your Personal Data to PondoCash’s affiliates, subsidiaries and partner companies for any of the following purposes (“Permitted Purpose”) :

1) to authenticate your identity;

2) to assess and process your applications for PondoCash’s products and/or services;

3) to handle complaints and queries, to communicate with you, including but not limited to sending you updates and reminders, responding to your inquiries and/or complaints and resolving disputes;

4) to manage and maintain your accounts/facilities with PondoCash;

5) to conduct credit checks to assess or verify your credit/financial worthiness and to assist other financial institutions to conduct credit checks;

6) to evaluate your financial needs;

7) to maintain your credit history for present and future references;

8) to detect and investigate crime, fraud or illegal activities, and to utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions, including know your customer (KYC);

9) to respond to the requirements of a civil or criminal legal process and/or for regulatory compliance purposes and/or as required by law or regulation;

10) to fulfil your instructions and to collect any debt due or owing and to enforce your obligations to PondoCash;

11) to compile, use, research, analyze, and generate data analytics reports to better understand our customers with the aim of improving our products and services and product development;

12) to provide you with the information on our third-party products and services which may be of interest to you;

13) to compare information/data for accuracy of our record, and to verify the same with third parties;

14) to utilize the same to customize and enhance user experience and improvement of our products and services, operational and business processes;

15) to support our business, financial and risk monitoring, planning and decision-making and to utilize and disclose the same for audit and compliance, no matter from outsourcing of business and internal operations;

16) to transfer or assign our rights and duties under any governing terms and conditions between PondoCash and yourself;

17) to transfer your Personal Data to local and/or foreign jurisdictions for the purpose of processing and storage and to enable any transactions, for the performance of a contract, products and/or services, for the purposes of legal proceedings;

18) for any other purposes that is required or permitted by any law, regulation, order and/or guidelines.

PondoCash may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help PondoCash better understand user behavior, tell PondoCash which parts of our products/services have visited or used, and facilitate and measure the effectiveness of advertisements and searches. If you want to disable/adjust cookies, you may adjust the settings on your browser and/or mobile device so that you will be notified when you receive cookie or other similar tracking tools. Please refer to your browser/device documentation to check if the tracking tools have been enabled on your device or to disable cookies. Please note that certain features of our products/service will not be available once cookies are disabled.


3.How We Disclose Your Personal Information

PondoCash takes your privacy seriously and shall only share personal information as described in this Privacy Policy. Your Personal Information, held by PondoCash, shall be always kept confidential. However, in order to provide you with effective and continuous products and services subject to any laws, regulations and guidelines and for the Permitted Purpose, you explicitly consent to us providing, disclosing, or otherwise processing your Personal Information, in connection with our products and services, to the following parties, in and/or outside the Philippines:

1) PondoCash’s agents, holding companies, subsidiaries, affiliates and associates;

2) professional advisers, contractors, service providers, debt collection agencies and our other agents/entities with whom PondoCash has contractual agreements for some of our functions and services;

3) national and local credit bureau, credit reporting agencies, credit reference agencies, rating agencies, insurers and/or insurance brokers;

4) financial service providers in relation to the products and services that you have with PondoCash;

5) any actual or potential participants or assignee or transferee of our rights and/or obligations under any transaction between PondoCash and you;

6) any guarantor or security provider for the products and/or services granted by PondoCash to you;

7) any authorities or regulators, including regulators for the performance of their functions, or any party as required by any law or any government, administrative and court;

8) strategic/business partners with whom we have a relationship with for specific products and services;

9) any person/entity connected to the enforcement or preservation of any of our rights under your agreements with PondoCash;

10) any party authorized and/or consented by.


4.Changes in Your Personal Information

You must keep the Personal Information provided to PondoCash up to date, and inform PondoCash of changes thereto. You are entitled to review the Personal Information that PondoCash have collected about you and request for corrections of the same. You have the right to update your Personal Inforamtion anytime. If there are any changes to your Personal Information or if you believe that the Personal Information PondoCash held about you is inaccurate, incomplete, misleading or not up-to-date, kindly write to PondoCash or email your request to PondoCash. PondoCash shall correct or update the information/data as soon as possible.

For the avoidance of doubt, PondoCash reserves the right to request information or documents from you to verify your identity and the authenticity of the request made and any other information relating to the corrections requested.


5.Minors

Minors shall not use our products/service for any purpose. PondoCash does not knowingly collect Personal Information from Minors for any purpose. If you believe that PondoCash has Personal Information of a Minor without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact PondoCash and we will delete such information.


6.Protection of Personal Information

PondoCash shall follow legal provisions and regulations strictly, and shall take strict and secure protective measures to safeguard your rights in accordance with this Privacy Policy. PondoCash maintains a comprehensive security program based on industry standards and best practices. PondoCash take a defensive, in-depth approach to implementing rigorous physical, administrative, and technical safeguards to ensure your information is safe from unauthorized access or misuse. The safeguards include preventive, detective, and corrective controls. PondoCash reviews and adjusts security safeguards periodically based on ongoing risk assessment. However, despite our substantial investment in protecting your personal information, ultimately no institution can guarantee its absolute security.


7.Withdrawal of Consent

You may communicate your objection to our continued use, collection, and/or other acts of processing of your Personal Information for any valid purpose and in the manner as stated at any time by contacting us at our e-mail address. This shall be your mechanism to turn off or allow the permissions that were previously granted to PondoCash.


8.Removal of Personal Data

We shall retain your Personal Data, registration and transaction records for the longest time period among the following three circumstances: (1) a period for up to ten (10) years, or (2) a period of time necessary to fulfill the purposes outlined, or (3) in adherence with the requirements of other laws and regulations; for the establishment, exercise or defense of legal claims; or for legitimate business purposes, which must be consistent with standards followed by the applicable industry.

Your Personal Data will be destroyed in irretrievable and unusable form in adherence with our physical and/or technical information security measures when retention is no longer allowed or required. The same will be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice the interests of the data subjects.

You may request for deletion of your Personal Data at all time, by submitting request to our customer service, on the premise that you are not liable to us/you don’t have active funding from PondoCash. Deletion of your Personal Data does not affect the lawfulness of processing and your obligation that was carried out before the deletion. Users hereby understand that the impact of deleting User's Personal Data from PondoCash's system will result in closure of your PondoCash's account.


9.Portability

If you wish for us to transfer the Personal Information to another party, PondoCash can only do so where it is technically feasible. PondoCash are not responsible for the security of the Personal Information or the processing of the same once received by a third party. PondoCash reserve the rights to refuse the transfer if such transfer would interfere with another person’s rights. Our legal rights and remedies are expressly reserved for such events.


10.Your Rights

PondoCash thinks carefully about how PondoCash uses your information. PondoCash always aim to use it in a way that’s fair to you. According to the applicable laws and regulations (e.g. The Data Privacy Act (DPA)) , you have a legal right to:

1) You have the right to indicate your refusal or withdrawal of consent to the collection and processing of your personal data;

2) You have the right to reasonable access to your personal information;

3) You may also correct or remove any information that you think is inaccurate. You have the right to dispute any inaccuracy or error in your personal data.

4) You have the right to the destruction of your personal data;

Please note that the enumerated rights and wording there of is not an exact copy of those indicated in the Data Privacy Act. Please check The Data Privacy Act for the exact list and rights you may have as a data subject. All the rights mentioned in such law are inherently incorporated into this Privacy Policy and may be freely exercised by the data subject.


11.Inquiries and Complaints

You have the right to object at any time to the processing of your Personal Information to the extent permitted under the Philippine law, and to the processing of your personal data for the Permitted Purpose. Any queries, requests, concerns, complaints or exercise of your rights regarding the use of your Personal Information may be raised to PondoCash. PondoCash commits to acknowledge your complaint in a prompt manner and will give you an estimated timeframe for when the company will respond to your complaint.

In case of any questions, inquiries, comments and requests regarding the Privacy Policy, we encourage you to get in contact with our Data Protection Officer via the email address: cs@pondocash.net.


12.Updates to the Privacy Policy

PondoCash may update this Privacy Policy from time to time. Please check this Privacy Policy frequently to see if there are any updates or changes to this Privacy Policy. If the Privacy Policy is updated, the said updated version shall apply to all of your information held and processed by PondoCash henceforth. If you do not consent to the updated terms thereby, you may contact PondoCash.


13.Consent and Acknowledgement

By providing us with your Personal Data, you hereby consent to the usage, processing and/or disclosure of your Personal Data in accordance with this Privacy Notice to PondoCash, its affiliates, subsidiaries, and partner institutions.

IF YOU DO NOT AGREE TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN THE WAY THIS PRIVACY POLICY DESCRIBES, PLEASE DO NOT PROVIDE YOUR INFORMATION WHEN REQUESTED AND IMMEDIATELY STOP USING OUR PRODUCTS/SERVICES. BY CONTINUING TO USE AND ACCESS OUR PRODUCTS/SERVICES, YOU ARE ACKNOWLEDGING OUR RULES REGARDING YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.