Privacy Policy
SunLoan Lending Investors Corporation., a corporation organized and existing in the Philippines (“Peso Plus”, “we”, “us” or “our”) takes your privacy very seriously.
This privacy policy (this “Privacy Policy”) describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You should read and understand this Privacy Policy in its entirety.
This Privacy Policy applies in connection with your use of the Peso Plus Android mobile application (the “Peso Plus-Fast and Safe Cash”) and your use of our services through the Peso Plus App or otherwise. Please check the privacy policy applicable to your use of our website.
1. What personal data does Peso Plus collect and process? From where does Peso Plus collect your personal information?
Peso Plus collects the following personal data (as defined under applicable law), including personally identifiable information:
Identification data (e.g., first name, surname, date and place of birth);
Information provided by you through your responses (e.g., information about your income or employment, your educational attainment, Bank information, customer-provided information about your mobile device);
Contact details (e.g., address, phone number, emergency contacts, email address);
Government-issued identification data and documents (e.g., UMID, Voter’s ID, Passport, National ID);
Mobile device specifications (e.g., SIM, IMEI, IP address, or other device identifiers, type of device, device operating system, device settings;
Location data (e.g., mobile approximate location, time zone setting);
Transaction data and financial information (e.g., loans, transfers, payments, loan requests);
Device behavioural data (e.g., SMS records, types and nature of mobile applications found on your mobile device);
Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies,).
Peso Plus collects your personal data from:
You, when you download the Peso Plus App and/or indicate that you want to apply for credit;
Your other interactions with us, including Information you may voluntarily share with our customer support team or other Peso Plus employees or agents;
Your mobile device (through the device permissions is more fully described below);
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 (such as telecommunications companies and credit scoring service providers) that may assist us in providing services to you).
Collection and processing of your personal data by Peso Plus is necessary for the provision of Peso Plus’s products and services and to comply with applicable legal and regulatory requirements to which you and/or Peso Plus is subject. Apart from such cases, we do not collect Information without your specific prior consent.
NOTE: We will store all your information on Singapore server: .
2. What are the purposes for which your personal data is processed? How does Peso Plus use your personal information?
To assess your eligibility to use our products or services (including, but not limited to, credit scoring and 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 account with Peso Plus (including, but not limited to, processing disbursement of your funds and collecting repayment of your outstanding balance);
To verify your identity and/or other information you 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 our 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 Peso Plus’s services;
To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” (KYC), customer verification, transaction monitoring, and/or anti-money laundering;
To send you marketing or advertising notices or other promotional offers, to the extent you have not objected to the use of your personal data 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 and to resolve disputes and complaints;
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.
We process your personal data for the purposes set out above on the following grounds:
To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you);
To carry out our legal obligations under applicable law;
In connection with our legitimate interest in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date;
With your prior consent.
3. Who do we share your personal data with?
General
Peso Plus will 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 Peso Plus’s products or services (provided, that, we may share limited personal data (as defined under applicable law) with select partners for research and development). Whenever practically feasible, Peso Plus will only share your personal data with third parties in an anonymized or de-identified format.
You understand and agree that we may, as necessary and/or appropriate for the purposes provided above, transfer and disclose your personal data to:
a subsidiary, affiliate or parent company of Peso Plus (collectively, the “Peso Plus Group”) located outside the Philippines;
employees, subcontractors, agents, service providers, or associates of the Peso Plus Group (including directors and officers);
bank partners (e.g., Asia Union Bank of the Philippines);
intermediary, correspondent and agent banks, non-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, remittance and transfer companies, credit reference agencies or credit bureaus;
service providers with contractual or fiduciary relationships with Peso Plus (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer), which may be located outside the Philippines;
telecommunication companies (e.g., Globe, TM, GOMO, Smart, Talk&Text, PLDT, Sun Cellular);
external collection agencies (to assist in the collection of any unpaid obligations to us);
external counsel, external auditors, and consultants, when necessary to resolve disputes or complaints;
a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Peso Plus and/or any company within the Peso Plus Group;
a party in connection with any assignment of credit or the creation of a security interest involving outstanding balances owned to Peso Plus;
to other public or private third parties to the extent (1) we have a duty to disclose or share your personal data in order to comply with any legal obligation (e.g., the Credit Information Corporation, the Bureau of Internal Revenue), (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 Peso Plus, the Peso Plus Group and/or our customers.
The above parties may also process or disclose your personal data for the purposes set forth above, so long as such processing or disclosure is in compliance with this Privacy Policy.
Further, Peso Plus may also share your personal data with law enforcement or other government agencies in connection with 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.
4. For how long will we retain your personal data?
Your personal data will be stored or retained by Peso Plus and its transferees only for so long as necessary for the purposes listed in this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We are required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion. We may also retain your personal data (i) for as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Information that is no longer needed for the purpose(s) for which it was collected shall be deleted or anonymized except as necessary to comply with legal obligations.
5. Where do we process, store or transfer your personal data?
We may transfer your personal data outside of the Philippines to 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 personal data. Your personal data may be processed by any of the parties described above. Peso Plus will use all reasonable and appropriate efforts as required by applicable law to protect your personal data.
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.
Credit decisions
When you apply for credit, we’ll use automated processing to decide whether to lend to you and/or make other decisions about your eligibility for our products and services, based on the personal data collected. 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 data science and machine-learning technology to process your personal data and assess your creditworthiness. The associated processing of your personal data 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 our services or ineligible for credit of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Detecting fraud
Peso Plus 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
If you apply for a credit and your request is declined (or you are informed that you are ineligible for other or associated products or services) as a result of an automated credit, underwriting or fraud decision, you may request that one of our underwriters review this decision. You may do so by contacting us at: service@pesoplusapp.com. You may also object to the automated processing of your personal data, but doing so will prevent us from providing you with our services.
7.Your rights as a data subject
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 ground for using or processing your personal data or because we need to retain your personal data to comply with a legal obligation.
Right to be informed
We must provide you with certain information related to how we collect your personal data, how we use your personal data (and our legal basis for doing so), who we share your personal data with, where we obtained your personal data and your rights as a data subject. This information is provided within the Peso Plus App and in this Privacy Policy in clear language.
Right to access
You may ask for a copy of the personal data (as defined under applicable law) we hold concerning you (and your Information related to such personal data), as well as information on how such personal data has been processed, 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. The right to access does not apply to analyses made by the Company with respect to your personal data, such as inferred, derived, modeled, or business-generated data.
Right to rectification
You may ask us to correct any personal data which you believe to be inaccurate. We will promptly update any such personal data. 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 request.
Right to erasure or blocking
You may ask us to erase your personal data (as defined under applicable law):
If you believe it’s 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 or object to processing
Where the processing of your personal data is based on your consent or our legitimate interest, 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 personal data 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. The right to data portability is limited to data that you provided actively and knowingly, or that you provided by virtue of the use of our services.
Right to file a complaint
You have the right to file a complaint with the relevant 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’re 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. Consequences of not providing us with your personal data
You are not required to provide us with your Information or any associated personal data (as defined under applicable law) and you may withdraw your consent from the use or processing of such Information or personal data. However, if you do so, we will be unable to provide our current or future products and services to you and we reserve the right to terminate our relationship with you, as permitted under applicable law. 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 an outstanding balance with Peso Plus, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts. We are also required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion.
9. Consent and Authorization
By downloading the Peso Plus App and clicking “Accept” on the permissions overview screen, you:
accept the terms of this Privacy Policy;
allow Peso Plus to access the device permissions more fully described below;
give Peso Plus consent to collect, use, share, or otherwise process your personal data, which may include personally identifiable information, personal information, sensitive personal information or privileged information (in each case, as defined under applicable law), as outlined in this Privacy Policy;
certify that all personal data you have provided and will provide to Peso Plus is true and correct to the best of your knowledge;
authorize Peso Plus to verify/investigate the accuracy of your personal data; and
acknowledge that Peso Plus may be required to disclose your personal data to the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, Bureau of Internal Revenue, Credit Information Corporation, credit bureaus and/or any other governmental body, in compliance with its legal obligations and in accordance with the principle of proportionality.
10. What device permissions does the Peso Plus app access?
Depending on your Android Operating System and the version of the Peso Plus app installed on your device, the following device permissions may be accessed by the Peso Plus App. Keep your Peso Plus App updated to make sure you can experience the latest and most secure features.
1.Peso Plus will be collecting the following personal data:
a. Visitors:
b. IP address or other device identifiers;
c. Usage of SunLoan’s website or Applications;
2. Users:
a. General personal information including Name, Gender, Birthdate, ID type/number, ID pictures&liveness, Email address, Phone Number, Emergency contacts, Bank information and Address etc. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
b. Geolocation ;
We collect your geo-location information when the platform is running in the foreground so as to auto-fill your address data. We endeavor to cease collection of your geo-location information when the platform is in the background You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
c. SMS data;
We will obtain your SMS data for risk management and anti-fraud checks. SunLoan will never share your data with third parties without your permission. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
d. App installed;
Your installed APPs help us identify your credit level and recommend suitable credit products. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
e. Camera access;
We will obtain your camera access to scan your ID card and perform facial recognition. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
f. Calendar;
The authorization to access your calendar help us remind you of the due date of the loan repayment, in this regard, we will add and modify the calendar events, but we will not access or modify other event(s) that you‘ve set in the calendar of your device. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
g. Phone information
We will collect and monitor specific information about your device, including hardware model, operating system and version, unique device identifier, user profile information, wi-fi information, mobile network information, user account information, to uniquely identify devices and ensure that unauthorized devices cannot act on your behalf, which helps us prevent fraud. This information will be encrypted and transmitted to our server https://pesoplusapp.com.
Personal data voluntarily entered by the User when using Peso Plus services. Peso Plus only collects personal data which are reasonably needed in connection with the purposes stated in this Privacy Policy.
11. General
If you have questions about this Privacy Policy or about your rights as a Data Subject, you can contact our Data Protection Officer at: .
To improve and continue our services to you and to comply with data privacy regulations that may be issued from time to time, this Privacy Policy may be updated. We will notify you prior to any updates to this Privacy Policy, either within the Peso Plus App, by SMS or by email.