PesoIn

Pesoin Privacy Policy And Disclosure Statement

Company information:

LINK CREDIT LENDING INVESTORS INC.

PSEC Registration Number: NO.CS201914644

Registered Business Name: Pesoin

Certificate of Authority to Operate a Financing/Lending (CA) Company Number: NO.3072

Please read our privacy policy carefully to get a clear understanding of how we collect, use, disclose, store, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

General

PesoIn (the "PesoIn," "Company," "We," "Us," or "Our"), is committed to protect the privacy and security of all personal and/or sensitive information (the "Personal Data") related to its employees, customers, business partners, suppliers, contractors, and other parties that the Company will and is engaged into. For this reason, uniform practice and procedure for collecting, recording, consolidating, updating, disclosing, storing, accessing, transferring, retaining, destructing and disposing of Personal Data by the Company are hereby adopted order to process Personal Data fairly, appropriately, and lawfully.

This Privacy Policy sets out the use, protection, and control of the company over the personal data it proces. The Company may change this policy from time to time by updating it in accordance with the Data Privacy Act of 2012, its Implementing Rules and Regulations, NPC Advisories and issuances and other relevant laws. The terms of this Privacy Policy apply to all person whose personal data is processed by PesoIn.

1.COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

When you use our Platform, whether our Website or our App, we collect and store your information (personal information) which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience and services. This allows us to provide services and features that meets your needs, and to customize our Platform to make your experience safer and easier and to improve the services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.

In general, you can browse the Website or App without telling us who you are or revealing any personal information about yourself. However, to create an account on the Website or App, you must provide us with certain basic information required to provide customized services. The information we collect from you, inter alia, including:

• Name

• Email Address

• Mailing Address

• Phone Number

• Birthday

• Place of Birth

• Photo

• Payslip

• Certificate of Employment

• Other information: We may collect some of your other Personal Information only after obtaining your additional explicit consent. For example,your SMS information stored on your Device may be collected to analyze your ability to repay; and your location information (IP address, longitude and latitude information) may be collected for anti-fraud purposes.

Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the Platform.

We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the Platform) requires registration and for you to provide the above details. The Platform shall clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.

2.COLLECTION OF SMS

We need to collect your SMS content, which will help us identify the various accounts you hold and the cash flow pattern of you as a user, help us conduct credit risk assessment, enable us to determine your risk status, and provide you with appropriate credit analysis to provide more suitable loan products.

SMS data will be encrypted and uploaded to our servers via the HTTPS protocol: https://appapi.pesoin.com/. We will filter and delete personal SMS data on the server, and only analyze financial related SMS to identify risks.

At the same time, we will delete the SMS data after the risk assessment and never share these data with third parties.

3.COLLECTION OF MOBILE NUMBER AND EMAIL ADDRESS

When you sign up with us, we collect your mobile number and email address to uniquely identify you. This helps us ensure that no unauthorised device or person is acting on your behalf.

4.COLLECTION OF LOCATION

We collect location information from your device to reduce the risk associated with your account.

5.COLLECTION OF INSTALLED APPLICATIONS

We collect a list of the installed applications' metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.

6.CAMERA

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.

7.Contact Information Collection

Collection Content: We are committed to ensuring the security of your account, therefore, we require you to provide relevant information about emergency contacts, including their names, phone numbers, and their relationship with you.
Collection Purpose: In cases where your account faces security risks or involves violations, we may not be able to contact you directly. To effectively address these situations, we will use the emergency contact information you provide to ensure timely communication with you or your emergency contacts, in order to obtain or convey necessary information, thereby safeguarding the security and compliance of the account.
Information Transmission and Protection: Given the sensitivity of contact information, we employ strict security measures to protect this information. All contact data will be encrypted and then uploaded to our member server via HTTPS protocol at https://appapi.pesoin.com , ensuring complete protection during transmission and mitigating potential threats.
Contact Information Deletion: Once you have completed all orders and decided to close your account, upon confirmation of all transactions being completed, we will proceed immediately. This includes deleting all personal information associated with your account, including emergency contact information. We are committed to protecting your privacy and ensuring the complete deletion of your personal information when it is no longer needed, in order to safeguard your rights and privacy.

8.Image Information Collection

Image Collection: Front side of identity proof documents and personal photos taken by the user.
Collection Purpose: We utilize advanced artificial intelligence technology to verify user identity, to prevent identity misuse and fraudulent activities, ensuring the security and reliability of the platform.
Image Transmission and Storage: To ensure user privacy and information security, all images will be encrypted and then uploaded to our secure server via HTTPS protocol at https://appapi.pesoin.com . We firmly commit not to share this data with any third parties, ensuring the confidentiality and integrity of user information.
Image Data Deletion: Users can delete uploaded images and other related user information by closing their account as long as there are no pending orders, ensuring that users have complete control over their personal data. We respect users' rights and privacy and strive to provide secure and reliable services.

9.COLLECTION OF OTHER NON-PERSONAL INFORMATION

We automatically track certain information about you based upon your behavior on our Platform. We use this information to do internal research on our users' demographics, interests, and behavior to better understand, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.

Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Website more user friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

If you choose to make a purchase through the Website, we collect information about your buying behavior.

We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

10.COLLECTION OF DEVICE INFORMATION

The information the App collects, and how that information is used, depends on how you manage your privacy controls on your device.

When you install the App, we store the information we collect with unique identifiers tied to the device you're using.

We collect information from the device when you download and install the App and explicitly seek permissions from YOU to get the required information from the device.

The information we collect from your device includes the unique ID i.e. IMEI number, information on operating system, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, list of installed apps, wi-fi information.

We collect information about your device to provide automatic updates and additional security so that your account is not used in other people's devices. 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.

11.USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION

We access, store and use the information we collect from you to provide our Services, to research and develop new ones.

We use personal information to provide the services you request, to customize your user experience and to improve our services. To the extent we intent to use your personal information to market any product to you, we will provide you the ability to opt-out of such uses.

We use your personal information to:

• resolve disputes;

• troubleshoot problems;

• help promote a safe service;

• analytical analysis;

• measure consumer interest and satisfaction in our products and services;

• inform you about online and offline offers, products, services, and updates;

• customize your experience;

• detect and protect us against suspicious or illegal activity, fraud and other criminal activity;

• enforce our terms and conditions;

• improvement of our services and as otherwise described to you at the time of collection.

In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Website.

12.USE OF YOUR DEVICE INFORMATION

We use the information provided by You in the following ways:

• to establish identity and verify the same;

• monitor, improve and administer our Website / Platform;

• provide our service i.e. perform credit profiling for the purpose of facilitating loans to You;

• design and offer customized products and services offered by our third-party financial partners;

• analyse how the Website is used, diagnose service or technical problems and maintain security;

• send communications notifications, information regarding the products or services requested by you or process queries and applications that you have made on the Website;

• manage our relationship with you and inform you about other products or services we think you might find of some use;

• conduct data analysis in order to improve the Services / Products provided to the User;

• use the User information in order to comply with country laws and regulations;

• to conduct KYC for our third-party lending partners based on the information shared by the User;

• use the User information in other ways permitted by law to enable You to take financial services from our lending partners.

We will use and retain Your information for such periods as necessary to provide You the Services on our Website, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

13.LINK TO THIRD-PARTY SDK

Our application has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third party service provider provides hosting security - they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

14.CHANGES IN THIS PRIVACY POLICY

PesoIn reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Website. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

15.ACCESSING YOUR INFORMATION / CONTACTING US

At any point of time Users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.

16.YOUR PRIVACY CONTROLS

You have certain choices regarding the information we collect and how it is used:

1. Device-level settings:Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.

2. Delete your entire App account.

3. You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.

17.SECURITY PRECAUTIONS

The Website/App intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

1. We use encryption to keep your data private while in transit;

2. We offer security feature like an OTP verification to help you protect your account;

3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;

4. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

5. Compliance & Cooperation with Regulations and applicable laws;

6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

18.LINKS TO OTHER SITES

Our Website links to other websites that may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we're only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.

19.YOUR CONSENT

By using the Website/App and/ or by providing your information, you consent to the collection and use of the information you disclose on the Website in accordance with this Privacy Policy, including but not limited to Your consent for collecting, using, sharing and disclosing your information as per this privacy policy.

If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

20.CANCEL ACCOUNT AND DELETE DATA

We provide you with the right to cancel your account after paying off loan orders . You can submit an account cancellation by clicking the "Mine-Settings-Cancel Account" on the APP.

We would like to inform you that once you submit the cancellation, we will delete all relevant personal information under your account. After you log out, we will no longer be able to provide you with loan products or services that require you to log in with your account. We provide you with a cancellation application service within 7 days. If you have any questions, you can contact us at any time.

For any queries, clarifications or requests on any aspect of this Statement, the exercise of your rights pertaining to your personal information or to provide any feedback that you may have about our processing of personal data, you may contact our Data Protection Officer at help@pesoin.com or you may fill out our Contact Us form and choose the subject "Data Privacy Request".