Statement and Acceptance
This Privacy Policy (the "Policy") details how Peranyo Agad (hereinafter referred to as "we," "us," or "the App") collects, uses, shares, and protects your Personal Information when you utilize the loan services we provide. We urge you to carefully read and review the contents of this Policy before registering or proceeding to use the App.
Your registration for or use of this application signifies that you have fully read, clearly understood, and unequivocally agreed to all provisions within this Privacy Policy. If you do not agree with any part of this Policy, you must refrain from using our services.
Your Express Consent
- Acknowledgement of Terms: You confirm that prior to accessing our services or submitting any information, you have comprehensively reviewed all clauses herein, particularly acknowledging the processing rules for Sensitive Personal Information (such as financial and identity verification data).
- Agreement to Processing: You explicitly consent to our collection, use, storage, and lawful sharing of your Personal Information for the legitimate purposes specified within this Policy. We note that refusing to provide information deemed necessary may render us unable to complete essential services, including account registration or loan application processing.
- Permission Management: You acknowledge and agree that certain functionalities of the service necessitate obtaining specific device permissions. While you may revoke these authorizations at any time via your device settings, understand that disabling necessary permissions may prevent the corresponding feature from operating correctly.
Data Collection Principles and Use
In processing your data, we strictly adhere to the following principles:
- Transparency: We provide clear and unambiguous notice regarding the specific data we collect and the rationale behind that collection.
- Purpose Specification: We collect data exclusively for explicitly declared, specific, and legitimate purposes.
- Data Minimization (Proportionality): We limit data collection to only what is strictly necessary and directly relevant for the delivery of our services.
Collected Information and Its Specific Purposes
We collect the following categories of information to perform our core lending and risk assessment functions:
A. Personal Identification and Contact Details
- Data Collected: Your legal full name, date of birth, gender, marital status, mobile phone number, valid email address, physical residential address, and the name and contact number of your designated emergency contact.
- Purpose of Use: This data is foundational for Know-Your-Customer (KYC) compliance, identity authentication, establishing your user profile, assessing loan applicant eligibility, loan disbursement, issuing repayment reminders, facilitating overdue collection processes, and fraud prevention. The emergency contact information is used only in verified emergencies where direct communication with you has failed.
B. Employment and Financial Data
- Data Collected: Your current occupation, employer's name, work address, monthly income range, the name on your bank account, your bank account number, and any associated e-wallet information.
- Purpose of Use: This information is critical for conducting thorough credit risk assessments, determining suitable loan limits, analyzing your repayment capacity, and is necessary for disbursing approved loan funds to you and processing your scheduled repayments.
C. Device and Network Data
- Data Collected: Device model specifications, operating system details, the unique device identifier, IP address, Wi-Fi and network connection status, and application usage logs.
- Purpose of Use: This data is processed to fortify account security, conduct advanced anti-fraud detection, perform risk management, and ensure service compatibility. We specifically analyze installed application lists to detect and mitigate patterns associated with known fraudulent activities, thereby protecting our platform and users.
D. Required Application Permissions
To ensure the full functionality and security of our services, we require explicit access to the following device permissions:
- Camera: Necessary for capturing images of your official identification documents and performing mandatory facial recognition identity verification.
- Location: Used to enhance the accuracy of our fraud detection systems, verify security checks, and improve overall risk control.
- IDFA (Identifier for Advertisers): Utilized to strengthen the security measures around your account and to potentially offer a personalized service experience.
You retain the ability to modify the authorization status for these permissions at any time within your device's "Settings - Privacy - Permission Management." However, note that disabling permissions deemed essential may directly impede your ability to utilize core functions, such as identity authentication and loan application submission.
Protecting Your Data
Our Security Measures
We have implemented multi-layered physical, technical, and administrative safeguards to protect your data from unauthorized access, loss, misuse, or alteration:
- Encrypted Transmission: We secure all data transmission using robust industry-standard protocols, such as SSL/TLS, to prevent eavesdropping.
- Access Control: Access to your data is strictly controlled and limited only to authorized personnel on a "need-to-know" basis.
- Administrative Safeguards: We maintain rigorous internal data handling standards and conduct regular, mandatory privacy protection training for all employees.
- Periodic Security Audits: We continuously test and audit our systems to identify and mitigate vulnerabilities, proactively defending against potential risks.
Crucial Note: Despite implementing comprehensive protective measures, no electronic system can guarantee 100% absolute security. You are essential to your security; please safeguard your login credentials and password diligently and never disclose sensitive information like one-time verification codes to any third party.
Information Protection Recommendations (Your Responsibility)
To maintain the highest level of information security, we advise you to:
- Maintain the confidentiality of your account credentials and never share them with anyone.
- Refrain from disclosing sensitive data like SMS verification codes or passwords to any third party.
- Exercise caution and be suspicious of any attempt to solicit sensitive personal information via non-official or suspicious channels.
- Ensure that your devices and the App are always running the latest security updates and software versions.
Data Sharing and Disclosure
We are committed to not arbitrarily sharing your Personal Information with third parties. Sharing only occurs under the following legally mandated or authorized circumstances:
- With Your Explicit Consent: For specific purposes you have independently authorized.
- For Service Operations: Shared with our trusted third-party partners (such as credit reporting agencies, cloud service providers, and payment processors) who assist us in operating our services. These partners are strictly bound by confidentiality agreements and are prohibited from using the shared information for any purpose outside the scope of our instruction.
- For Legal Compliance: Disclosure may be necessary when required by Philippine law, regulation, or legal proceedings, or when necessary to protect our rights, property, or safety, or the rights, property, or safety of our users or the public.
We absolutely do not sell or rent your Personal Information to any third party, nor do we permit third-party service providers to use shared information for purposes not outlined in this Policy.
Data Retention and Deletion
Retention Mechanism
We determine retention periods based on the data's nature, its intended purpose, and mandatory Philippine legal requirements:
- Transaction and Compliance Data (KYC, Financial Records): Due to stringent legal obligations (e.g., Anti-Money Laundering, tax laws), this highly regulated data will be retained for a mandatory period of at least 5 years and up to 10 years, even following account closure.
- Active Account and Profile Data: We retain your basic profile and account information as long as your account remains active, facilitating continuous service provision and easy account reactivation.
- Service Optimization and Marketing Data: Non-sensitive data used for internal analysis will be immediately deleted or anonymized once the specific purpose has been fulfilled or upon the withdrawal of your consent.
Deletion Mechanism
When Personal Data reaches the end of its required retention period or is no longer necessary, we employ secure methods for its disposal. Our deletion mechanism involves secure destruction (for physical or paper records) and electronic shredding or permanent anonymization (for digital data) to ensure the information is irreversibly removed and cannot be reconstructed or traced back to your identity.
If your loan obligations are fully settled and no disputes are pending, you may formally request the deletion of your Personal Information. We commit to completing the necessary verification and deletion process within 15 business days and informing you of the outcome.
Your Data Subject Rights
In compliance with relevant Philippine data privacy laws, as a Data Subject, you are entitled to exercise the following rights:
- Access: Request access to and obtain a copy of your Personal Information.
- Rectification: Request the correction of any inaccurate or incomplete data we hold about you.
- Objection: Object to the processing of your data.
- Erasure/Blocking: Request the deletion or blocking of your Personal Data.
- Data Portability: Request that your data be transmitted to another entity, where technically feasible and applicable.
To formally exercise any of these rights, please contact us using the information provided in the "Communication and Contact" section below.
Minor Protection
Our loan services are strictly intended for adults aged 18 and above. We neither offer services to minors nor knowingly collect Personal Information from them. Should we discover any information inadvertently collected from a minor, we will immediately cease processing and delete the related data within 3 business days.
If you are under 18, you must not use this service. If a minor has submitted information without parental or guardian consent, the guardian may contact us to request its immediate deletion.
Policy Update Notice
We reserve the right to update this Policy periodically to reflect changes in our operational practices or legal requirements. We will notify you of any material changes by publishing the updated Policy within the application and revising the "Effective Date" at the top. Your continued use of our services following such notification signifies your acceptance of the revised Policy.
Communication and Contact
For any questions, concerns, or complaints regarding this Privacy Policy or our services, please contact our designated Privacy Officer using the details below:
Company Name: AR HC LENDING INVESTOR, INC.
Email: helpdesk@arhclending.com
Office Address: Santa Cruz, Diplahan, Zamboanga Sibugay Philippines
We commit to responding to all inquiries or complaints within 5 business days of receipt and providing a resolution within 15 business days.