Privacy Policy

Cashflow Lending Corporation (the “Company”), along with its assigns, affiliates, and related companies operating in the Philippines, values the privacy of Pocket PH Users and anyone who uses, accesses, downloads, browses, or registers with the Pocket PH service through its website, application (the “Pocket PH Application”), or related digital platforms, including social media (collectively, the “Pocket PH Facility”). This Privacy Policy reflects Pocket PH Lending Corporation’s commitment to respecting and protecting the personal data of Pocket PH Facility Users. We are dedicated to safeguarding any personal information provided by Users or visitors.

This Privacy Policy has been prepared in accordance with the laws of the Republic of the Philippines and is exclusively for Cashflow Lending Corporation The Company is committed to complying with Republic Act 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations. This Policy outlines how the Company and its affiliates handle all types of personal information, including sensitive personal information as defined under Republic Act No. 10173 (collectively referred to as “Personal Data”). This information may be provided by individual users of the Pocket PH Facility, including prospective lenders or borrowers (“you”, the “User” or “Users”), and can be used by the Company, its assigns, affiliates, and related companies to identify individuals.

All names and other information related to users will be handled as set out in this Privacy Policy. We only collect information when necessary and only if it is relevant to our dealings with users. We will retain user information only for as long as required by law or as is relevant for the purposes for which the information was collected. When visiting the Pocket PH Facility, you may choose to remain anonymous, and at no time can we identify users of the Pocket PH Facility unless you have a Pocket PH account and log in with a username and password.

The scope of this Privacy Policy is limited to information collected or received through your use of the Pocket PH Facility, including the Pocket PH website or application. We are not responsible for the actions of third parties or companies, the contents of their facilities, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our partnership with, sponsorship or endorsement of, or affiliation with, those parties or companies and their brands. By using the Pocket PH Facility service, whether via the Pocket PH website or application, you agree to this Privacy Policy and the processing of your personal information, including your personal data, as provided in this Privacy Policy. If you do not agree to these terms, please do not use and exit the Pocket PH Facility.

Purposes and Legal Basis for Collecting Personal Information

1.Location Data
We collect your geo-location data when the Platform is active in the foreground to automatically fill in your address information. We aim to stop collecting your geo-location data when the Platform is running in the background. You can always choose to temporarily disable location tracking on your mobile device.

2.Contacts Information
As part of our loan process, we require information about a guarantor or co-signer, which users select from their contact list. While completing the form on our Platform, we collect your contacts data to auto-fill necessary details during the loan application. This contacts information will not be used for other services or shared with third parties, except for the guarantor or co-signer's contact details, which may be used by us or authorized third parties if the loan becomes overdue. The contact data is encrypted and uploaded to our servers via the application, and we may filter and delete personal contact data from our servers six months later. We will never share this data with third parties. If you wish to delete your contact data immediately, please notify our customer service center.

3.Camera Access
We require access to your camera to provide a seamless experience and to allow you to take photos of your KYC documents and other necessary documents, which can then be uploaded to the Platform during your loan application process.

4.Storage Access
We require storage permissions to enable the Platform to upload photos and documents necessary to complete the application form during your loan application journey.

5.Phone Information
Phone information includes your device's brand, model, operating system version, unique device identifier, network environment, WiFi status, device status, IMEI (International Mobile Equipment Identity), IMSI (International Mobile Subscriber Identity), application software details, mobile number, and device memory. Access to this information helps us create a user profile and preferences, allowing us to recommend suitable credit products.

Methods of Collecting Personal Data

1.Personal Data provided by the User during registration, the loan application process, or when using any product or service within the Pocket PH Facility. For data submitted for pre-approval or the availment of financial products, the information will be collected by both the Company and the relevant platform lender, such as Cashflow Lending Corporation

2.When the User interacts with Pocket PH Facility’s customer service representatives through various channels, including phone calls, letters, face-to-face meetings, online chat, social media, messaging apps, emails, and any other communication methods available now or in the future.

3.When the User requests to be contacted or to be added to an email or other mailing list.

4.When the User responds to the Company’s or Pocket PH Facility’s promotions, initiatives, or any requests for additional Personal Data.

5.When the User is contacted by, and responds to, the Company’s or Pocket PH Facility’s marketing representatives or customer service officers.

6.When the Company or its affiliates seek information from third parties about the User in connection with products and services offered in the Pocket PH Facility.

7.Personal Data collected from publicly available sources, including but not limited to social media, public repositories, websites, and similar platforms.

8.As per the Authorization and Consent to Collection below, Personal Data obtained on the User’s behalf from third parties with whom the User has transacted, is currently using, or has obtained a service or product from.

9.Information gathered through cookies, web beacons, web crawlers, flash cookies, general log information, mobile and browser data (all in accordance with the User’s permission settings in the application and on such devices), User browsing behavior, search activities, transactions, and referral information.

Submission of True and Accurate Information – You must submit to us information including Personal Data which is true and accurate and not misleading and you must keep it up to date and inform of us changes. We reserve the right to request for documentation to verify information provided by you.

Voluntary Submission of Personal Information / Personal Data- We will only be able to collect your Personal Data if you voluntarily submit the information to us. If you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with some or all of the services available through the Pocket PH Application or Pocket PH Facility. You may access and update your Personal Data submitted to us at any time.

IOS and Android Platform – When you use the Pocket PH Application on a mobile platform, we may collect and record certain information such as your unique device ID (persistent/non-persistent), the hardware type, media access control (“MAC”), address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address, your profile information (if connected to any social media account including Facebook), and your location based on your Internet Protocol (“IP”) address. This information is useful to us for troubleshooting and helps us to understand usage trends. Whenever you use the Pocket PH Application, we may collect data about all of your interactions with the Pocket PH Application or usage of certain features of the Pocket PH Facility via server log files. This data is stored offshore within our cloud server.

Log Data- When a User or visitor visits the Pocket PH Facility, the User’s or visitor’s browser may send the Company Personal Data which the Company collects for statistical and internal record-keeping purposes. The process of collecting this information is called “Log Data”, and may include information such as the computer’s IP address, browser type, browser version, the visited pages of the Pocket PH website, the time and date of the visit, time spent on the pages or other channels of the Pocket PH Facility including the Pocket PH Application, and other statistics.

Collection and Use of User Data

The User hereby consents to and authorizes the release of any and all information required by Cashflow Lending Corporation, its subsidiaries, affiliates, the lender, and/or its third-party partners. This authorization extends to the User's employer, banks, credit card companies, and the institutions mentioned in the immediately preceding paragraph, including but not limited to, the following: 1. Identity & Credit information;
2. Data usage records;
3. Promo subscription and redemption records;
4. Customer relationship management records;
5. Borrower status;
6. Recovery rate per borrower.
7. Financial assets and liabilities
8. Regular spending and expenditure
9. Outstanding loans and/or liabilities at other financial institutions
10. Retail spending record
11. information on fraud detection, monitoring and prevention

For clarity, the User acknowledges and agrees that Cashflow Lending Corporation or any lender in the Pocket PH Facility may process Personal Data directly or, at their discretion, outsource the processing to third-party subcontractors or service providers, whether within or outside the Philippines. These third parties may include any member of Cashflow Lending Corporation, its subsidiaries, or affiliates, all of which will operate under an outsourcing agreement in compliance with the law.

The Personal Data shall be processed, collected, used, disclosed, stored and retained for the following purposes: 1. to identify Users;
2. to contact Users in relation to their registered account/s or requested information;
3. to process registration of account/s as part of screening of the investors, borrowers, and loan applications;
4. to market and offering new, related or complementary products and services to the User;
5. to conduct background check and identity verification;
6. to conduct and perform fraud monitoring, detection, analysis and prevention;
7. to prevent, detect and investigate actual or suspected crime and analyzing and managing commercial risks;
8. to analyse User behavior or for user profiling, (e.g. in relation to financing products availed, provided, viewed, and searched) in order to improve, and develop better products and services in the Facility including to provide better matches among lenders and borrowers consistent with their respective priorities;
9. to develop, enhance and maintain a risk assessment process and model, offline and online;
10. to develop and generate a credit score, credit model and user model;
11. to respond to your queries and requests;
12. to facilitate and as may be required as part of any financing or capital raising activity (i.e. obtaining loans, credit facility, mortgage, assignment, assignment as a form of security or mortgage of loans);
13. to initiate and maintain correspondence with the User via electronic mail (e-mail), SMS (short messaging service), registered mail, phone calls or field visits;
14. for any other legal and/or regulatory purposes (including but not limited to obtaining legal advice and dispute resolution) and legitimate business purposes and to carry out all mandatory administrative, operational and legal duties applicable to Cashflow Lending Corporation, its subsidiaries and affiliates pursuant to the prevailing laws and regulations.

Sharing of Personal Data

Your Personal Data may be shared with Cashflow Lending Corporation and its affiliates for processing as needed to fulfill their duties under the Pocket PH Facility, in compliance with applicable laws, rules, and regulations. Cashflow Lending Corporation may also engage its subsidiaries or affiliates as subcontractors or data processors for the purposes mentioned above.

Personal Data in connection with a lender may be shared with borrowers availing the Pocket PH services. As a borrower, your Personal Data will be shared with the lenders in order to allow the lenders to assess your credit history and such other information the lender will require to confirm your credit history and credit score and to determine or assist in determination of decisions as part of screening of borrowers, registrations, pre-approval of the lender’s financial products and services or loan applications. Your information may also be shared with third-party purchasers of any loans including Non-Performing Loans. In the event that your loan or other financial product is assigned, ceded, taken over, purchased or is otherwise transferred to any other party, all your records, transactions, any other information (including personal and sensitive personal information) about you, as it relates to the issuance, history, basis, and status of such loan or financial instrument, shall be shared, transferred and delivered to such third party.

You as a User hereby acknowledges and agree that Cashflow Lending Corporation may share any and all information relating to you as a User to third parties for purposes provided under this Privacy Policy, for any legitimate business purpose including, but not limited to, credit investigation, credit scoring, credit collection, fraud detection, fraud prevention, fraud monitoring, product and systems development, sales and marketing activities, communications relating to the development of their products and/or services, and the like.

All data processing, subcontracting or data sharing agreements will be in accordance with the requirements under the Data Privacy Act of 2012, or applicable laws and regulations as may be hereafter passed and implemented. To the extent that such processing, subcontracting, or data sharing requires notice or consent, we will provide or request for such notice and/or consent, in each case, prior to any processing or sharing of your Personal Data.

Please note that should you agree to sharing of information with other third parties for their own marketing purposes, handling of your Personal Data shall be subject to their separate privacy policies and should you wish to opt-out of marketing or promotional emails from these third parties, you should contact these parties directly.

We may release your information including Personal Data as permitted by law or when we believe that release is appropriate to comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

On occasion, we may share to or obtain user-level data collected about you from third parties (including affiliates), for purposes beyond the specific examples noted in this Privacy Policy. User-level data is information that is associated with your specific device and is not aggregated with other data. For example, we may share to or obtain data from third-party data that reveals that you have viewed certain sites or used certain apps or features, but you will not be personally identified with such information. Rather, the user-level data will be associated with an anonymous identifier.

Storage of Personal Data

The data including Personal Data that we collect from you may be transferred to, and stored at, a destination outside the Philippines. It may also be processed by staff operating outside the Philippines who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests. By submitting your Personal Data, you agree to this transfer, storing or processing of data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We may also disclose your data to anyone we consider necessary in order to provide you with services in connection with an account.

Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of the Pocket PH Facility, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted through the Pocket PH Facility, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Retention of your Personal Data

Your Personal Data will be retained by the Company for the duration of your activities and transactions in connection with the products and services availed of in this Pocket PH Facility and/or for such period of time required for legal and regulatory and/or other legitimate business purposes, and will be disposed of in a secure manner that would prevent further processing, unauthorized access or disclosure to any other party or the public or prejudice your interest, provided that the Company may retain copies of your Personal Data in the Company’s archives for the purpose of determining its continuing obligations or pursuant to its bona fide record retention or data back-up policies, access to which shall be restricted on a need-to-know basis, as may be required under applicable laws and regulations.

The Personal Data may likewise be retained for the purpose of fraud prevention, detection, and monitoring in accordance with the Company’s fraud detection and prevention policies, and any requirement imposed by any credit agency, bureau or agency in order to prevent fraud, identify theft, anti-money laundering, terrorist financing and other similar causes which are consistent with public policy and the public good.

Security of your Personal Data

The Company values Personal Data collected, used, retained and stored through the Pocket PH Facility. The Company has adopted technical, organizational and physical measures to protect your Personal Data,

We take reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration by third parties.

Although we make good faith efforts to store the information collected on the Pocket PH Facility and/or the Pocket PH Application in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our system. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers" from illegal obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties.

Access and Correction of Personal Data

If you wish to exercise your rights to access, correction, cancellation, portability, and objection as described below, or for complaints and other inquiries.

To receive details of the data's source, the purposes and methods of processing, the logic applied to the processing (especially if electronic means are used), and the identity of the data controller and data processors, as well as the entities or categories of entities to whom the data may be communicated and who may have access to it;

To update, correct, supplement, or delete the data; to block or anonymize data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which such data were collected or subsequently processed; to obtain a certification that the requested operations have been completed, including related details, to the entities to whom the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right to be protected; to receive your Personal Data, and copy or transmit it to another data controller (right to data portability); and

To object, on legitimate grounds, to the processing of data, even if the data are relevant to the purposes for which they were collected; or to object, even partially (e.g., only in relation to certain communication methods), to the data being processed for sending advertising materials, direct sales, market research, commercial information, profiling purposes, or to receive communications by traditional means only.

Please note that if your Personal Data has been provided to us by a third party (e.g., a referrer), you should contact that organization or individual to make such queries, complaints, access, and correction requests.

Control over your Personal Data

Users retain control over their Personal Data, and may amend their Personal Data registered over the Pocket PH Facility database.

The User shall be responsible for maintaining the confidentiality of his or her own Pocket PH Account and password, as well as any and all applications submitted, obligations agreed to or entered into and all other activities occuring under the said account. The User agrees to immediately notify the Company of any unauthorized use or disclosure of the User’s account or password, any unauthorized activities under the User’s Pocket PH Account or any other breach of security.

The Company will not be liable for any loss that the User may incur as a result of a third-party’s use of the User’s Pocket PH Account or password, either with or without the User’s knowledge, without fault or negligence on the part of the Company.

The User may be held liable for any damage or loss incurred by the Company in connection with or arising from a third-party’s use of the User’s Pocket PH Account or password, without fault or negligence on the part of the Company.

Users have the following rights regarding Personal Data:

1. Right to Request Special Privacy Protections. You have the right to request restrictions on certain uses and disclosures of your Personal Data by a written request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information, we will abide by your request, unless we must disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request, and will notify you of our decision.

2. Right to Inspect and Copy. You have the right to inspect and copy your Personal Data, with limited exceptions. To access your Personal Data, you must submit a written request detailing what information you want access to, whether you want to inspect it or get a copy of it, and if you want a copy, your preferred form and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable, or if we can’t agree and we maintain the record in an electronic format, your choice of a readable electronic or hard copy format. We will also send a copy to any other person you designate in writing. We will charge a reasonable fee which covers our costs for labour, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary. We may deny your request under limited circumstances. If we deny your request to access your personal records or the personal records of an individual you are representing because we believe allowing access would be reasonably likely to cause substantial harm to the customer, you will have a right to appeal our decision.

3. Right to Request Confidential Communications. You have the right to request that you receive your Personal Data in a specific way or at a specific location. You may ask that we send information to a particular e-mail account or to your work address. We will comply with all reasonable requests submitted in writing which specify how or where you wish to receive these communications.

4. Right to Amend or Supplement. You have a right to request that we amend your Personal Data that you believe is incorrect or incomplete. You must make a request to amend in writing, and include the reasons you believe the information is inaccurate or incomplete. We may deny your request if we do not have the information, if we did not create the information, if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.

5. Right to Revoke Authorization. Your consent is necessary before the Company can lawfully collect and process your Personal Data. You may revoke (take back) your consent at any time. For the avoidance of doubt, this does not invalidate any previous processing that the Company has performed in accordance with consent originally given.

6. Right to Erasure or Blocking. You have the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data. You can exercise this right upon discovery and substantial proof of any of the following: i. Your Personal Data is incomplete, outdated, false, or unlawfully obtained.
ii. It is being used for purposes you did not authorize.
iii. The data is no longer necessary for the purposes for which they were collected.
iv. You decided to withdraw consent, or you object to the processing and there is no overriding legal ground for processing.
v. The data concerns information prejudicial to the customer — unless justified by freedom of speech, of expression, or of the press; or otherwise authorized by law.
vi. The processing is unlawful.
vii. The Company, or its Personal Data processor/s, violated your rights as a customer.

7. Right to Be Notified of a Breach. You have the right to receive notifications of breaches of your Personal Data, as may be required by law. Aside from protecting you against unfair means of Personal Data collection, this right also requires the Company to notify you in a timely manner if your Personal Data has been compromised. If you have provided us with a current e-mail address, we may use e-mail to communicate information related to the breach.

8. Right to a Paper or Electronic Copy of this Notice. You have a right to be notified of our legal duties and privacy practices with respect to your Personal Data, including a right to a paper copy of this Privacy Notice, even if you have previously requested its receipt by e-mail.

Disclosure Statement for Users and Reference Persons

1. Payment. We use and disclose Personal Data about you to other providers under or in partnership with the Pocket PH service, with an affiliate company or parent company and other vendors to obtain payment for the services we have provided.

2. Payment Reminders. We may use and disclose your Personal Data to contact and remind you about due payments.

3. Research. You agree that your Personal Data may be used and disclosed for research purposes; provided, that access is granted strictly on a need to know basis to protect customer confidentiality involving Personal Data. Separately, your personal records may be used for data analytics to create customer demographics and trends; however, these reports are generated in such a way that customer identities are anonymized.

4. Marketing. We may use your contact details to communicate with you and give you information about products, promotions or services related to your loan applications or other services provided by Pocket PH, with an affiliate company or parent company and other business vendors that may be of interest to you. We may also contact you to ensure customer satisfaction regarding services provided, including identification of your concerns so that addressing of issues are assured.

5. Required by Law. As required by law, we will use and disclose your Personal Data, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirement set forth below concerning those activities. We may disclose your Personal Data to an oversight facility for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure.

6. Law Enforcement. We may, and are sometimes required by law to, disclose your Personal Data to a law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness or missing person, complying with a court order, warrant, subpoena and other law enforcement purposes.

7. Other Uses and Disclosures: If we wish to use or disclose your Personal Data for a purpose that is not discussed in this Privacy Notice, your written consent will be requested separately.

Statement For Reference Persons, Related Party Contacts and Third-Party Contacts:

Additional Information. If you are identified by a Pocket PH User as a Reference Person, Related Party Contact or Third Party Contact, we may contact you to ask for additional information about our User who named you as his/her reference person, to verify the information provided in a User’s application, and/or other information such as the User’s new address and/or new contact number, in the event that we have an important information for the User (for example, if a borrower defaults on his/her payment obligation to us) and we are unable to reach the User or borrower using the contact information that he/she provided to us.

Statement For Users in relation to verification with Related Party Contacts and Third Party Contacts

1. If you provide information of nominated Related Party Contacts and/or Third Party Contact, you understand, accept, and expressly and unconditionally consent to the sharing and disclosure of any information related to the you (including your Personal Data and/or sensitive personal information), to your nominated Related Party Contacts and/or Third Party Contacts, as such Related Party Contact and Third Party Contact may be changed from time to time, for the purpose of:

(a) verifying any or all information about you (whether submitted by you or obtained from other sources) prior to, during and after the application, approval, and termination of the loan agreement;

(b) to inquire about, request for, ascertain or determine the whereabouts, contact information, financial status, and other information related to you (including making such inquiries as part of the loan collection process);

(c) for fraud, theft, or other investigation related to any suspected or actual criminal action or activity, in each case for the purpose of the review, processing, approval, administration, collection, servicing, sale, transfer, amendment, or such other matters in relation to an existing or future loan, which shall be implemented, in accordance with any mandatory applicable law or regulation as the same may be issued from time to time.

2. We may share your Personal Data with our suppliers, including entities within Cashflow Lending Corporation and other business partners who provide services such as IT, marketing, communication, printing, debt collection, fraud prevention, and credit referencing. We ensure that these partners meet our data security standards to keep your Personal Data secure. If you wish to stop sharing your Personal Data with these parties or change your preferences, please inform us in writing. When we share your Personal Data, the recipient may process it on our behalf or for their own purposes. If they process it for their own purposes, they are responsible for complying with applicable laws regarding your Personal Data.

Changes on our Privacy Policy

This Privacy Policy may be updated from time to time and shall continue to remain in effect unless otherwise amended. If this Privacy Policy is changed, those changes will be posted on the Pocket PH Facility and/or the Pocket PH Application. The change will be effective when posted. Users availing Pocket PH services and/or visitors to the Pocket PH Facility are advised to check the Pocket PH website and/or Pocket PH Application on a regular basis to remain aware of the policies and practices of how information is collected and used.

If significant changes to this Privacy Policy will affect certain Personal Data, the Company shall notify its Users through the email address provided or by posting a public notice on the Pocket PH Application and/or Pocket PH Facility.

The foregoing consents and authorizations shall continue for the duration of, and shall survive the termination of any loan agreement(s) signed by the borrower, or any other transactions, dealings, arrangements and accounts which borrower may have with, or avail from, the Company and the lender through Pocket PH service and/or the Pocket PH Facility.

Contact Us
Company Name: Cashflow Lending Corporation
Certificate of Authority No. 2784
Company Registration No.CS201821740
Email: lopezmarzan@cashflowslending.com
Address: No. 123, Market Street, Barangay South Central, Santa Cruz, Zambales, Central Luzon, Luzon, Philippines