Statement of Policy

The information contained in this website has been prepared in accordance and in compliance with the laws of the Republic of the Philippines, and is for the exclusive use of Business Process Outsourcing International Inc. (hereinafter referred to as the “Company” or “BPOI Inc.”), its assigns, affiliates, and related companies in the conduct of its business in the Philippines (hereinafter referred to as “BPOI Inc.”).

This Statement of Policy sets out the policies of the Company, its assigns, affiliates, and related companies in relation to any and all types of personal information, including sensitive personal information, as defined under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (hereinafter referred to as the “Data Privacy Act”), which may be provided by individuals, whether as prospective lenders, borrowers or investors (the “Client” or “Clients”), for the collection and use of the Company, its assigns, affiliates, and related companies, and from which the identity of the individual may be apparent or can be reasonably and directly ascertained.

The Company values the privacy of its Clients and any visitor to its website. The Company is committed to the protection of any and all personal information which may be provided by its Clients or any website visitor.

Personal Information Collected and Handled

When a Client creates or registers an account in the Company’s website, or uses the Company’s website platform or software, or when the lenders and borrowers enter into a transaction, or when a Client engages the services of the Company, the Company shall collect the following personal information (hereinafter referred to “Personal Information”):

• Full name, permanent and residential address, contact number/s, email address, birth date and/or age, employment information, bank account details, credit card and/or financial account information, financial history and details of government-issued ID;
• other information from which the Client’s identity may not be apparent or which may not reasonably and directly identify the Client, such as, but
• information from third parties, in each case with the consent and authority from the Client; and
• traffic and usage information generated from the Client’s visits and use to the website.

The Personal Information may be collected through the following means: [cookies, flash cookies, general log information, Client browsing behavior, Client searches and transactions and referral information from third-party websites.]

The Personal Information will be accessed by (personal information processors?) mindful of your rights and our obligations under the Data Privacy Act of 2012.

The Personal Information may be disclosed to the following: (a) the Company’s affiliates and subsidiaries, agents (including collection agencies), and subcontractors; (b) the government, regulatory agencies, and fraud prevention agencies for the purposes of identifying, preventing, detecting or tackling fraud, money laundering, or other crimes, and for other lawful purposes; and (c) other entities as may be required by law or as the public interest may warrant, for the purposes identified in the next paragraph.

Use/Purpose

The Personal Information shall be collected, used, disclosed, stored and retained for the following purposes:

• to identify Clients;
• to contact Clients in relation to their registered account/s or requested information;
• to process registration of account/s as part of screening of the investors, borrowers, and loan applications;
• to maintain internal records;
• to carry out marketing and promotions initiatives relating to the Company, local affiliates of BPOI Inc., BPOI Inc.’s partners, and BPOI Inc.’s products and services, whether by electronic means, by email and post, or by telephone, SMS or social media, or by sending newsletters (for example, to be updated on new products or features and to find out about events, contests, demonstrations, loyalty programmes, etc. organized by BPOI Inc.), also by using automated means. Such communications will relate to products and services of the financial products, services and the like. In addition, BPOI Inc. will process your data for market research, statistical analyses, or other research to improve its products, and customer satisfaction analysis; and
• to analyse Client behavior (user profiling), for example, in relation to financing products you availed/provided, viewed/searched products, in order to provide better matches among lenders and borrowers consistent with their respective priorities INSERT OTHER DATA ANALYSIS/ANALYTICS/MINING OBJECTIVES.

Sharing of Personal Information – If applicable and appropriate

Your Personal Information may be shared with BPOI Inc. assigns, affiliates, and related companies in the conduct of its business in the Philippine for processing as may be required in the maintenance and performance of its duties and responsibilities under the site. The BPOI Inc. may, as necessary be engaged by BPOI Inc. as subcontractors or data processors in each case with respect to the purposes enumerated above.

As a lender, your Personal Information will be shared with all borrowers in the site in order to allow the borrowers. This includes your [ENUMERATE CLASS OF INFORMATION]

As a borrower, your Personal Information will be shared with the lenders in the site 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.

The Personal Information of a Client will likewise be shared to third parties (i.e. collection agent, bank, collection agent, etc.) who are engaged, used, or is otherwise authorized by either the lender or the borrower to provide any support or service with respect to any transaction concluded by the lender and borrower.

All data processing, subcontracting or data sharing agreements will be in accordance with the requirements under the Data Privacy Act of 2012. 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 Information.

Retention of your Personal Information

The Personal Information will be retained by us for (state duration, should be at the very least while the loans are outstanding), 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.

Security of your Personal Information

The Company values the Personal Information collected, used, retained and stored through its website platform, and will ensure that it is protected from possible threats, both online and offline. The Company has the necessary technical, organizational and physical measures to ensure that the Personal Information is kept safe and secure, as well as to prevent unauthorized access or disclosure of the collected and stored Personal Information.

Access and Correction of Personal Information

If you wish to exercise your right to access, correction, cancellation, portability and objection rights as described below, or make complaints and other inquiries, please send a registered letter with return receipt to [ADDRESS] or email [EMAIL] to the attention of [DATA PRIVACY OFFICER]:

• to receive details of the source of the data, the purposes and methods of the processing, the logic applied to the processing, or if the latter is carried out with the help of electronic means, of the identity of data controller and data processors, the entities or categories of entity to which the data may be communicated and which may become aware of the data;
• to update, correct, supplement, or delete the data, to block or render anonymous data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which such data have been collected or subsequently processed; to have a certification that the operations requested have been completed, as also related to their contents, to the entities to which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; to receive the personal data concerning you and copy or transmit it to another data controller (right to data portability); and
• to object, on legitimate grounds, to the processing of data, despite the data being relevant to the purposes for which they were collected or to object, also partially (e.g., only in relation to certain communication means), to the data being processed in order to send advertising materials or for direct sales, or market research, or commercial information, profiling purposes, or to receive communications by traditional means only.

Log Data

When a Client or visitor visits the Company’s website, the Client’s or visitor’s browser may send the Company personal information 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 Internet Protocol (IP) address, browser type, browser version, the visited pages of the Website, the time and date of the visit, time spent on the pages, and other statistics.

Cookies

A cookie is a small file which asks permission to be placed on the visitor’s computer hard drive. Once the visitor agrees, the file is added and the cookie helps analyze web traffic or provides internet usage information. A visitor can instruct his or her browser to refuse all cookies or to indicate when a cookie is being sent. However, if the visitor does not accept cookies, the visitor may not be able to use some portions of the website. A cookie in no way gives the Company access to the visitor’s computer or any information about the visitor, other than the data the visitor chooses to share with the Company.

Control over your Personal Information

Clients retain control over their Personal Information, and may amend their personal information registered in the Company’s website database.

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

The Company will not be liable for any loss that the Client may incur as a result of a third party’s use of the Client’s account or password, either with or without the Client’s knowledge. The Client 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 Client’s account or password.

Changes on our Privacy Policy

This Privacy Policy is in effect as of [•], and shall continue to remain in effect unless otherwise amended.

The Company reserves the right to amend this Privacy Policy from time to time, upon due notification to its Clients or visitors.

If significant changes to this Privacy Policy will affect certain Personal Information, the Company shall notify its Clients through the email address provided or by posting a public notice on the Website.

Contact Us

For any questions, concerns or clarifications about the Company’s Privacy Policy, the Company may be contacted through:

• support@coindrop.com.ph
• Business Hours: 8:am to 5:00pm PST
• Location: Makati city, Philippines