Disclosure Statement and Privacy Policy

About us:

Company information:MICRODOT LENDING CORPORATION 

SEC Registration Number:CS201951287

Certificate of Authority to Operate a Financing/Lending (CA) Company Number：No.: 2921

registered office:Unit 3006 One Corporate Center,Julia Vargas Avenue, Barangay San Antonio,Pasig,1600 Metro Manila.

Credit Peso ("Credit Peso", "We", "Us", or "Our", for brevity) hereby adopts this Privacy Policy in compliance with the provisions of Republic Act No. 10173, entitled: An Act Protecting Individual Personal Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission, And For Other Purposes, otherwise known as the "Data Privacy Act of 2012".

For this purpose, this Privacy Policy ensures that the personal data gathered from our clients in the course of transactions, and in accordance with the nature of our business, shall remain secured and protected.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 must read this Privacy Policy in its entirety. 

1. What Personal Information We Collect

When you use Credit Peso, in order to process and handle your use, Credit Peso shall in accordance with the law only collect information that is strictly necessary and shall not use it for other purposes. The specific information collected is as follows:

1)CAMERA &  IMAGE INFORMATION

We will collect photos taken by users during the loan application process and photos actively selected and uploaded by customers for KYC verification and anti-fraud inspection purposes only. We will not access, retrieve and collect any other photos from your device's gallery.We are committed to encrypting the information and ensuring the security of the information,so this information will be encrypted and uploaded to https://mic.microdotlending.top/. And we will never share this data with third parties

2)APP INSTALLED

We are a financial application. We need to collect the App installed in your device so as to protect your fun d safety and to prevent frauds. We need this information for your risk assessment and to recommend suitable products.

The data will beencrypted and uploaded to our https://mic.microdotlending.top/. And we will never share this data with third parties

3)SMS INFORMATION

We need SMS permission to complete the credit risk score. We only collect SMS messages about financial transactions and related activities, which helps us identify the user's various financial transactions, allowing us to determine the user's risk profile and provide the user with appropriate credit analysis.

We are committed to encrypting the information, which will be uploaded to https://mic.microdotlending.top in an encrypted manner. This data will never be shared with third parties

4)PHONE INFORMATION

The device information includes the phone number of the SIM card, device brand, model, operating system version, de vice unique identifier, device network environment, WiFi, device status, identification international mobile device, international mobile subscriber identification, application software information, mobile phone number, device memory information. The authorization to access this information help us to identify your user portrait and preferences and to recommend the suitable credit products. We collect the phone number of the SIM card to facilitate the login process. When we have identified the phone number of the SIM card from the user’s

phone, the user can log in directly. without requiring an OTP code. The information is also used to prevent frauds that act on your behalf.

The phone data will beencrypted and uploaded to our https://mic.microdotlending.top/. And we will never share this data with third parties

5)Location data (e.g., mobile device location, time zone setting);Other information:We may collect some of your other personal information only after obtaining your additional explicit consent. 

The information is also used to prevent frauds that act on your behalf.

The location data will beencrypted and uploaded to our https://mic.microdotlending.top/. And we will never share this data with third parties

2.How We Use Your Personal Information

One of our primary purposes in collecting Personal Information is to establish a safe, smooth, efficient and customized experience that allows our users to take full advantage of the products and services available through Credit Peso. During the course of your availment of our service, Credit Peso may utilize, process and/or disclose your Personal Data to Credit Peso’s affiliates, subsidiaries and partner companies for any of the following purposes (“Permitted Purpose”):

1) to authenticate your identity;

2) to assess and process your applications for Credit Peso’s products and/or services;

3) to handle complaints and queries, to communicate with you including but not limited to sending you updates and reminders, responding to your inquiries and/or complaints and resolving disputes;

4) to manage and maintain your accounts/facilities with Credit Peso;

5) to conduct credit checks/credit evaluation to assess or verify your credit/financial worthiness and to assist other financial institutions to conduct credit checks;

6) to evaluate your financial needs;

7) to utilize the same for marketing and promotions;

8) to maintain your credit history for present and future references;

9) to detect and investigate crime, fraud or illegal activities, and to utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions, including know your customer (KYC);

10) to respond to the requirements of a civil or criminal legal process and/or for regulatory compliance purpose and/or as required by law or regulation;

11) to collect any debt due or owing by you, and to enforce your obligations to Credit Peso;

12) to compile, use, research, analyze, and generate data analytics reports to better understand our customer with the aim of improving our products and services and product development;

13) to provide you with the information on our and third-party products and services which may be of interest to you;

14) to compare information/data for accuracy of our record, and to verify the same with third parties;

15) to utilize the same for customize and enhance user experience and improvement of our products and services, operational and business processes;

16) to support our business, financial and risk monitoring, planning and decision-making and to utilize and disclose the same for audit and compliance, no matter from outsourcing of business and internal operations;

17) to transfer or assign our rights and duties under any governing terms and conditions between Credit Peso and yourself;

18) to transfer your Personal Data to local and/or foreign jurisdictions for the purpose of processing and storage and to enable any transactions, for the performance of a contract, products and/or services, for the purposes of legal proceedings;

19) for any other purposes that is required or permitted by any law, regulation, order and/or guidelines.

Credit Peso may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help Credit Peso better understand user behavior, tell Credit Peso which parts of our products/services have visited or used, and facilitate and measure the effectiveness of advertisements and searches.

3.How does Credit Peso use your Information?

a. 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. 

Lending decisions

When you apply for a loan, 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 Information 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 Information and assess your creditworthiness. The associated processing of your Information 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 a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

Detecting fraud Credit Peso 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 loan and your loan 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 contact us through the contact information shown on the mobile app

b. Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about Credit Peso products, services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with Credit Peso, including by learning more about you and how you use and interact with Credit Peso Internet Sites, Apps, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.

c. Communicate with you. This may include: (i) informing you of Credit Peso products, services, and promotional activities that may be of interest to you; (ii) providing information about relevant Credit Peso products, services, and transactions, including, for example, pricing, information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.

d. Provide and improve our Internet Sites, Mobile Application, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new Credit Peso Internet Sites, Mobile Application, products and services.

e. Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Credit Peso Internet Sites, Apps, products or services; and (v) protecting Credit Peso’s rights or property, or yours or others’ health, safety, welfare, rights, or property.    

4. Who do we share your Information with?

Credit Peso shall 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 Credit Peso's products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Credit Peso will only share your information with third parties on an anonymous basis.

You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to:

a subsidiary, affiliate or parent company of Credit Peso (collectively, the "Credit Peso Group");

employees, subcontractors, agents, service providers, or associates of the MICRODOT LENDING CORPORATION (including directors and officers);

intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, credit reference agencies or credit bureaus;

service providers with contractual or fiduciary relationships with Credit Peso (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer);

external collection agencies (to assist in the collection of any unpaid obligations to us);

tax authorities;

a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Credit Peso and/or any company within the Credit Peso Group;

to other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (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 Credit Peso, the Credit Peso Group and/or our customers.

The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy. 

Further, Credit Peso may also share your information with law enforcement or other government agencies pursuant to 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.

5.For how long will we retain your Information?

Your Personal Data will be stored or retained by Credit Peso and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We may also retain your Information (i) 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.

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 Microdot Lending Corporation Corp 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.

6. Where do we process, store or transfer your information?

Your Personal Data including your transaction data is stored in the secure third-party cloud service provided by our cloud service providers, including Amazon and Alicloud, who are among the best-of-breed cloud providers in the industry.

We may transfer your Information outside of the Philippines, either to the United States, or 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 Information. Your Information may be processed by any of the parties described in Section 4. Credit Peso will use all reasonable and appropriate efforts as required by applicable law to protect your Information.

We may use third-party Service Providers to monitor, analyze, support and improve the use of our Service. In order to facilitate the process for you to obtain our services, we use the following SDKs in our application:

Firebase Cloud Messaging

Firebase Cloud Messaging SDK, provided by Google LLC, has been registered in the Google Play SDK Console. We use this SDK in our application to collect Firebase installation ID, FCM registration token, application information, device information, notification delivery status and notification interaction information in order to send push notifications, service messages, repayment reminders, overdue reminders, account security alerts, coupons, promotional offers and other information related to Credit Peso products and services. This SDK uses HTTPS to encrypt data in transit to ensure the security of your personal data.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Facebook Android SDK

Facebook Android SDK, provided by Facebook, has been registered in the Google Play SDK Console. We use this SDK in our application to collect advertising identifier and application activities, including webpage visits, clicks within the application and other actions, solely to understand your actions in our app and measure the performance of our mobile application ads.

Adjust SDK

Adjust SDK, provided by Adjust GmbH, has been registered in the Google Play SDK Console. We use this SDK in our application to collect advertising identifier, Android ID, device type, device model, system type, application activities, including webpage visits, clicks within the application and other actions, solely to record activations, app opens, sessions and in-app events. In-app events mean user behaviors such as in-app registration or applying for a loan. We will use these events to measure ROI and user quality. This SDK adopts encrypted transmission on data transmitted through it to ensure the security of your personal data.

Liveness Detection SDK

We use Liveness Detection SDK in our application to collect device type, device model, system type, app name, app version number and sensors, including gravity sensor, magnetic field sensor, accelerometer and gyroscope sensor information, solely to efficiently identify identity fraud and improve the accuracy of detection of retakes and deep fake frauds with close-up and long-range images.

7. 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.

Lending decisions

When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. 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 machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information 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 a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

Detecting fraud Credit Peso 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

In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through :creditpesocustomerservice@gmail.com.

8. Your rights as a data subject

You may contact us to exercise your rights at creditpesocustomerservice@gmail.com.

Rights to notice and consent

We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Credit Peso App and in this Privacy Policy.

Right to access

You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), 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.

Right to rectification

You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. 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 thereof.

Right to erasure ("right to be forgotten")

You may ask us to delete your personal data (as defined under applicable law) from our system:

If you believe it is 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 processing

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 information 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. 

Right to object

You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data).

Right to file a complaint

You have the right to file a complaint with the appropriate 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 are 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).    

9. Advertising and Marketing

You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through creditpesocustomerservice@gmail.com and we will remove you from such communication lists.   

10. Deletion of Personal Information

If you want to stop using our service and delete your personal information, it can be done in the following two ways:

a. You can ask us to delete your personal information.

Please send us a request email to delete personal information at creditpesocustomerservice@gmail.com, we will complete your request within five days.

b. You can wait for us to automatically delete your personal information.

When you stop using our services for more than 12 months, we will automatically delete your personal information.

If you still have outstanding bills, you will not be allowed to delete your personal information.

Only when all your bills have been settled can you successfully delete your personal information through the above two ways.  

11. Consent and Authorization

By downloading the Credit Peso App, you: 

accept the terms of this Privacy Policy;

give Credit Peso consent to collect, use, share, or otherwise process your Information, which may include 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 Information you have provided and will provide to Credit Peso is true and correct to the best of your knowledge;

authorize Credit Peso to verify/investigate the accuracy of your Information; and

acknowledge that Credit Peso may be required to disclose your Information to the Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, credit bureaus and/or any other governmental body, in compliance with its legal obligations.

12. General

If you need to contact us, please do so at: creditpesocustomerservice@gmail.com

To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Credit Peso App or by email.