Privacy Policy

APP Name: Suki PaluwaganPal

1. Introduction

Suki PaluwaganPal ("the App") is a personal finance management tool designed for Filipino Paluwagan (rotating savings) participants and organizers. This Privacy Policy explains how we collect, use, store, and protect your information when you use Suki PaluwaganPal.

Operated by: Suki PaluwaganPal Effective Date: September 8, 2026

By downloading, installing, or using Suki PaluwaganPal, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

2. Information We Collect

Suki PaluwaganPal collects and stores the following types of information locally on your device only:

Information You Provide:

• Paluwagan group data: Group names, member names, nicknames, optional phone numbers (for local identification only), payment amounts, payment dates, notes

• Utang (advance/repayment) records: Records of advances and repayments between group members, including amounts, dates, notes, and linked round references — stored locally to track who covered whom and outstanding balances

• Payment and utang receipt photos: Images captured through your device camera or selected from your photo library, used as proof of payment or utang transactions

• Location data: Approximate GPS coordinates when you choose to tag a group collection meeting point (only when you explicitly use this feature)

• Financial calculations: Simulation parameters, true value calculations (equivalent interest rates per position), and results from the Paluwagan Calculator and True Value Calculator

• Reputation archive data: Completed paluwagan history, personal on-time rates, organizer management scores, and generated reputation card images — all derived from your existing group data and stored locally

• Backup files: JSON export files containing your App data, saved to your device's Files app

Information Collected Automatically:

• IDFA (Identifier for Advertisers): Collected only with your explicit consent through Apple's App Tracking Transparency (ATT) prompt, used for advertising attribution and analytics

Information We Do NOT Collect:

• Real names or legal identities (member names are user-defined labels)

• Government-issued IDs, passport numbers, or social security numbers

• Bank account numbers, credit card information, or payment credentials

• Biometric data

• Browsing history or usage of other apps

3. How We Use Your Information

• Group and member data — To create and manage Paluwagan rotation cycles, track payment status, calculate member credit scores, and generate settlement reports

• Utang records — To track advances and repayments between group members, calculate net balances, perform automatic offset clearing, and include utang summaries in settlement reports

• Payment and utang receipt photos — To attach proof of payment or utang transactions to individual records for dispute resolution

• Location data — To tag the physical meeting point where group members collect payments, for your personal reference only

• Financial calculations — To simulate Paluwagan parameters, calculate true economic value of each rotation position (equivalent interest rates), and help you make informed decisions

• Reputation archive data — To build your paluwagan track record from completed cycles, calculate organizer management scores, and generate shareable reputation cards for use with new groups

• Backup files — To allow you to back up and restore your data locally

• IDFA — For advertising attribution and analytics (only with your explicit consent)

4. Permissions Required and Permission Descriptions

Suki PaluwaganPal requests the following device permissions. Each permission is requested only when you first use the related feature, not at App launch.

Camera

• Purpose: To take photos of payment receipts and utang proof (GCash screenshots, cash handoff photos, bank transfer confirmations)

• When requested: First time you tap the camera button when recording a payment or utang (FR-05)

Location

• Purpose: To tag the GPS coordinates of your group's collection meeting point

• When requested: First time you tap the location tag button when creating a paluwagan group (FR-01)

IDFA / App Tracking Transparency

• Purpose: For advertising attribution and analytics

• When requested: After App launch at an appropriate moment (system ATT prompt)

If you deny a permission:

• Camera denied: You can still record payments, but without attaching receipt photos.

• Location denied: You can still use all features, but cannot tag meeting point locations.

• IDFA denied: No impact on App functionality. The App works identically with or without tracking consent.

5. Information Storage and Security

Local Storage Only: All your data is stored exclusively on your device using SQLite database and the iOS file system. No data is uploaded to any server, cloud service, or third-party platform.

Security Measures:

• Data is protected by iOS Data Protection API encryption

• App data is isolated within the iOS sandbox

• Backup files are saved to your device's Files app directory, protected by your device passcode/biometrics

• Receipt photos are stored within the App's sandboxed storage, not in your public photo library

• No network connections are made (except for IDFA attribution if consented)

Data Retention:

• Your data remains on your device for as long as you use the App

• Deleting the App permanently removes all stored data

• You can manually delete all data at any time through the Settings page

6. Information Sharing and Disclosure

Suki PaluwaganPal does not share your personal information with any third party.

• We do not sell, rent, or trade your data

• We do not transmit data to any server or cloud service

• We do not share data with advertisers, analytics providers, or data brokers

• The only data that leaves your device is when you choose to export (CSV/JSON backup) or share (settlement report image) using your device's built-in sharing functionality

Exceptions:

• If required by Philippine law, court order, or government regulation (Data Privacy Act of 2012, Republic Act No. 10173), we may be required to disclose information. However, since we do not have access to your data (it is stored only on your device), we cannot provide what we do not possess.

7. Your Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173) and Apple's App Store guidelines, you have the following rights:

• Right to Access: View all your data within the App at any time

• Right to Export: Export all your data as CSV or JSON files through the Settings page

• Right to Delete: Delete individual records, entire groups, or all data through the App. You can also delete all data by using "Delete Everything" in Settings, or by uninstalling the App

• Right to Rectify: Edit or correct any data you have entered at any time

• Right to Object: Deny any permission request without losing access to core features

• Right to Data Portability: Export your data in standard formats (CSV, JSON) for personal use

Since all data is stored locally on your device, exercising these rights requires no request to us — you have full control at all times.

8. Cookies and Tracking Technologies

Suki PaluwaganPal does not use cookies, web beacons, pixels, or any web-based tracking technologies.

IDFA (Identifier for Advertisers):

• Collected only with your explicit consent through Apple's ATT framework

• Used solely for advertising attribution and basic analytics

• You can revoke consent at any time through iOS Settings > Privacy & Security > Tracking

• Denying IDFA tracking has zero impact on App functionality

9. Children's Protection

Suki PaluwaganPal is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. The App is designed for adults who participate in or organize Paluwagan savings groups.

If you believe a child under 13 has provided personal data through the App, the data exists only on that device and can be deleted by the device owner at any time.

10. Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect changes in the App's features or applicable laws.

• Notification: Material changes will be communicated through an in-App notice upon the first launch after the update

• Effective Date: The updated policy takes effect on the date stated at the top of the document

• Continued Use: By continuing to use the App after changes take effect, you accept the updated Privacy Policy

• Access: The current version of this Privacy Policy is always accessible within the App's Settings page

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data, please contact us:

• Email: craigb@garnershronda.lol

• Response Time: We aim to respond within 7 business days

For complaints regarding data privacy, you may also contact the National Privacy Commission (NPC) of the Philippines:

• Website: https://www.privacy.gov.ph

• Email: complaints@privacy.gov.ph