Privacy Policy
Last Updated: December 1, 2021

This Plentina Privacy Policy applies to Plentina Inc. and its subsidiaries and affiliates (collectively “Plentina”, “we”, “our” or “us”). It represents our commitment to treat information with utmost care, transparency and confidentiality in compliance with relevant and applicable data privacy laws and regulations, and with constantly changing commercially acceptable standards for data protection (collectively, the “law”). This Privacy Policy only covers the information that Plentina collects, uses, processes and shares. It does not explain what third parties do with any information they may collect about you separately from Plentina. This policy also does not cover any websites, platforms, products, or services provided by others. We encourage you to review the privacy policies or notices of those third parties for information about their practices and we hope you will take some time to read this Privacy Policy.

When you use our mobile application, as the case may be (the "App"), apply for a loan, and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this Privacy Policy (“Policy”), we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of our Services immediately.

With this policy, we present transparently that we gather, process, store and use the data of persons fairly and in accordance with law. As part of our drive to serve you better, we need to obtain and process your information. Plentina collects or processes this information only with the full knowledge, cooperation and consent of interested parties.

Your data will be kept up-to-date, collected or processed fairly and for lawful purposes only. The information you give us will be processed within legal boundaries and will be protected against any unauthorized or illegal access by internal or external parties. You are free to exercise your rights under the law as a data subject and we fully respect the same.

Your data will not be distributed to any party other than the ones consented and agreed by you or the data’s owner (exempting those compellable to be disclosed by law and legitimate requests from courts of competent jurisdiction and law enforcement authorities). Without such express consent from you or the data owner, it will not be communicated or transferred, informally or in any manner, to any other person, entity, organization or country.

We also allow people to modify, erase, reduce or correct data contained in our databases in line with their rights under the law. We will have provisions in cases of lost or corrupted data.

For protection, our officers and employees will be trained in online privacy and data security and will establish data protection practices (secure locks, data encryption, access authorization, etc.). In addition, security measures will be built through a secure network to protect data from cyber attacks.

We may change this Policy from time to time without any advance notice. Should there be material changes to the Policy, you shall be promptly notified via e-mail and/or in-app. You are strongly recommended to regularly review and read the Privacy Policy. Any changes in this Policy will be effective immediately upon posting in the website and in the Plentina app, with an updated effective date. In case of any inconsistency with any other policy of Plentina regarding data, information and system security measures, this Privacy Policy will govern.

This Policy applies to all information collected through our Services (which, as described above, includes our App), as well as any related services, sales, marketing or events.

Please read this Policy carefully as it will help you understand what we do with the information that we collect. Thank you for using Plentina!

TABLE OF CONTENTS

1. WHY DO WE COLLECT YOUR INFORMATION?

2. WHAT INFORMATION DO WE COLLECT?

3. HOW DO WE USE YOUR INFORMATION?

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. DO WE COLLECT INFORMATION FROM MINORS?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE AND EXERCISE YOUR DATA PRIVACY RIGHTS?

12. YOUR ACKNOWLEDGMENT AND CONSENT

1. WHY DO WE COLLECT YOUR INFORMATION?

In Short: We collect your information to enable us to provide our Services to you.

We are a Company duly organized and existing under the laws of the Republic of the Philippines (Company Registration No. CS20200001117) and are licensed by the Securities and Exchange Commission to operate as a Lending Company (Certificate of Authority No. 3266).

Pursuant to this, you may register in our App and, subject to our Terms and Conditions and User Agreement, be eligible to apply and receive loan/s under our Services. To do this, we will need to collect your personal information to the extent needed for you to access and for us to provide to you our Services.

2. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and Services, when you participate in activities on the App or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following: full name; citizenship; date of birth; place of birth; present and permanent address; phone numbers; email addresses; contact preferences; self-reported income; employer, employment status; mobile plan status; government I.D., photo (selfie), and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our App.

We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

The information we collect includes:

· Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

· Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

· Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's contacts, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

· Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed.

· Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

To the extent permitted by law, in order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.

When collecting information from third-party sources, Plentina ensures that the third-party provider has secured the users’ on your consent to the sharing of their data for marketing purposes. This will be made as a representation & warranty of the third-party provider under the relevant Data Sharing/Outsourcing Agreement between the third parties and Plentina.

3. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

· To facilitate account creation and log-on process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

· To perform our Know-Your-Customer and Verification procedures. In order to provide to you our Services, we will need to collect your personal information and verify your identity as our customer.

· To perform loan origination, fulfillment, and collection. Once you have submitted your personal information and have been verified by our system, you will be eligible to apply for a loan via our App. In this regard, we will use your personal information in the process of originating your loan application/s and, if approved, fulfilling and performing collection/s for your loan repayment/s, as well as performing any other related data processing activities incidental to these activities.

· To comply with our legal obligations. As a Lending Company, we can perform the release, submission or exchange of customer information with regulators of competent jurisdiction, other financial institutions, credit information bureaus, lenders (potential or actual), their agents and/or representatives.

· To perform loan collections. We may disclose your personal information to collection agencies, counsels and our agents to enforce our rights against you as our borrower as a last resort in case of default.

· To administer our business. We may disclose your personal information to third party service providers solely for the purpose of assisting or rendering services to us in the administration of our lending business.

· To procure insurance. We may disclose your personal information to third parties such as insurance companies, solely for the purpose of insuring us from borrower default or other credit loss, and you, the borrower, from fraud or unauthorized charges.

· To post testimonials. We post testimonials on our App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at privacy@plentina.com and be sure to include your name, testimonial location, and contact information.

· To request feedback. We may use your information to request feedback and to contact you about your use of our App.

· To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

· To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

· To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

· To protect our Services. We may use your information as part of our efforts to keep our App safe and secure (for example, for fraud monitoring and prevention).

· To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

· To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

· To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the App.

· To administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

· To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

· To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

· To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our App, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

· To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

· For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, marketing and your experience.

· Profiling, automated processing, automated decision-making, or credit rating or scoring. We may use your personal data for profiling, automated processing, automated decision making, credit rating or scoring. Thus, we may use any of the methods to process your registration, loan application, and your use of our App and Services.

We will only process your information in the aforementioned methods if the same is necessary for our performance of our obligations to you and based on your consent.
We commit to implement suitable measures to safeguard your rights and freedoms and legitimate interests. If you wish to exercise your rights regarding profiling, automated processing, and/or automated decision-making you may contact us at privacy@plentina.com.

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

The Company acknowledges its role and responsibilities under the law, subject to the provisions of this Policy. In providing our Services to you, you consent to our outsourcing of our data processing activities within and among Plentina and its subsidiaries and affiliates, such as Plentina, Inc., a company duly organized and existing under the laws of the United States of America, and which provides credit-scoring services to using your personal information. This arrangement is covered by a Data Outsourcing Agreement which you may access upon request from us.

We may also process or share your data that we hold based on the following legal basis:

· Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

· Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

· Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

· Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

· Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, subject to the requirements of the applicable law/s, we may also need to process your data or share your personal information in the following situations:

· Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

· Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

· Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

Any data transfer/sharing to outside parties will be covered by a Data Sharing/Outsourcing Agreement, when applicable.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, and in the case of account termination, for an archiving period of twelve (12) months to allow for ease of account revival, unless a longer retention period is required or permitted by law (such as tax, accounting, anti money laundering or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either irreversibly delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You understand that you are, at any time, free to unsubscribe from our newsletters, delete your account, uninstall our App from your devices, and/or submit an official request for deletion of your data, subject to this Policy. Should you wish to have your personal information deleted and destroyed or you wish to withdraw your consent in the processing of your personal information, you may do so by contacting us.

The deletion of your personal data shall be honored within reasonable time from request and as long as it will not compromise, damage, injure, or make inefficient the entirety, integrity, confidentiality, and security of App and/or Services, and shall be performed within such reasonable time from the time of your request to do so.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of physical, organizational, and technical security measures.

We have implemented appropriate physical, technical, and organizational security measures designed to protect the security of any personal information we process subject to the requirements of the law and of commercially acceptable standards for data protection.

We will develop and implement measures to ensure that all Plentina staff who have access to any personal information will strictly process such data in compliance with applicable laws and regulations. These measures may include drafting new or updated relevant policies of Plentina and conducting or sponsoring training programs to educate our stockholders, directors, officers, employees, agents and other interested parties on data privacy related concerns. A continuing obligation of confidentiality is also imposed on our stockholders, directors, officers, employees, agents or other interested parties in connection with such personal information that they may encounter during the period of which they are such with Plentina. This obligation will still apply after they cease to work with Plentina for whatever reason.

Furthermore, Plentina will, from time to time, conduct a privacy impact assessment relative to all activities, projects and systems involving the processing of personal information. We will review security policies, conduct vulnerability assessments and perform penetration testing, as applicable, within Plentina on a regular schedule to be prescribed by our IT Team.

Our IT team will continuously evaluate this Privacy Policy, considering the following:

Safeguards to protect Plentina computer network and systems against accidental, unlawful, or unauthorized usage, any interference which will affect data integrity or hinder the functioning or availability of the system, and unauthorized access;
Our ability to ensure and maintain the confidentiality, integrity, availability, and resilience of Plentina data processing systems and services;
Regular monitoring for security breaches, and a process for identifying and accessing reasonably foreseeable vulnerabilities in Plentina computer network and system, and taking preventive and corrective actions against security incidents;
Our ability to restore the availability and access to personal information in a timely manner in the event of a security incident;
A process for regularly testing and evaluating effectiveness of security measures; and
Encryption of personal information during storage and while in transit, authentication process, and other technical security measures that control and limit access thereto.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to minors, being individuals under 18 years of age. By using the App, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@plentina.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Under the Law, you are entitled to the following data privacy rights:

1. the right to be informed whether your personal information shall be, are being, or have been processed;

2. the right to object to the processing of your personal information;

3. the right to reasonably access your personal information;

4. the right to dispute the inaccuracy or error in your personal information and have us correct it immediately and accordingly;

5. the right to suspend, withdraw, or order the blocking, removal or destruction of your personal Information from our records;

6. the right to file a complaint with the proper government authorities for any violation of your data privacy rights;

7. the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information not in accordance with this Statement;

8. the right to data portability of your personal information; and

9. the right to be informed whether personal information is being or has been processed. This includes processing through automated processing, automated decision-making and profiling

In respecting your data privacy rights, you may opt to tell us:

1. not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the Services that you have availed with us;

2. to provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the relevant jurisdictions where Plentina operates by certain laws and regulations;

3. to update your personal information; and

4. about your other concerns relating to how we collect, use, share, protect or dispose your information.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

■ Log in to your account settings and update your user account.

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and User Agreement and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

■ Contact us using the contact information provided in this Policy.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a Policy of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE AND EXERCISE YOUR DATA PRIVACY RIGHTS?

If you have questions or comments about this Policy, you may contact our Data Protection Officer (DPO), Edsel Tupaz, by email at privacy@plentina.com, or by post to:

Edsel Tupaz

Plentina Lending, Inc.

Valgosons Admin Office, 8484 Ground Floor.,

Valgosons Building, East Service Road,

Km 18, South Superhiway, San Martin de Porres,

Parañaque City, Metro Manila,1700

You have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at privacy@plentina.com.

12. YOUR ACKNOWLEDGMENT AND CONSENT

In Short: Yes, you acknowledge and consent to our data processing activities as described in this Policy.

By communicating with us using the App and our Services, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and/or transfer of your Personal Information by us as described in this Policy.

You agree that we may use our Personal Data and other Information for automated processing, automated decision-making, profiling, and credit scoring in connection with the your application, establishment, maintenance, cancellation and/or closure of your account and your relationship with us including the our provision of our Services and your use of the App and our Services.

From time to time we may modify, update or amend the terms of this Privacy Policy by placing the updated Policy on our App and website. The effective date of such modifications, updates or amendments will be noted at the start of the Policy. You should therefore review it periodically so that you are up to date on our most current policies and practices. If we make material changes to our practices regarding the processing and/or use of your personal information, your personal information will continue to be governed by the version of the Policy to which such personal information was subject (prior to those changes), unless you have been provided notice of, and have not objected to, the changes. By continuing to communicate with us, by continuing to use our App and Services or by your continued engagement with us following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments; provided, we shall secure your express consent when so required by the Law.

By submitting the required personal information to us, you consent to such collection, disclosure, processing and use thereof. You hereby expressly waive and release us from any and all liability, claims, causes of action or damages arising from our legitimate use of the submitted personal information.

***nothing follows***

Privacy Policy Last Updated: December 1, 2021

Privacy Policy
Last Updated: December 1, 2021