Trusting Social AI Philippines, Inc. (hereinafter referred to as “the Company”, “We” or “Us”) operates the https://www.goevo.ph/ and the EVO Application (hereinafter referred to as the “Platform”). We respect and value your privacy and we employ reasonable measures to protect your personal information in accordance with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and related issuances from the National Privacy Commission (“Commission”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Platform and the choices you have associated with that data.
We use your data to provide and improve the Platform. By clicking “Next”, prior to the creation of your account, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.goevo.ph/t-c.
Definitions
The following words and terms shall have the meanings set forth below, unless repugnant to the context and/or otherwise mentioned:
“Loan Provider” shall mean a bank or a lending company duly licensed by the Bangko Sentral ng Pilipinas or by the Securities and Exchange Commission to engage in the business of lending money to third persons.
“Company” / “We” or “Us” shall mean Trusting Social AI Philippines, Inc. and includes its successor and assigns.
“Commission” shall mean the National Privacy Commission of the Republic of the Philippines.
“Partner Products” shall refer to the products and/or services offered by Loan Providers and third parties such as channel partners which conduct marketing campaigns with whom the Company may have contractual arrangements with for the purpose of providing information regarding the product and/or services of such third parties.
“Person” includes any individual, partnership, corporation, company, society, unincorporated organization or association, joint venture company, joint stock company, trust or other entity, whether incorporated or not.
“Third Party Partners” shall refer to third party entities such as channel partners of the Company which conduct marketing campaigns.
“Third Party Service Providers” shall refer to processors or subprocessors engaged by the Company.
“You” / “User” shall mean the Person accessing or using the Platform or submitting any information on the Platform.
This Privacy Policy supplements the Terms and Conditions.
- Personal Information Collected and Processed
1.1 When you use our Platform, we process, collect and store several different types of information for various purposes to provide and improve our Platform to you.
1.2 While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you:
- your full name;
- email;
- gender;
- Selfie / photograph;
- Photo of ID;
- mailing address;
- postal code;
- results of evaluation checks, or credit scoring and evaluation results;
- type of employment;
- monthly net income;
- civil status;
- Other Employment information including but not limited to Monthly Gross Income, Employer/Business Name, Nature of Work, Position Employment Status, Years of business / Work Experience;
- Taxpayer Identification Number (TIN);
- Home Development Mutual Fund (HDMF or Pag-IBIG) Number;
- family details;
- phone number;
- Taxpayer Identification Number (TIN);
- Academic records and certificates.
- Reference contact information including, but not limited to the name and mobile number of the reference, relationship with the reference;
- Information from third party databases such as credit bureaus, Telecommunication network partners and customer service providers, including, but not limited to telecommunications usage data or “telco usage score;
At times, we may decide to conduct certain Know-Your-Customer processes. As a part of our Video Know Your Customer (Video KYC) process, collection of your personal information has become mandatory to ensure the completion and authentication of your KYC. In this regard, permissions for microphone, camera will be mandatorily required.
1.3 We may also collect information on how the Platform is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Platform that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers. Operating system, and other diagnostic data. This information is not matched with your personal information and will not be used to identify you.
1.4 We use cookies and similar tracking technologies to track the activity on our Platform and hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Platform.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Platform.
2. Methods of Collection and Processing
2.1 We collect your data from the documents and information that you may have directly submitted to us, information from third party databases such as mobile network operators (e.g. Globe, PLDT, Smart, Sun Cellular), telecommunication companies, banks, financial institutions, credit bureaus and customer service providers, or forms, surveys, and/or other channels.
Where you have provided us with the personal data of individuals other than yourself, you warrant that you have obtained their consent for the disclosure, in accordance with the DPA.
Your personal data may be processed both by way of computer media and on paper, in compliance with the rules in relation to personal data protection, therein including those relating to data security.
3. Use of Data
3.1 The Company uses the collected data for various purposes:
- To provide and maintain the Platform;
- To onboard you in the platform / start the onboarding process;
- To ensure that the provided information is accurate by verifying information with third parties;
- To communicate with you alerts, notifications, follow-ups, and recommendations;
- To process your application for Partner Products on your behalf;
- To provide you with updates and reminders regarding applications you have commenced, including but not limited to informing your about Partner Products pre-approvals or updates;
- To conduct credit checking and/or to perform data analytics on the propensity of a user to pay off credit products, and such other related analytics;
- To allow the Company and/or Loan Providers to provide you with information about products and services offered by the Company and/or the Loan Providers;
- To conduct initial Know-Your-Customer services for the Loan Providers pursuant to agreements with such parties;
- To connect you with our partners on the Platform;
- To share the data with our Loan Providers and other partners for purposes of processing your application and onboard you more seamlessly on their end;
- To monitor the usage of the Platform;
- To provide customer care and support;
- To detect, prevent and address technical issues;
- To provide analysis or valuable information so that we can improve the Platform;
- To store and save customer data to improve our services;
- To monitor, detect and prevent fraud or abuse of the Services;
- To establish, exercise, or defend legal claims;
- To fulfill any other purposes directly related to the above-stated purposes.
We will not process your personal information in ways incompatible with the above-stated purposes.
Our communications with you may be conducted through SMS, e-mail, and other electronic means, including but not limited to messaging applications such as Viber, Telegram, Whatsapp, or Signal. Through such communications, we may send you links and other information in order to fulfill the purposes stated in this document.
4. Personal Information Controller
4.1 The Company is the Personal Information Controller under the DPA, which means that it determines what purposes personal information it holds will be used for. It may also be that your personal data is disclosed to third parties pursuant to a data sharing agreement. In which case, such third parties are also the personal information controllers of your personal information.
5. Transfers and Disclosures
5.1 The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
5.2 Your personal information may be disclosed to the Company’s Third Party Partners and Third Party Service Providers for the following purposes:
- To provide and maintain the Platform;
- To onboard you in the platform / start the onboarding process;
- To ensure that the provided information is accurate by verifying information with third parties;
- To communicate with you alerts, notifications, follow-ups, and recommendations;
- To process your application for Partner Products on your behalf;
- To provide you with updates and reminders regarding applications you have commenced;
- To conduct credit checking;
- To allow the Company and/or Loan Providers to provide you with information about products and services offered by the Company and/or the Loan Providers;
- To conduct Know-your-customer processes;
- To connect you with our partners on the Platform;
- To share the data with our Loan Providers, Third Party Partners, Third Party Service Providers and other partners for purposes of processing your credit application and onboard you more seamlessly on their end;
- To monitor the usage of the Platform;
- To provide customer care and support;
- To detect, prevent and address technical issues;
- To provide analysis or valuable information so that we can improve the Platform;
- To store and save customer data to improve our services;
- To monitor, detect and prevent fraud or abuse of the Services;
- To establish, exercise, or defend legal claims;
- To fulfill any other purposes directly related to the above-stated purposes.
5.3 The Company may also transfer your personal information to third parties as required by law or legal instrument, to protect the Company’s rights or assets, to facilitate acquisition or disposition of the Company’s businesses, and in emergencies where the health or safety of a person is endangered.
The following are the third parties to whom your personal data may be disclosed in accordance with the above-mentioned purposes:
- Loan Providers
- Financial institutions that provide credit and/or other financial products
- Third Party Service Providers
- Third -Party Partners
- Legal Counsel
- Government Agencies
- Stockholders and business partners
- Law enforcement agencies
- Government regulatory agencies and offices
- Potential investors or target companies in the context of a mergers and acquisitions deal
- Affiliates and subsidiaries
6. Data Retention
6.1 Your personal data will be retained or stored for as long as the purposes for which they are being processed have not been satisfied. The Company will retain and use your personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.
7. Data Protection Measures
7.1 The Company has put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to correctly use the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store.
7.2 The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
8. Access
8.1 We encourage you to keep their personal information current and updated. Subject access requests may be made by emailing the data protection officer at TSAIPH_DPO@trustingsocial.com. The Company may take reasonable steps to confirm the requestor's identity as a data subject before granting access to the personal information and allowing updates thereto.
9. Links to Other Sites
9.1 Our Platform may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
9.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or Platforms.
10. Rights of Data Subjects
10.1 Under the DPA, it is possible for individuals to request access to any of their personal data held by the Company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer.
10.2 The DPA requires the Company to take reasonable steps to ensure that any personal data it processes is accurate and up-to-date. It is your responsibility to inform us of any changes to the personal information that you have supplied to us during the course of your engagement.
10.3 You have the right to object to the processing of your personal information, including processing for direct marketing, automated processing, or profiling. You shall also be notified and be given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to you in this Privacy Policy. Please note that some of the personal data you have provided to us is necessary for us to comply with statutory and regulatory requirements, as well as the Company’s administrative policies and is thus mandatorily required to be collected and processed. Withholding of your consent to the processing of certain personal data may prevent you from availing of certain benefits.
10.4 You have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our filing system.
10.5 You have the right to be informed whether personal information pertaining to you shall be, is being, or have been processed, including the existence of automated decision-making and profiling.
10.6 Upon presentation of a valid decision, the Company recognizes your right to be indemnified for actual and verifiable damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information, taking into account any violation of your rights and freedoms as a data subject.
10.7 You are also granted the right to lodge a complaint before the Commission.
10.8 You have the right to request that the personal information provided to the Company be transferred to you or a third party at your request in a structured, commonly used and machine readable format.
11. Modification of Privacy Policy
11.1 We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
11.2 We will let you know via email and/or a prominent notice on our Platform, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
11.3 You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12. Contact Us
12.1 In case you require any clarifications or in case of any issues arising pursuant to this Privacy Policy, you may contact our data protection officer at: TSAIPH_DPO@trustingsocial.com
13. Validity of Consent
13.1 This consent and authorization remain valid and subsisting for a limited period consistent with the purposes above or until otherwise revoked or canceled in writing. You may inform the Company of the specific personal information you do not want to be processed beyond the requested purpose. The Company will respect your request insofar as it is feasible to fulfill the purpose for which the personal information was collected.