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Legal

Privacy Policy

This Policy sets out the commitment of First Digital Finance Corporation doing business under the names and styles of FDFC, BalikBayad, and Billease (“FDFC”) regarding the collection, processing, and storage of personal information and sensitive personal information (collectively “Personal Data”) in accordance with the Data Privacy Act of 2012 (“DPA”), its implementing rules and regulations (“DPA IRR”), and other issuances by the National Privacy Commission (“NPC”).

Security

Much of the information we hold about you will be stored electronically in secure data centers. Some information we hold about you will be stored in paper files. We recognize how important it is to protect and manage the information you share with us. We use a range of physical and electronic security measures to protect the security of personal information we hold. In addition, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we only authorize access to those employees who require it to fulfill their job responsibilities.

Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required.

Collecting your information

We collect information about you in a number of ways:
  • Information you provide to us through our websites and applications;
  • Information you provide through communications with us;
  • Information you have provided to us or authorized us to collect through our applications such as your photograph, video footage, or facial features obtained via access to your computer/smartphone camera or photo gallery and your phone, email, or social media contact lists and metadata, exclusively for the purpose of KYC and preventing fraud;
  • Information you have authorized us to collect from various services and networks, including financial institutions, financing companies, lenders, your employer (for auto-debit or other auto-deduction mechanisms) whether private or public, telecommunication companies (such as Globe Telecom, Inc., Smart Communications, Inc., PLDT, Inc., Sun Cellular/Digitel Mobile Philippines, Inc.), utility companies (such as Meralco/Manila Electric Company, Maynilad Water Services, Inc., Manila Water Company, Inc.) and data aggregating affiliates of such telecommunications and utility companies such as but not limited to Kayana Solutions Inc., government agencies (such as SSS, GSIS, NSO, BIR), credit bureaus (such as the CIC, NFIS), remittance companies (such as Palawan Express, Cebuana Lhuillier), insurance providers (such Sun Life Grepa Financial, Inc., Insular Life), financial service providers (such as CC Mobile Financial Services Philippines, GCash/G-Xchange, Inc., PayMaya Philippines, Inc.) and other service providers, online or otherwise; and
  • Information from outside sources such as credit bureaus and customer service providers to help us with customer verification and credit-related decisions.

In addition to the personal and financial information you submit (or we collect), we may collect information about your computer and smartphone, including, where available, your IP address, operating system and browser type, for the purposes of system and loan administration and product improvement.

We may also record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.

To register with us you must be 18 years of age or older. Minors are strictly forbidden from using the service.

Use of your information

Information we hold:

We will hold and use the following details about you:

  • your name, address, phone numbers, email address, date of birth, employment and banking and financial details;
  • demographic and lifestyle information;
  • information we receive when making a decision about you, your loan or application (including information collected from credit bureaus or other sources);
  • details of the loans you have and have had with us and all transactions;
  • details of when you contact us and when we contact you;
  • mobile device data (such as SIM, IMEI, or other device identifiers, type of device, device operating system, device settings, user account information for your mobile device or Google PlayStore account, information about mobile network provider, device specifications), Location data (such as mobile device location, time zone setting); phone data (such as contact lists and metadata, SMS metadata, types and nature of mobile applications found on your mobile device); mobile app usage data (such as traffic volume, mobile app usage) and telecommunications usage data or “telco usage score”;
  • as well as any other information which we reasonably need to operate your account, make decisions about you or fulfill our regulatory obligations.

We may keep details of any phone number(s) that you call us from and use them to contact you.

References to personal information include all of the information above whether obtained from you, from a credit bureau, from the internet or from any other source.

Information we share:

We will keep your personal information confidential and only share it with others for the purposes explained in this policy. We have trusted relationships with carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your personal information and to use it only as permitted by us.

We may share information about you:

  • with any firm, organization or person we use to help us operate our lending business for the purpose of conducting KYC, determination of credit worthiness, fraud prevention, and to collect payments and recover debts or to provide a service on our behalf;
  • with any firm, organization or person who provides us with products or services or who we provide products and services to for the purpose of providing such products and performing such services;
  • with any person who has told us and who we reasonably believe to be your parent, carer or helper, when proof is presented that you are unable to handle your own affairs because of mental incapacity or other similar issues for the purpose of proper handling of said affairs;
  • with any payment system we may use for the purpose of disbursement of loan proceeds and payment of loans;
  • with any Third Party Entities (“Partners”) engaged by the Lender such as the Borrower’s employer (for auto-debit or other auto-deduction mechanisms) whether private or public, telecommunication companies (such as Globe Telecom, Inc., Smart Communications, Inc., PLDT, Inc., Sun Cellular/Digitel Mobile Philippines, Inc.), utility companies (such as Meralco/Manila Electric Company, Maynilad Water Services, Inc., Manila Water Company, Inc.) and data aggregating affiliates of such telecommunications and utility companies such as but not limited to Kayana Solutions Inc., government agencies (such as SSS, GSIS, NSO, BIR), credit bureaus (such as the CIC, NFIS), remittance companies (such as Palawan Express, Cebuana Lhuillier), insurance providers (such Sun Life Grepa Financial, Inc., Insular Life), financial service providers (such as CC Mobile Financial Services Philippines, GCash/G-Xchange, Inc., PayMaya Philippines, Inc.) for the purpose of (i) determination of creditworthiness, conducting all the necessary background checks that may include credit scoring and investigation, and data analytics; (ii) data analytics, statistical analysis and demographics, business development purposes (such as improvement of the websites, mobile applications, and the Lender’s credit scoring algorithm/s including the performance of profile analysis, behavioral modeling, and analytics to understand market trends including conducting studies, research, statistical, automatic, and manual profile analysis, behavior modelling (including without limitation, training and back-testing machine learning algorithms of our third-party service provider’s software) to improve efficiency and reliability of their credit scoring capabilities, the creation of effective service delivery and payment collection strategies, improving customer experience and customer assistance), and the direct marketing of the Lender’s existing and prospective financial services as well as the products and services of its Partners; (iii) for fraud detection, investigation, and prevention; (iv) for all phases of provisioning the products and services that the Borrower may apply for including evaluation of loan applications, its automated processing, complying with eKYC (Know Your Customer) regulations required by the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, and the Anti-Money Laundering Council, credit verification, credit scoring, and payment collection.
  • with any of our lenders, including but not limited to any local or foreign financial institutions, or any agent, assignee or transferee of any such lenders, in connection with any loan or credit facilities that we may obtain from any such lenders, for purposes that may include but are not limited to (i) the conduct of credit assessment on us or our business, (ii) providing as collateral our receivables from you and our rights under our contracts with you, (iii) registration of the security interest constituted in favor of any such lender or any other secured party with any registry maintained by a government body, including but not limited to the Personal Property Security Registry administered by the Land Registration Authority, (iv) any audit, inspection or monitoring that may be conducted by any such lender or any other secured party or in connection with any regulatory obligation of any such lender, (v) loan and/or collateral administration, and/or (vi) enforcement of any security interest given to any of such lenders or secured parties. For avoidance of doubt, your sensitive personal information is among the information that may be shared pursuant to this paragraph;
  • with any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you, or transfers arising out of or in connection with the enforcement by any lender or security agent of security interests constituted in their favor in accordance with relevant agreements or applicable law. If the transfer or sale goes ahead, which may also occur in the exercise of a third party’s security interests referred to in the preceding paragraph and this paragraph, the transferee or purchaser may use your personal information and/or sensitive personal information in the same way as us;
  • certain authorities in order to detect and prevent terrorism (including to authorities outside the Philippines);
  • with regulatory agencies and government authorities (including but not limited to the Securities and Exchange Commission, the Bangko Sentral ng Pilipinas, the Bureau of Internal Revenue, the National Bureau of Investigation, the National Privacy Commission, and the Office of the Ombudsman), including those overseas, where we are requested by them to do so;
  • with credit bureaus or any similar organization which provides a centralized application matching service that collects information from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud. We may also provide information to third parties to help them to make decisions about whether to lend to you, allow you extended payment terms or otherwise do business with you.
  • with any third-party communications or messaging provider (including but not limited to telecommunications carriers, voice-call service providers, and third-party mobile messaging applications including but not limited to Viber), for the limited purpose of delivering one-time passwords, verification codes, and other account-security or transactional notifications to you.

How we use your information

We will use your information to:
  • search credit bureaus’ records (including information from overseas);
  • make, or assist in making, credit decisions about you, assess lending and insurance risks and to check the details that you have let us and others have;
  • operate and manage your account and manage any application, agreement or correspondence you may have with us;
  • carry out, monitor and analyze our business;
  • contact you by email, SMS, letter, telephone or in any other way about our products and services, unless you tell us that you prefer not to receive marketing;
  • contact you by SMS, voice call, or third-party mobile messaging application (including but not limited to Viber) for the limited purpose of delivering one-time passwords, verification codes, and other account-security or transactional notifications;
  • identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
  • form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
  • carry out market research, business and statistical analysis;
  • conduct profile analysis, behavioral modeling, and analytics to understand market trends including conducting studies, research, statistical, automatic, and manual profile analysis, behavior modelling (including without limitation, training and back-testing machine learning algorithms of our third-party service provider’s software) to improve efficiency and reliability of their credit scoring capabilities;
  • provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
  • carry out audits;
  • perform other administrative and operational purposes including the testing of systems;
  • trace your whereabouts;
  • recover any debt you owe us; and
  • comply with our regulatory and contractual obligations.

Your data may also be used for other purposes for which you give your permission or where we are permitted to do so by law or it is in the public interest to disclose the information or is otherwise permitted under Philippine law.

Credit Bureaus

When you apply for a loan from us, we will check the following records about you (and others where applicable):

  • our own, including information and records you supplied to us or authorized us to collect;
  • those at credit bureaus;

Whether or not your application is successful, when credit bureaus receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit. This is applicable whether you have been accepted or declined.

The credit bureaus supply us with both public information and shared credit and fraud prevention information including information about previous applications and the conduct of your accounts.

We may also make periodic searches at credit bureaus to manage our relationship with you.

Information provided by you on our applications will be sent to credit bureaus and will be recorded by them. We and other organizations may access and use this information to prevent fraud and money laundering and credit bureaus may use your information for statistical analysis. Information held by credit bureaus will be disclosed to us and to other organizations in order to (for example):

  • prevent fraud and money laundering and to check and assess applications for credit, credit related or other facilities;
  • recover debts that you owe and trace your whereabouts;
  • manage credit accounts and other facilities and decide appropriate credit limits;
  • verify your identity;
  • make decisions on credit and other facilities for you, your financial associate (s), members of your household or your business;
  • check details on proposals and claims for all types of insurance; and
  • check details of job applicants and employees.

When you borrow from us, we will give details of your loan and how you manage it to the credit bureaus. If you borrow and do not repay in full and on time, the credit bureaus will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding; other organizations may see these updates and this may affect your ability to obtain credit in the future.

If you fall behind with your payments and a full payment or satisfactory proposal is not received, then a default notice may be recorded with the credit bureaus. Any records shared with credit bureaus will remain on file for a retention period after your account is closed, whether any outstanding sums have been settled by you or as following a default.

If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud, we may record this and may also pass this information to organizations involved in crime and fraud prevention including law enforcement agencies who may then access this information.

We and other organizations may access and use the information recorded by fraud prevention agencies from other countries.

Retention of your information

We will hold your personal data and records for as long as necessary for the fulfillment of the above-stated purposes and uses, or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as may be provided by law.

In the event that your personal data are no longer required to be retained, such data will be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or that would prejudice your interests.

1. Your Rights as a Data Subject

Under the DPA, you have the following rights as a data subject:

  1. You have the right to indicate your refusal to the collection and processing of your personal data. You also have the right to be informed and to withhold your consent to further processing in case there are any changes or amendments to information given to you. Once you have notified us of the withholding of your consent, further processing of your personal data will no longer be done, unless (i) the processing is required pursuant to a subpoena, lawful order, or as required by law; or (ii) the collection and processing is pursuant to any lawful criteria indicated under the terms of this Policy.
  2. You have the right to reasonable access to your personal data. Furthermore, you have the right to limit and prevent disclosure of your personal data, to be provided with the identity of the recipients of your personal data that may have been shared by us with third parties, and to receive notification of any possible breaches of your personal data.
  3. You may also correct or remove any information that you think is inaccurate. You have the right to dispute any inaccuracy or error in your personal data. You may request for the correction or removal of any inaccuracy or error in your personal data by logging into your account or making a formal request with our Data Privacy Officer.
  4. You have the right to the destruction of your personal data;
  5. You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal information;
  6. You have the right to lodge a complaint with the NPC.
  7. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent prior to its withdrawal by contacting our Data Protection Officer (“DPO”) with the contact details below.

If you would like to make any request in relation to your rights as a data subject, please contact our DPO. Please note that the exercise of some of your rights as a data subject is subject to review and may result in the denial of any application currently pending.

Third party links

Our site may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for them.

Social Media Features

Our Web site includes Social Media Features such as the Facebook Like button. These Features may collect your IP address, which pages you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Biometric and Face Data

As part of our identity verification and Know-Your-Customer (KYC) process, we collect face data — specifically a selfie image and a liveness capture taken via your device camera — which we match against your government-issued ID.

Why we collect and store it: We collect and store this face data to verify your identity, to comply with the KYC, anti-money-laundering, and record-keeping obligations imposed on us as a financing company regulated by the Securities and Exchange Commission (SEC) and the Bangko Sentral ng Pilipinas (BSP), and to prevent fraud and account takeover.

How long we store it and why: We retain face data for as long as necessary to fulfill the declared, specified, and legitimate purpose connected to your use of a Billease account, which in this case is the entire tenor of your loan obligation and any extensions or restructuring thereof, and subject at all times to the applicable prescriptive periods for actions on written contracts under Philippine law for the establishment, exercise, or defense of legal claims in relation to your loan obligation. Retention of your face data is exclusively for purposes of identity verification, KYC, and ensuring compliance with anti-money laundering obligations under Philippine law. We do not store face data indefinitely. Once this retention period lapses and the data is no longer required for the purposes described above or for the establishment, exercise, or defense of legal claims, it is securely and permanently deleted.

Third parties we share it with, and why: We use Innovatrics, a third-party identity-verification provider, to perform face matching and liveness detection. We share your face data with Innovatrics solely to carry out this identity-verification check.

Whether the third party stores it: Innovatrics processes your face data only to perform the verification and return a result; it does not store your face data. All selfie images are stored solely on our own secured servers, encrypted in transit and at rest.

Verification Codes and One-Time Passwords

Verification codes may be delivered via SMS, voice call, or third-party mobile messaging applications (including but not limited to Viber), and your mobile number may be shared with a third-party vendor for the limited purpose of sending these verification codes for account-security or transactional notifications.

Changes to Privacy Policy

We may make changes to this Privacy Policy from time to time (without notice to you) that are necessary for our business requirements or the law. We encourage you to visit this page from time to time to ensure you have read our most current Privacy Policy. In case of substantial changes which will affect the purpose, scope, method, and extent of our processing of your data, we shall endeavor to secure your consent. For the avoidance of doubt, your continued use of the Company’s services shall be considered assenting action signifying consent to such changes to this Privacy Notice.

Data Protection Officer

The Data Protection Officer (DPO) is the individual principally responsible for ensuring that FDFC complies with all applicable laws and regulations for the protection of data privacy and security. The DPO is likewise responsible for the supervision and enforcement of this Policy. You may reach the DPO via the following contact information:

Data Protection Officer

FIRST DIGITAL FINANCE CORPORATION

9th Floor T.M. Kalaw Center Building,

667 T.M. Kalaw Ave., Ermita, Manila

Tel. No. (02)53203051

email add.: [email protected]

Questions and complaints

If you have any questions or concerns regarding this Privacy Policy or if you have any complaints on our use of your personal information, please email us at [email protected] .