Believe Commodities-Loan Cash Privacy Agreement
The Company "Believe Commodities PRIVATE LIMITED" is doing business under the platform “Believe Commodities-Loan Cash” and respects the privacy of our customers and users of our online platforms such as our mobile application. “Believe Commodities-Loan Cash” respects the privacy of our customers and users of our online platforms, such as our mobile application. We strive to embed privacy in all of our processes in compliance with rules and regulations, and other issuances of the National Privacy Commission.
We recognize the importance of protecting your personal information and transparency in the way that we collect, use, store, transfer/disclose, and dispose of information derived from your use of our products, services, online portals, and mobile applications.
1. Collection of Information
Personally Identifiable Information
“Personally identifiable information” is information that can be used to uniquely identify an individual, such as name, password, age, civil status, gender, mailing address, email address, telephone number, mobile number, income, employment details, financial information, credit info, photographs, and other personal info. We also consider personal information and sensitive personal information, as defined under the Data Privacy Act of 2012, as personally identifiable information.
We collect personally identifiable information when you apply for our services, and when you register an account on our mobile applications and online platforms. You may be asked to provide us with personally identifiable information through our website, mobile apps, Point-of-Sale devices, or paper application forms.
Mobile Device Data & Mobile App Permissions
Other than personally identifiable information defined above, “Believe Commodities-Loan Cash” Indias may also process the following data through your use of the mobile app: mobile device data or other identifiers; location data; phone data; and mobile app usage data such as traffic volume, crash logs, diagnostics, and page views and taps.
The “Believe Commodities-Loan Cash” mobile application may likewise request, with your prior consent, that you activate specific app permissions including, limited to Calendar, GPS Location, Device Information, Address Book, and phone number, and files that we need for fraud prevention, security, and to determine your eligibility for “Believe Commodities-Loan Cash” Indias’ products and services. We may also request to send you push notifications about your account or the mobile app.
The general description of the mobile app’s behavior can be referenced through the permissions module of your mobile phone. If you wish to change our access or permissions, you may do so in your device’s settings. You may deactivate the permissions requested by the “Believe Commodities-Loan Cash” mobile app after the submission of any application for our services. However, certain features or resources meant to enhance security or usability may not work or may produce a degraded experience for you.
The mobile application's processing of personal information and metadata is consistent with the purposes we explained in this privacy notice.
GPS Location
Location data that we collect with your prior consent or permission will be used to help you find nearby merchant partners and deals tailored for you. We also use location data in our scoring and underwriting models to determine your eligibility for our services. You can disable this permission anytime through the app or through your phone’s settings. We may engage third-party partners who provide us with location data, which we use in skip tracing, to support our collection efforts. We assure you that we only partner with third parties that process personal data with reasonable and appropriate data protection controls and who guarantee us that data are collected lawfully and in compliance with all regulations where the data is sourced.
Device Information:
We may collect certain device information, including but not limited to the type of device you are using, unique device identifiers, operating system information, and mobile network information. This information helps us optimize our services for your device and diagnose technical issues that may arise.
Address Book Information:
With your consent, the App may access your address book to facilitate certain features, such as inviting friends to use the App or processing loan requests. We will only access this information for the purposes specified and will not store it beyond what is necessary to fulfill those purposes.
Calendar Information:
The App may request access to your calendar information to schedule appointments or reminders related to your loan applications or financial aid services. We will only use this information for the purposes explicitly stated and will not retain it longer than necessary.
2. Use of Personally Identifiable Information
Accurate information about you lets us provide you with a smooth, efficient, and customized experience. The personally identifiable information you share will be used according to the contracts you execute with us for our services. Specifically, we may use information collected about you through the mobile application for the following purposes.
a. to assess your eligibility to use our products and services, including, but not limited to, credit verification, credit scoring, automated processing of loan applications, loan collection, and complying with eKYC (Know Your Customer) regulations required by the Bangko Sentral ng Pilipinas and the Anti-Money Laundering Council.
b. for the creation of your user account in the “Believe Commodities-Loan Cash” Indias Mobile Application.
c. to enable mobile app features and functionalities.
d. to verify your identity and/or other information you provided to us.
e. to detect and prevent fraud, money laundering, and/or other illegal uses of our services.
f. to send you information about “Believe Commodities-Loan Cash” Indias, including news about product updates, events, and other promotional materials, but only if you agree to receive such communications. “Believe Commodities-Loan Cash” Indias will not share any personally identifiable information with third parties for marketing purposes without your consent.
g. to provide customer service or support and to resolve issues and complaints.
h. for data analytics, data profiling, and other legitimate interests, which will help us understand your needs and to help us improve our services.
3. Storage and Security of Personally Identifiable Information
Personally identifiable information provided to “Believe Commodities-Loan Cash” Indias is stored in a secure database under our control. We have taken reasonable and appropriate steps to protect the information you share with us, including, but not limited to, physical security controls, equipment, software, and technical security controls such as encryption to prevent unauthorized access, use, or disclosure of personally identifiable information. Always keep your “Believe Commodities-Loan Cash” Indias mobile application updated to ensure you experience the latest and most secure features.
4. Retention of Personally Identifiable Information
We retain your personally identifiable information for varying periods of time, sometimes for extended periods, due to operational business needs and legal requirements. Among the reasons we retain your personal data are:
(i) for the reasonable period necessary for us to deliver our services,
(ii) to meet legitimate business purposes,
(iii) when necessary for the establishment, exercise, or defense of any legal claim, and
(iv) to comply with retention periods provided by other laws governing “Believe Commodities-Loan Cash”
For example, despite your request to delete your account in the “Believe Commodities-Loan Cash” mobile app, we are required by the Anti-Money Laundering Act and its implementing rules to retain transactions and customer records for a period of at least five (5) years. If an account is also the subject of a case filed in court, retention may also extend beyond the five-year period. Similarly, pertinent BIR Regulations also require us to retain electronic data, books of accounts, and other accounting records necessary for tax filing purposes for ten (10) years.
Factors we consider when deciding how long we retain your information include how long we’ve had a relationship with you or provided you with our services, our legal obligations, such as in the example above, or legal positions we’ve taken, such as any applicable statutes of limitations.
When the purposes of processing your information no longer exist, the applicable retention periods have expired, or we are no longer legally obligated to retain them, we will either delete, de-identify, or anonymize your personal information, or if not yet possible, then we will securely store your personal information and isolate it from any further processing until such deletion is possible.
5. Disclosure and Transfers of Personally Identifiable Information
“Believe Commodities-Loan Cash” Indias does not share any personally identifiable information with other parties except as described in this notice and in the Applicant Consent Form (ACF) signed by customers. As mentioned in your ACF, we may share your information with our partners, such as government agencies, partner stores, utility companies, remittance companies, insurance providers, financial service providers, courier service providers, order or payment processors, merchandise warehouse and fulfillment services and other services providers, but only to the extent necessary to provide the services you consented to or signed up for.
“Believe Commodities-Loan Cash” Indias may share personally identifiable information to comply with court orders or laws that require us to disclose such information. In the event of a reorganization, sale, or merger, we may transfer personally identifiable information to the relevant third party with users’ consent if required by law.
“Believe Commodities-Loan Cash” Indias may share anonymous data, aggregated or not, with third parties. We ensure that such anonymous data does not allow the identification of customers and users to which they relate.
6. Persons under the Age of 18
“Believe Commodities-Loan Cash” Indias will not knowingly collect personally identifiable information from any person under the age of 18. “Believe Commodities-Loan Cash” Indias encourages parents to instruct their children never to give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us.
7. Data Subject Rights
Under the Data Privacy Act, you have the right to be informed, the right to object, the right to access, the right to rectification, the right to erasure or blocking, the right to damages, and the right to file a complaint.
You may contact us if you wish to exercise any of these rights. These rights, however, are subject to certain limitations. As such, we may decline requests that are excessively repetitive, require disproportionate technical effort, are against the public interest, jeopardize the privacy of others, or are extremely impractical or unreasonable.
8. Contact “Believe Commodities-Loan Cash” Indias’s Data Protection Officer (DPO)
“Support” Indias’ Data Protection Officer provides support for any data privacy-related inquiries or complaints. You may contact “Believe Commodities-Loan Cash” India DPO through the following information:
Email address: info@believe commodities.com
Individuals with inquiries or complaints regarding our privacy practices should first contact our DPO. Our DPO will always make reasonable efforts to address and settle any requests or complaints that are brought to our attention.
9. What are your Data Privacy Information Rights?
You have the following rights regarding your personal data:
Right to Request Special Privacy Protections. You have the right to request restrictions on specific uses and disclosures of your personal data by a written request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information, we will abide by your request, unless we need to disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request and will notify you of our decision.
Right to Inspect and Copy. You have the right to inspect and copy your personal data, with limited exceptions. To access your personal data, you must submit a written request detailing what information you want access to, if you wish to inspect it or get a copy of it, and if you want a copy, your preferred form, and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable, or if we can’t agree and we maintain the record in an electronic format, your choice of a readable electronic or hard copy format. We will also send a copy to any other person you designate in writing. We will charge a reasonable fee that covers our costs for labor, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary. We may deny your request under limited circumstances. If we deny your request to access your personal records or the personal records of an individual you are representing because we believe allowing access would be reasonably likely to cause substantial harm to the customer, you will have a right to appeal our decision.
Right to Request Confidential Communications. You have the right to request that you receive your personal data in a specific way or at a specific location. You may ask that we send information to a particular e-mail account or to your work address. We will comply with all reasonable requests submitted in writing, which specify how or where you wish to receive these communications.
Right to Amend or Supplement. You have a right to request that we amend your personal data that you believe is incorrect or incomplete. You must make a request to amend in writing and include the reasons you believe the information is inaccurate or incomplete. We may deny your request if we do not have the information if we did not create the information, if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.
Right to Revoke Authorization. Your consent is necessary before “Believe Commodities-Loan Cash” can lawfully collect and process your personal data. You may revoke (take back) your consent at any time. To avoid doubt, this does not invalidate any previous processing that “Believe Commodities-Loan Cash” has performed in accordance with the consent initially given.
Right to Erasure or Blocking. You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal data. You can exercise this right upon discovery and substantial proof of any of the following:
a. Your personal data is incomplete, outdated, false, or unlawfully obtained.
b. It is being used for purposes you did not authorize.
c. The data is no longer necessary for the purposes for which they were collected.
d. You decided to withdraw consent or object to the processing, and there is no overriding legal ground for the processing.
e. The data concerns information prejudicial to the customer — unless justified by freedom of speech, of expression, or the press, or otherwise authorized by law.
f. The processing is unlawful.
g. “Believe Commodities-Loan Cash,” or its personal information processor/s, violated your rights as a customer.
Right to Be Notified of a Breach. You have the right to receive notifications of breaches of your personal data, as may be required by law. Aside from protecting you against unfair means of personal data collection, this right also requires “Believe Commodities-Loan Cash” to notify you promptly if your personal data has been compromised. If you have provided us with a current e-mail address, we may use e-mail to communicate information related to the breach.
Right to a Paper or Electronic Copy of this Notice. You have a right to be notified of our legal duties and privacy practices concerning your personal data, including a right to a paper copy of this Privacy Notice, even if you have previously requested its receipt by e-mail.
10. How Does “Believe Commodities-Loan Cash” Collect, Use, Transfer or Disclose, Retain, and Dispose Your Personal Data?
“Believe Commodities-Loan Cash” collects personal information about you and stores it on a computer or in an electronic record. To the extent reasonably necessary to affect the relevant purpose, we may use or disclose your personal data for the following:
Payment. We use and disclose personal information about you to other providers under or in partnership with “Believe Commodities-Loan Cash,” with an affiliate company or parent company, and other vendors to obtain payment for our services.
Payment Reminders. We may use and disclose your personal data to contact and remind you about due payments. If you are not home, we may leave this information on your answering machine or in a message left with the person answering the phone.
Research. Your personal information may be used and disclosed for research purposes, provided that it is approved through a unique review process to protect customer confidentiality. A researcher may have access to information that identifies you only through the unique review process or with your written consent. Your personal records may be used for data analytics to create customer demographics and trends; however, these reports are generated to anonymize customer identities.
Marketing. We may use your contact details to communicate with you and give you information about products, promotions, or services related to your loan applications or other services provided by “Believe Commodities-Loan Cash” with an affiliate company or parent company and other business vendors that may interest you. We may also contact you to ensure customer satisfaction regarding services provided, including identifying your concerns so that issues are addressed.
Required by Law. As required by law, we will use and disclose your personal data, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse, neglect, or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirement set forth below concerning those activities. We may disclose your personal data to an oversight facility for legally authorized activities. These oversight activities include, for example, audits, investigations, inspections, and licensure.
Law Enforcement. We may, and are sometimes required by law to, disclose your personal data to a law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness, or missing person, complying with a court order, warrant, subpoena, and other law enforcement purposes.
Other Uses and Disclosures: If “Believe Commodities-Loan Cash” wants to use or disclose your personal data for a purpose that is not discussed in this Privacy Notice, “Believe Commodities-Loan Cash” will ask for your written consent.