When you engage with us to avail of our loan products and services, you are trusting us with your information. We understand that this is a big responsibility, and we will work hard to protect your information and put you in control.

We have prepared this document exactly for you to understand how we process your data and how you can exercise your rights.

1. This Privacy Notice (“Notice”) tells you about our policy whenever we collect, use, or otherwise process the personal data of our clients in respect of their privacy rights.
2. You may email our Data Protection Officer at: dpo@invested.ph or you may write to our Data Protection Officer at Unit 908 Rosemont Tower, 75 Panay Avenue, Barangay Paligsahan, Quezon City.
3. This Notice is an important document. Please read it carefully. It is also available on our website at www.invested.ph/privacy. If you would like a printed copy, please contact dpo@invested.ph and we will send you a copy.
4. Note that while we may give examples to make this Notice clear and simple, the lists below are not exhaustive of all the data that we process.
5. Why and How We Use Your Personal Information
   1. Personal data provided by you or by others will be used by us, for the following processes:
      1. Loan application assessment;
      2. Computation of your allowable loan amount and grace period;
      3. Conduct Know Your Client (KYC) and fraud verification procedures;
      4. Disbursement of loans;
      5. Organize activities, trainings, workshops, webinars, and coaching sessions;
      6. Issuing payment reminders
      7. Credit and collection processes;
      8. Conduct of surveys;
      9. Conducting internal market studies and generating insights; and
      10. Direct Marketing
   2. As a Borrower:
      1. Your personal identification such as but not limited to your name, birthdate, address, employment background, and/or educational information may be collected and processed during your loan application and pre-qualification process.
      2. Personal circumstances as well as income information are used to compute the allowable loan and grace period.
      3. Should you be unable to provide us with the required personal data, we will be unable to provide you access to our loan facility.
   3. As a Guarantor:
      1. Your personal information, such as your name, contact number, email, relationship with the borrower, and other relevant information as to your personal circumstances will be used in assessing your eligibility as Guarantor for the loan of the Borrower.
      2. Your contact information may also be used to verify your identity as well as communicate with you as regards the status of the loan of the borrower.
6. We will use and share certain personal data to comply with certain legal obligations and regulatory requirements. The following processing activities are used for this legal purpose:
   1. To verify your identity the accuracy of the information we receive in compliance with the Anti-Money Laundering Act;
   2. To share your credit data with the Credit Information Corporation;
   3. To process payments or disbursements;
   4. To manage and investigate any complaints;
   5. To comply with laws and regulations;
   6. To make back-ups of your data in case of emergencies and for disaster recovery purposes.
   7. We will use and share certain personal data with our lenders, lawyers, accountants, consultants, and other service providers for legitimate business interests.

   The following processing activities are used for this legal purpose:

   a. Risk management, auditing, and the provision of financial advice which are key governance functions to protect our business;

   b. Checking information provided ensures accuracy which contributes to effective assessment of the loan application;

   c. Prevention and detection of fraud to help protect the business and the lending market;

   d. Direct marketing of our other products and services by post, telephone (including mobile), e-mail, or other means of communication which might be of interest to you;

   e. Market research, competitions, customer satisfaction surveys, and data analytics, including profiling, to develop and enhance the customer relationship and journey as part of our business strategy;

   f. We may record or monitor calls for regulatory, trainingv, and quality purposes;

   g. We may also share with or seek information from a number of external parties in order to enrich your customer journey and to prevent and detect fraud. For example:

   1. Other educational and financial institutions to confirm the information provided and to safeguard against non-disclosure and help prevent fraud;

   2. Anyone authorized to act on your behalf;

   3. Our Third-Party Service Providers such as technology suppliers, hosting/storage providers, payment providers, and document providers;

   4. Our funders and lawyers;

   5. As a result of our legal and regulatory obligations, other official agencies and on foot of a Court Order or Subpoena;

   8. We may need your consent for the processing of certain data and in these cases, we will inform you of such processing and the reason for this at the time consent is captured.
   9. In order to provide you with our products and services, we may share your personal information with third parties as set out in Section 6.7(g).
   10. In all of these processing activities, your interests are considered and we ensure that necessary safeguards are in place to protect your privacy, such as contracts in place with third parties, restricted access to data, regular testing, and evaluation of technical and organizational security measures, retention limitations, etc.
7. Your Rights in Relation to Your Personal Information
   1. You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected.
   2. Where we require your consent to process your personal data you have the right to withdraw your consent for such processing.
   3. You also have the right to have your personal data erased, object to certain processing activities, or have the processing restricted.
   4. You have the right to data portability for your personal information that you have shared with us.
   5. If you would like to exercise any of these rights, please email a request to dpo@invested.ph or write to us at the address contained in Section 2 of this Notice. To ensure that we do not disclose your personal information to a party who is not entitled to it, when you are making the request please provide us with:
      1. Your name;
      2. Address(es);
      3. Date of birth;
      4. A copy of your government-issued ID or reference numbers that you have along with a proof of address.
   6. All requests are free of charge although we reserve the right to charge an administrative fee for subsequent requests (such as when the request is part of a series of repeated requests over a short period of time).
   7. We endeavor to respond within one month from receipt of the request. If we do not meet this time frame, we will explain this in our response.
   8. Please be noted that by simply submitting a request does not mean we will be able to fulfill it – we are often bound by legal obligations which can prevent us from fulfilling some requests in their entirety, in such cases, we will inform you of this and explain this to you in our response.
   9. Please also be noted that exercising some of the above-mentioned rights may hinder us in continuing to provide you loan facilities and allied services and, therefore, lead to cancellation of your loan agreement with us, but when this is the case, we will inform you of this and explain this to you in our response.
8. How can you lodge a complaint?

   If you wish to raise a complaint on how we have handled your personal information, please send an email to dpo@invested.ph or write to us using the address provided in Section 2. Our Data Protection Officer will investigate your complaint and will give you additional information about how it will be handled. We aim to respond in a reasonable time, normally thirty (30) days.

9. Up-to-Date Information

   For us to keep your information accurate and up-to-date, please contact us at an email to dpo@invested.ph or write to us using the address provided in Section 2, if any of your details change.

10. Changes to our Data Protection and Privacy Notice

    This Notice will be updated regularly, so please check it each time you submit or provide us any personal information.