I. Policy Statement
II. Personal Data Collected
We may collect the following information:
- Information to identify you (e.g. first name, surname, government issued ID, facial image, birthday, marital status, nationality, gender)
- Contact Information (e.g. mobile number, email, address, emergency contacts)
- Employment Information (e.g. Employer name and address, business contact number, job industry, job position, job employment date, and monthly income)
- Bank Information (e.g. Bank name, bank account number)
- Mobile Device Information (e.g. phone settings, phone device information, mobile device location, contact list, web history, device accounts, media information, calendar information, storage information, call log information)
- Web information (cookies, forms, location, IP address);
- Information gathered from communicating with us (e.g. chat conversations with Atome via in-app chat, emails, phone, or other available channels)
- Third Party Data (e.g. information provided by partners for identity and credit verification, external collections)
We may collect your information through:
- Registration to the mobile application;
- Applying a loan through our mobile application;
- Interaction from our verification, customer support and collection team, or other NCFI employees or agents;
- Website contact us page;
- Credit partner agencies which may have access to other databases, or fraud prevention agencies;
- Third party or other publicly available sources, with your consent, or other business partners which may help us to provide service to you.
III. Purposes of Collecting Personal Data
We collect your personal information because of the following:
- Assess your eligibility to provide you with our products and services (this may include assessing the appropriate credit amount that we can offer to you, and/or determining your eligibility to better service offered in our existing product);
- Verify your identity as part of our KYC process;
- Process your loan application (disbursing your loan to your bank account and repayment of your loan)
- Detect, prevent, and identify activities of fraud, money laundering, and/other illegal use of our service;
- Assist you with problems you may encounter in our products and services;
- Analyze user behavior in aid to improve our services;
- Comply with applicable laws, regulations, advisories, and other government issued rules;
- Contact you for marketing purposes or other promotional offers;
- Contact you reminding of your credit obligations, schedules, and other activities of our products and services;
- Conduct employee training;
We process your information based on the following grounds:
- Operate our business;
- To provide you with our financial products and services;
- Maintenance of our system and update of our records;
- To comply with our legal obligations;
- Your prior consent
IV. Automated Processing
Some of our processes may be decided and being processed without human intervention such as credit scoring, loan disbursement, and fraud detection.
- Credit Verification and Scoring
We are using an automated process for verification and scoring to decide if your information contains fraudulent information, and if your submitted application may be eligible to grant a loan amount or is competent to avail our services. This is our way to ensure that we provide you a faster processing of your loan application.
- Loan Disbursement
Disbursing your approved loan amount is easier by integrating our disbursement process to payment gateways available locally to provide our commitment of an accessible and convenient financing.
- Fraud Detection
Fraud detection is using an automated process in our system to identify, detect, and prevent fraud activities by our consumer. This process decides whether the behavior of an individual using the information provided leads to a money laundering activity or other fraudulent activity that will affect our products and service. This also flags an individual access to our application to be suspended or declined to avail of our services.
- Your rights in relation to automated processing
You may inquire at email@example.com for details if your access to our services has been affected by the enumerated automated processes.
V. Protection of Personal Data
NCFI is committed to uphold your rights as a data subject. We implement appropriate organizational, physical, and technical measures to manage all personal data fairly and lawfully to ensure confidentiality, integrity, and availability of your information to us.
VI. Storage and Retention of Personal Data
Our storage facility for our systems is located outside the Philippines and is protected with enough security and data protection standard to ensure that protecting your personal data complies with the applicable law and data protection requirements of the Philippines. Sharing of your information to any of the parties to whom we disclosed also provides safeguards to protect and process your information.
Your personal information will retain to our system as long as needed for the purposes that we have described under Purposes of Collecting Personal Data. We may also retain your information for us to comply with any legal obligation, for business purposes, and in some cases as authorized by law.
VII. Disclosure of Personal Data
NCFI may disclose your personal data to any third party if necessary and is appropriate for the fulfillment of providing our products and services. We may only share limited personal data depending on the engagement to the third party and if possible, will transfer your personal data in an anonymized format.
In addition, we may also provide your personal data for the fulfillment of Purposes of Collecting Personal Data to the following:
- Our affiliate entities or parent company;
- Our agents for verification, collection, and customer support team, and other employees, and contractors of NCFI;
- Third party service providers with contractual and fiduciary engagement with NCFI;
- Third party collection agencies;
- Third party financial institutions such as banks, collection agents, and credit agencies;
- Entities involved in any merger, acquisitions, or joint venture with us;
- Government agencies which may comply us for court orders, enforcement action, or any legal proceedings and obligations as required by applicable law;
VIII. Your Rights as a Data Subject
1. Right to be informed
2. Right to access
You as a data subject may request for a copy of the personal data that we hold, except in cases that may affect the rights and freedom of others especially with applicable laws which requires us not to comply with your request.
3. Right to rectification
In cases of inaccuracies to your personal data provided from us, you may ask us to correct any of your information. This may require supporting proof or documentation which will help us verify the accuracy of your request.
4. Right to remove
You as a data subject may request to erase your personal data if:
- Retaining your personal data to our possession is no longer necessary;
- Processing your personal data has no legitimate reason ;
- Your personal data is being used unlawfully;
- Applicable laws require us to erase your data;
5. Right to restrict processing
You as a data subject may request to stop using your personal data if:
- It is inaccurate;
- Your personal data is being used unlawfully;
- There is a legal proceeding that will restrict us to use your personal data;
- We do not have a legitimate reason to use your personal data;
6. Right to data portability
You may request to provide you with your personal data in a structured, commonly used and machine-readable format.
7. Right to object
You as a data subject have the right to object whenever we are using your personal data based on our legitimate interests
8. Right to file a complaint
You as a data subject have the right to file a complaint if you think there is any violation of your rights as a data subject with the National Privacy Commission and other government agencies that may be involved with your complaint.
As part of our commitment, you can send an email at firstname.lastname@example.org for your inquiries or complaint with regards to your data privacy.
By using our website, and/or mobile application, you:
- Certify that all information you have provided is true and correct to the best of your knowledge;
- Authorize NCFI to conduct verification of the accurateness of your provided information;
- Acknowledge that NCFI, as part of compliance to the applicable laws, may be required to disclose your information to relevant governmental councils, agencies, or any offices as required by law.