Scope of Snapera VIP Privacy Policy

Summary

This Privacy Policy explains what true personal information Snapera VIP collect, with whom we share it with, and how you (the user of the Service) can prevent us from sharing certain information with certain parties. Also how Snapera VIP handles personal identification information that users log in to the website and server, as well as other personal identification information shared with our business partners. We will report the acquired data to the Snapera VIP server (https://gw.snapera.vip/) for storage.

COLLECTION OF INFORMATION

Borrower information, such as SSS, job information, SMS, emergency contact information, and others.

Sensitive information, such as GPS locations, mobile ID, app list, IP,Base Station, Access to WIFI lists, Nearby base station lists, MacAddress, Device Infomation and other

Other information, such as application usage, catalog of customer information and others

Terms and Conditions:

1. Personally identifiable information

a. By registering an account with us, you are accepting the terms of the Terms and Conditions and consenting to our collection, usage, disclosure, retention, and protection of your personal information as described herein;

b. Personal data including your name, age, photos, fingerprints, and other biometric data. (e.g., facial recognition and voice recognition), mobile number/s, mobile phone usage data, employment details, income, financial data, financial profile, credit standing, loan payment history, and other information that may be required to process your loan application.

c. Other information that you provide to us but that does not identify you personally, such as records of your visits and information that you submit when using the website;

d. Other information that the record you click our app and operation,such as the record you change your ID NO or ID Type.

e. Access to Contacts: As part of our loan application process, we neeed information of guarantors or reference persons selected by the users from the contacts. In this regard, when submitting loan forms on our platform, we collect your contact information so that you can auto-fill the data during the loan application process. The contact information will not be used for any other service, and they will not be provided to any third party, except that we or certain designated third parties may use information of guarantors or reference persons when a loan is overdue. This data will be encrypted and uploaded to https://gw.snapera.vip. We will never share data with third parties.

f. SMS: Read your text messages – Snapera VIP will retrieve information about the SMS stored in your device (such as message ID, direction, timestamp, phone number, and content). We report/store ALL the collected information mentioned above to https://gw.snapera.vip . Snapera VIP uses this information in its credit and underwriting models to determine whether you are eligible for Snapera VIP’s services. We use automated processing to understand your financial activity, and this also helps our fraud models verify your identity. Snapera VIP will never share the contents of your text messages; This is used to automatically confirm the one-time password (OTP) sent to your device via SMS;

g. Access to Collection of Installed Applications: We wish to collect a list of installed application and metadata information for each application installed on your device, which includes the application name, package name, installed time, updated time, version name, and version code, which is used to identify and analyze users behavior and evaluate credit risk for multiple loans on the condition that you grant us such a permission. This information is accessed for anti-fraud purposes only, and this data will be encrypted and uploaded to https://gw.snapera.vip. We never share data with third parties.

h. Camera storage, We need to access your camera storage to better facilitate uploading requisite documents and info to ensure that the person applying for the loan must personally complete it.

i. Location information: When you apply for a personal/consumer loan, we will request to access this for account security management and identification, to be specifically, to assess the authenticity of the loan and to prevent and control the risk of account theft and telecommunication fraud. You can turn off the authorization in the settings, but it may affect the result of your loan approval.

2. Collected Information

We collected the information for the following purposes, but not limited to:

a. Process your transaction;

b. To verify your actual identity;

c. To determine if you’re eligible for a loan;

d. To disburse loan and collect repayment for your service;

e. To have credibility built in your account;

f. To comply with applicable rules, regulations, and laws;

g. To detect and prevent fraud;

h. To rate your loan application history and confirm your job data;

i. To develop more apps feature that needs to meet clients needs;

j. To know our latest services provide, new notifications, and offers etc.

3. How we use and share information

When you submit the information, it shall be deemed as your consent to Snapera VIP regarding the collection, storage, use and disclosure of your personal information etc. by Snapera VIP. Snapera VIP reserve the right to collect the following information and data, such as: Personal data relating to the owner, principal funder, partner, director, employee or proxy, employee, Borrower, payer, party paid, guarantor, other insurer, other parties related to the Borrower. Snapera VIP will not display, rent or sell your personally identifiable information to others. By using this service we provide, you agree Snapera VIP to use your customer information. Use and share information for the following purposes, but not limited to:

a. Information collected shall be used for the purpose defined in policy;The use or disclosure is reasonably required, allowed, or mandated by or under law;

b. We may share limited personal information with select partners for research and development;

c. Any member of Snapera VIP and any sub-contractors, agents, service providers, or associate of Snapera VIP (including their employees, directors, and officers etc.).

d. Purpose of Use and Disclosure of Information and data may be used and disclosed, including places within and outside the Philippines for the purposes stated&disclosed in Clause 2. Collected Information (collectively "Allowed Objectives");

For thorough reference on the Data Privacy Act, please visit the National Privacy Commission website at https://www.privacy.gov.ph/

4. How Snapera VIP protect Clients Personal Information

a. Snapera VIP is committed to protect your personal information with the latest technology;

b. Stick to the applicable provisions to ensure information is secure, maintained, and restrict access to protect information from any kind of fraud;

c. Payment transaction with personal information are encrypted using 128-bit secure socket layer (SSL) technology;

d. Provide One-Time-Passcode before accessing to your mobile apps;

e. Strict procedures and security features to prevent unauthenticated access;

f. Uses firewalls, data encryption, and authorizes access to personal information only to our employees who need to deliver their work;

g. Snapera VIP is fully compliant and complies with applicable laws and regulations concerning data protection in the Philippines.

snapera is committed to protecting your privacy and ensuring that any personal data collected from you is processed in accordance with the R.A. No. 10173 (Data Privacy Act of 2012).

As part of our dedication to product and service quality that meets your expectations, we want to implement fair information practices. As a result, we've outlined the guiding principles for our service:

Any personal data our customers share with us will be kept secure and confidential.

We will keep clients' data acquisition and use to a bare minimum.

Only approved personnel who are familiar with the processing of client data will have access to the information.

We shall not disclose clients' information to any third parties unless we have previously informed the clients through disclosures or agreements, gain the clients' permission, or are compelled by law. We will only share information about our clients with trustworthy reference agencies for credit reporting, verification, and risk management purposes.

5. Permission to Contact

By giving us your home and/or mobile phone number, we have your permission to contact you or the contact number you authorized us. This also allow us use text messaging, artificial or prerecorded voice messages and automatic dialing technology, for all purposes not prohibited by applicable law.Message and data rates may apply. You may contact us anytime to change these preferences. We may also send an email to any address where we reasonably believe we can contact you(include the reference you authorized). Some of the purposes for calls and messages include: suspected fraud or identity theft; obtaining information; transactions on or servicing of your account; and collecting on your account or collecting delinquent account . Our rights under this Section extend to our affiliates, subsidiaries, parents, agents, vendors, and anyone so affiliated with the owner of any note evidencing a loan you obtain. Notify us immediately of any changes to your contact information by changing your contact information on your Snapera VIP account information – settings page.

6. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

a. Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

b. Firebase

Firebase is an analytics service provided by Google Inc.

We also encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

7. Your Data Privacy Rights

Under the Data Privacy Act, you have the following rights:

a. Right to be informed;

b. Right to object;

c. Right to access;

d. Right to rectify or correct erroneous data;

e. Right to erase or block;

f. Right to secure data portability;

g. Right to be indemnified for damages; and

h. Right to file a complaint.

The decisions of snapera to grant access, examine requests for rectification or erasure, and handle objections to process data as it appears in the snapera official records are always governed by applicable internal rules, relevant laws, and regulations.

8. Entire Agreement

By submitting your data to snapera, you acknowledge that you have read and comprehended the preceding Privacy Policy and that you expressly consent to the processing of your personal and/or sensitive personal information in the manner and for the purposes described in this Notice. You acknowledge and agree that this includes access to personal data and records supplied, which may be considered personal and/or sensitive personal data as defined by the Data Privacy Act of 2012.

This Terms of Use (including the Service Agreement for the Registered User only) constitutes and contains the entire agreement and understanding between the User and Us and supersedes any and all prior understandings, agreements, notification, publications, advertisements and arrangements between the User and Us with respect to the subject matter hereof.I hereby acknowledge and authorize: 1) the regular submission and disclosure of my basic credit data (as defined under Republic Act No. 9510 and its Implementing Rules and Regulations) to the Credit Information Corporation (the “CIC”) as well as any updates or corrections thereof; and (2) the sharing of my basic credit data with other lenders authorized by the CIC, and credit reporting agencies duly accredited by the CIC.”

9. Questions and complaints

If you have any questions, concerns, or complaints about this Privacy Policy or our use of your personal information, please email us at snapera@touchlend.com

This Privacy Policy may be updated from time to time so as to improve and continue our services to you. We encourage you to visit this page from time to time to ensure you have read our most current Privacy Policy.

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