Privacy Policy

Version: 1.0
Date: Feb 27, 2024
PayJoy Philippines Finance Inc.

The privacy of individuals, including our customers and clients, is of utmost importance to PayJoy Philippines Finance Inc. (hereinafter the “Company” or “PayJoy PH”). At PayJoy PH, we are committed to complying with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, that governs the processing and protection of personal data.

This serves as PayJoy PH’s statement on its data processing activities. It is essential to clarify that this is not a consent form; rather it is an announcement detailing how PayJoy PH handles personal data.

Purpose

Aligned with the principles of transparency, legitimate purpose, and proportionality, and in acknowledgment of the data subject’s right to be informed, this Privacy Notice (“the Notice”) furnishes you, the data subject, with clear, sufficient, transparent, and easily accessible information about the collection and processing of personal data, either yours or that of the person you represent through products or services contracted from PayJoy PH.

This Notice is intended to establish in clear terms the types of information collected, the reason for such collection, the source of the information, the entities with which said information may be shared, the rights of the data subject, as well as the practices and processes adopted by the Company for the appropriate management of this information.

Please read this Notice carefully as you continue to browse the website, use, or avail any of our products or services (the “Services”), or if you provide any personal data to the Company through your use of the website or any Service. We assume that such information is provided voluntarily, and everything in this Notice is based on that assumption.

Policy to Protect and Respect Personal Data

PayJoy PH is unwavering in its commitment to protecting and respecting the privacy of personal data. We have instituted measures compliant with the requirements of the Data Privacy Act of 2012, its implementing rules and regulations, and other issuances of the National Privacy Commission.

Definitions

The following terms shall have the respective meaning whenever they are used in this Notice:

Consent – refers to any freely given, specific, informed indication of will, whereby the Data Subject agrees to the collection and Processing of his or her Personal Information, Sensitive Personal Information, or privileged information. Consent shall be evidenced by written, electronic or recorded means. It may also be given on behalf of a Data Subject by a lawful representative or an agent specifically authorized by the Data Subject to do so;
Data Sharing – refers to the disclosure or transfer to a third party of personal data under the custody of a Personal Information Controller or Personal Information Processor. In the case of the latter, such disclosure or transfer must have been upon the instructions of the Personal Information controller concerned. The term excludes outsourcing, or the disclosure or transfer of personal data by a Personal Information Controller to a Personal Information Processor;
DPA – refers to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012;
Data Subject – refers to an individual whose Personal Information, Sensitive Personal Information, or privileged information is processed;
IRR – refers to the implementing rules and regulations of the DPA;
NPC – refers to the National Privacy Commission;
Personal Data – refers to either of the following:
- Personal Information – refers to any information, whether recorded in material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual; or
- Sensitive Personal Information – refers to Personal Information:
  - About an individual’s race, ethnic origin, marital status, age, color and religious, philosophical or political affiliations;
  - About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
  - Issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
  - Specifically established by an executive order or an act of the Philippines Congress to be kept classified.
- Personal Information Controller or PIC – refers to a natural or juridical person, or any other body who controls the processing of Personal Data, or instructs another to process Personal Data on its behalf;
- Personal information processor or PIP – refers to any natural or juridical person or any other body to whom a PIC may outsource or instruct the processing of Personal Data pertaining to a Data Subject.

I. Acts of Processing

The Company processes Personal Data to provide its Services, including Know-Your-Customer procedures, assessing borrowers’ creditworthiness, and facilitating the loan application process. This includes administering credit, processing transactions, and enforcing debtor obligations. Processing of Personal Data serves the purpose of meeting legal obligations, such as customer due diligence, maintaining transaction records, reporting transactions, and credit reporting. Additionally, it aids in the collection of payments, processing queries, and addressing future loan or credit product applications.

II. Personal Data Collected

We collect the Personal Data from you when you manually or electronically submit the following:

Identification data: full name, address, proof of residence, email address, phone number, age, birth date, face/photo (including selfies), fingerprints, and handwriting;
Credit reports, watchlists & validation services: requested copies of your credit history which may contain professional and financial information about you. We check for your information in public watchlists such as Office of Foreign Assets Control (OFAC) lists. We use validation services to ensure the validity and quality of identification data we receive;
Social Media Data: data provided in your social media accounts, including photo, friends list and name;
Telecommunications data: data provided and shared by your telecommunications provider to us or to our service providers, such as credit bureaus;
Copies of Documents: collected documentation, including government IDs, data privacy authorization, credit history authorization, and contract signed;
Payment Information: information about how you pay your obligation to PayJoy PH; and
Customer Service: information you provide to us in connection with the Services, including when you communicate with us, by any means, for customer service purposes.

III. Storage and Retention

PayJoy PH prioritizes responsible data management, and our commitment to safeguarding Personal Information extends to the principle that Personal Data will not be retained beyond what is necessary to:

Fulfilling the declared, specified, and legitimate purpose, or upon termination of processing relevant to the intended purpose (as defined in this Notice);
Supporting the establishment, exercise, or defense of legal claims;
Fulfilling obligations of a financing company under relevant laws and regulations, including but not limited to anti-money laundering and tax laws; or
Serving legitimate business purposes, consistent with industry standards or those approved by the appropriate government agency.

Personal Data shall be disposed or discarded in a secure manner that prevents further processing, unauthorized access, or disclosure to any other party or the public. This disposal process is designed to safeguard against any prejudice to the interests of the Data Subjects.

IV. Use

The Company engages in the collection, use, processing, storage, disclosure, transfer or handling of Personal Data for the following purposes:

Contracting PayJoy PH Services. When you interact with PayJoy PH, we process your information to authenticate your identity, assess repayment risk, provide requested services and products, report information changes, evaluate service quality, comply with contractual obligations, adhere to regulatory requirements from competent authorities, and fulfill client requests.
Fraud Prevention. We process and store some of your information for fraud prevention, enhancing security for PayJoy PH, you as the user, and the financial system in general.
Communication. Your information is necessary for us to contact you through various channels, including electronic methods, mail, or telephone (SMS and others). This communication is related to the onboarding process and throughout the provision of Services. It includes notifications of changes in the platform or Services, as well as providing information on products or services that may interest you such as payments reminders, offers, update in our Terms and Conditions, Privacy Policy or contract changes.
Payment Obligations. Your information is processed to manage payment obligations for payment collection purposes.
Data Analytics and Research. We process your information for data analytics, research, and statistics. This helps PayJoy PH assess and study the profile of our service users, contributing to the development of better products, offers, and services.
Other Business Activities. Information processing is also conducted in connection with other business activities of the Company.
Legal Compliance. PayJoy PH may be required to collect, process, and disclose your Personal Data to government authorities, such as the Anti-Money Laundering Council and the Credit Information Corporation, to comply with its reporting obligations under existing laws.
Storing data in company databases: Storing your Personal Data in company databases for various operational purposes.
Authenticating and updating user information: Authenticating, verifying, validating, confirming, and updating your information and identity.
Sharing information: Capturing, enrolling, verifying, and sharing financial, commercial, credit, telecommunications, and biometric information with third parties for verification, analysis, and risk management services, including reports on credit behavior or credit scoring, compliance with obligations to financial databases, data analytics and scorecard development.
Developing new products: Conducting simulations and analysis for developing new products to make offers to you.
Billing: Performing billing activities related to credit products granted by PayJoy PH.
Managing collection of financial obligations: Managing judicial or extrajudicial collection of financial obligations arising from your status as a client of PayJoy PH.
Sending documents related to products: Sending documents related to products provided by PayJoy PH, such as statements, collection communications, electronic invoices, or equivalent documents, through various communication channels.
Transferring data to third parties: Transferring Personal Data to allied third parties that can provide information and benefits of interest to your, related to similar or complementary products to those of PayJoy PH.
Transmitting data for audit processes: Transmitting your information and Personal Data to third parties for internal and/or external audit processes.
Transmitting Data Internationally: Transmitting and transferring your Personal Data internationally for cloud computing and big data processes.
Collecting information about mobile devices: Including but not limited to information related to the device, operating system, device identifier, SIM information, IMEI, internet connection status, etc.
Transaction information: if the device is purchased, rented, or leased through PayJoy PH, the Company will collect information related to that transaction, such as the store where it occurred, the transaction amount, the clerk (salesperson) who made the sale, and any information associated with the operation.
Sending offers and promotions: Sending relevant offers, promotions, and advertising of PayJoy PH or third-party products.

V. Manner of Collection

The Company may collect Personal Data from a variety of sources, including:

Directly collected from you. PayJoy PH directly collects information from you and through your use of our Services.
Indirectly collected from you. Where permitted by law, PayJoy PH may collect information about you from third parties such as credit reporting agencies and telecommunications providers.
Mobile device. PayJoy PH collects information from your mobile device operating system, device identifier, SIM information, IMEI, internet connection status, etc., via the PayJoy mobile application installed on your phone. You may check the information collected by PayJoy’s app in the privacy section of your mobile device.
Website. When you visit the website, information may be automatically collected through cookies or similar technology.

Cookies

A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store specific information about a client or website and are designed to create a record or “remember” online activity.

PayJoy PH or a third party may collect cookies, web beacons, small data text files, or similar technologies primarily to ensure that the core functions of our website are optimally accessible to your use of our website. We or a third party may also use cookies to provide analytics, store your preferences, and allow advertisements delivery, including behavioral advertising.

If you like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the Help pages of your web browser. The Help pages of some common web browsers are linked below:

Please note that if you delete cookies or refuse to accept them, you might not be able to use all of the features our website offers, you may not be able to store your preferences, and some of our pages might not display properly.

PayJoy PH uses Personal Data proportionately as necessary for its legitimate purposes. All Personal Data we collect is kept private and confidential by PayJoy PH, utilized solely for legal purposes as mandated by the DPA, its IRRs, other issuances of the NPC, and relevant laws and regulations.

VI. Sharing and Transfer of Personal Data

The Company adheres to the principles for Data Sharing. PayJoy PH may disclose and share your Personal Data based on your Consent, legitimate business interest, and other lawful processing, to governmental agencies, courts, or regulators. This may also include sharing with agents, contractors, service providers, or other third parties involved in the Company’s business and the provision of Services, as well as any with other individual bound by a duty of confidentiality to the Company.

VII. International Transfers

Transmitting data internationally: PayJoy PH may transfer your Personal Data to recipients in countries other than the one in which the information was originally collected, and to third parties providing services essential for the Company’s proper operation, including its affiliates, subsidiaries, controllers, and processors within the same group or associated entities. These countries or third parties may not have the same data protection laws as the country where you initially provided the information. When transferring your information to recipients in other countries or third parties, we commit to conducting these transfers in accordance with the requirements of the DPA, its IRRs, and other relevant laws and regulations.

VIII. Rights of a Data Subject

Data Subjects possess the right to access and understand the Personal Data held about them, along with the reasons and methods of its processing. The DPA delineates specific rights concerning the processing of Personal Data, encompassing:

Access: You are entitled to request reasonable access to your Personal Data. This allows you to verify whether data related to you is currently being processed. You are entitled to information such as the contents of your processed Personal Information, sources from which the information was obtained, names and addresses of recipients of the Personal Information, the manner in which the data were processed, reasons for disclosing the Personal Information to recipients, details on automated processes that may significantly impact decisions about you, the date when your Personal Information was last accessed and modified, and the designation, name, identity, and address of the PIC.
Rectification: The right to rectify Personal Data is at your disposal. You can request corrections if your Personal Data is found to be inaccurate or incomplete.
Erasure or Blocking: When warranted, you can request the erasure or blocking of your Personal Data, except when laws allow us to retain your Personal Data for certain periods, or when you have an existing transaction with PayJoy PH. As the Data Subject, you hold the right to suspend, withdraw, or instruct the blocking, removal, or destruction of your personal data from the filing system of the PIC. This right may be exercised upon discovery and substantial proof that the Personal Data is incomplete, outdated, false, unlawfully obtained, is being used for a purpose not authorized or no longer necessary for the purposes for which they were collected. Moreover, you retain the option to withdraw your Consent or object to the processing of your Personal Data, provided there is no other legal ground or overriding legitimate interest supporting the processing. The erasure or blocking of Personal Data is also admissible when said data pertains to private information that could be prejudicial you as the Data Subject, unless justified by freedom of speech, expression, or the press, or otherwise authorized. Ultimately, you maintain the right to request the erasure or blocking of Personal Data if the processing thereof is deemed unlawful or if the PIC or PIP has violated your rights as a Data Subject.
Objection: You hold the right to object if the processing of your Personal Data is based on Consent or legitimate interest, but please note that you may not be able to access some of PayJoy PH’s Services if you will not allow us to process your Personal Data.
Data Portability: The right to data portability empowers you to obtain, securely move, copy, or transfer your data for further use.
To File a Complaint: If you suspect a violation of your rights or the DPA, you have the right to file a complaint with NPC.
To Damages: If you believe you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of Personal Data, or if your rights and freedoms as a Data Subject were violated, you have the right to be indemnified.

IX. Security Measures

The Company has implemented reasonable security practices and procedures that conform to internationally accepted standards for the security and protection of information. These practices and procedures include directive, technical, operational, and physical security control measures commensurate with the nature of the information collected and processed by the Company.

X. Changes to the Privacy Notice

PayJoy PH reserves the right to update or revise this Notice as needed and commits to providing a new notice in the case of substantial changes. The Company holds the discretion to add, revise, amend, modify, or delete any part of this Notice, whether in part or in full. The updated Notice will be consistently posted on the Company’s website. You are responsible for regularly reviewing this Notice for any updates or changes.

Should you choose not to continue using the Services after such changes, you are required to apply for the cancellation of your account and/or termination of your legal relationship.

XI. Contact us

You have the right to ask for a copy of any Personal Data we hold about you and to seek corrections if necessary. For inquiries related to data privacy or feedback concerning this Notice, please reach out to us:

Data Protection Officer
PayJoy Philippines Finance Inc.
privacy.ph@payjoy.com
9th Floor Uptown Bonifacio Tower 3
36th St. corner 11th Avenue
Bonifacio Global City, Fort Bonifacio, Taguig City