Privacy Policy

This website introduces the App. It does not take loan applications and does not ask you to submit personal data through a form. The practices below describe how information will be handled once the App is released and you choose to register or apply. If you only read this website, we do not collect an application file from you.

By downloading, registering, or using the App after it is released, you acknowledge this Policy. If you do not agree with it, do not register or apply.

1. Philippine data privacy law

We process personal data fairly, for a stated purpose, and only to the extent needed for that purpose. Those are the principles of transparency, legitimate purpose, and proportionality under the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

2. Data Protection Officer

A Data Protection Officer will oversee compliance with the Data Privacy Act for Tiwala Loan. The officer’s name and contact details will be published on this page and inside the App before the App is released to the public. Until that channel is published, this website is not a place to submit personal information.

3. Information we collect

When the App is available, we may collect the categories below. We do not collect them on this website today.

3.1 Information you provide

• Full name, date of birth, gender, civil status, and nationality
• Government-issued identification, such as SSS, GSIS, PhilHealth, passport, driver’s license, UMID, or voter’s ID
• Present and permanent address
• Mobile number and email address
• Work details you choose to give, such as employer, role, income, and length of employment
• Bank account or e-wallet details for a disbursement or repayment, if a loan is offered and accepted
• Application details, such as the purpose of the request, the amount you ask for, and the term you prefer

3.2 Information collected from the device

• Device model, operating system, and device identifiers such as an Android ID
• IP address, mobile network information, and location information if you allow it
• App usage and interaction logs
• SMS data only if you grant that permission, as described in Section 4

3.3 Information from other organizations

• Credit reports, including reports from the Credit Information Corporation (CIC), where the law allows or requires it
• Results from identity-verification providers
• Information from payment partners needed to move funds or record a payment

4. Permissions on your phone

Each permission is requested on its own, with a short explanation. You can refuse a permission or turn it off later in your device settings. Refusing a permission may limit identity checks, risk review, or account security, and may mean an application cannot be completed.

4.1 SMS

The mobile number you give us is used to send service messages that are not advertising. Those messages can include one-time passwords, security alerts, application updates, disbursement or payment notices, repayment reminders, and customer-service information.

If you give a separate, explicit permission, the App may read SMS from a recent period, limited to what is needed to review an application, check identity, assess repayment capacity, detect fraud, and protect the account. That read may include the sender name or number, message content, time, and messages tied to income, bills, repayments, or account security. We do not use SMS for advertising, we do not sell it, and we do not give it to an unrelated third party unless you consent or the law allows it.

SMS data, when collected, is sent over an encrypted connection to the Company’s servers and is used only for the purposes in this section. You can withdraw the permission in your device settings. A verified request to delete personal data will be handled within 3 to 5 business days after we can confirm it, unless a law, an open loan record, a dispute, an audit, or a regulator requires us to keep it.

4.2 Camera

The camera is used only when you start an identity check. It may be used to photograph a government ID, take a selfie, or complete a face-liveness check, so we can see that the applicant matches the ID and can reduce fake or duplicate applications. The App does not run the camera in the background, does not record unrelated audio or video, and does not open your photo library, videos, or other files on the device. Images from this check are sent encrypted and are used for identity verification, application review, fraud prevention, account security, and legal compliance.

4.3 Location

The App is not designed to collect precise GPS tracks or to follow your location in the background. For service availability, account security, and unusual-application checks, we may use the address you type in, a coarse region taken from your IP address or network, or a non-precise region you allow the device to share. That information is not used for advertising or for continuous tracking. Turning the permission off may affect some security checks.

4.4 Installed applications

If you explicitly allow it, the App may read a list of applications installed on the device in order to look for signs of fraud, automation, cloned devices, emulators, multi-account tools, or other account risks. The list may include app name, package name, version, and install or update time, together with related device-risk signals. We do not read chats, files, photos, videos, or transaction content inside other apps. This check runs when you open the App, sign in, or submit an application. It is not used for advertising and it is not sold.

4.5 Emergency contacts

We may ask for up to two references: name, relationship, and phone number. You type and confirm what you send. We do not upload your full address book or contacts you did not choose to submit. You should have a proper basis for sharing another person’s details. Reference details are used for identity checks, application review, account security, fraud prevention, repayment reminders, or other contact the law allows. They are not used for advertising.

4.6 Device and technical data

To run the App and protect accounts, we may collect device model and brand, operating system, app and SDK version, language and region, network type, mobile carrier, IP address, crash logs, diagnostic logs, sign-in records, and security events. We do not collect IMEI, IMSI, or SIM serial numbers. This data is not sold and is not used for advertising unrelated to the lending service. Permissions are limited to the purposes in this Policy, and you may revoke them in device settings.

5. Why we process data

Each use has a basis under the Data Privacy Act, such as a contract, a legal duty, a legitimate interest, or your consent:

• To receive and assess a loan application, including credit evaluation
• To verify identity and reduce fraud
• To release funds and record repayment, if you accept a loan
• To answer questions and send service messages
• To meet reporting duties to regulators, including the Securities and Exchange Commission and, where applicable, the Bangko Sentral ng Pilipinas
• To maintain and improve the App
• To send marketing only where you have given a separate consent

6. When we share data

We do not sell personal information. We may share it with:

• Credit bureaus and the Credit Information Corporation, where the law requires or allows a report
• Providers who host systems, move payments, check identity, or send SMS, under instructions from the Company
• Collection service providers, only under a written processing arrangement and in line with SEC Memorandum Circular No. 18, Series of 2019
• Regulators, courts, or law enforcement when the law, a court order, or legal process requires it
• A buyer or successor if the business is merged, sold, or reorganized, with the same privacy duties

Providers must handle the data in line with the Data Privacy Act and the written terms we set.

7. Collection conduct

Collection, if a loan becomes overdue, will follow SEC Memorandum Circular No. 18, Series of 2019 and Republic Act No. 11765, the Financial Products and Services Consumer Protection Act. We will not contact people in your phone’s contact list to collect a debt. We will not send threatening, harassing, or abusive messages. We will not publish your debt or personal data to shame you. Collection contact will come from identified staff. You may complain to the SEC about abusive collection.

8. How long we keep data

• Records of a loan that was granted: for the life of the loan and up to five (5) years after it is fully paid
• Applications that are not approved: up to two (2) years
• Identity records: for the period required by know-your-customer and anti-money-laundering rules
• Marketing records: until you withdraw consent

After the applicable period, data is deleted or anonymized, unless the law requires a longer hold.

9. Security

The Company will protect personal data with measures appropriate to a lending app, including encryption while data is moving between the App and our servers, limits on which staff can view records, and a process for security incidents. If a breach is likely to affect your rights, we will notify the National Privacy Commission within 72 hours of becoming aware of it, and we will notify affected people without undue delay, as the Data Privacy Act requires.

10. Your rights

Under the Data Privacy Act you may:

• Be informed of how your data is collected and used
• Access personal data we hold about you
• Correct data that is inaccurate or incomplete
• Ask for erasure or blocking where the conditions in the law are met
• Object to processing based on legitimate interest, including direct marketing
• Receive certain data in a portable format where the law provides that right
• Complain to the National Privacy Commission

If an application is decided with an automated score, you may ask for a person to review that result. Send rights requests to the Data Protection Officer once the contact details are published. We will answer within fifteen (15) business days.

11. Cookies and analytics

This website does not set advertising cookies and does not use a sign-in. The App does not use browser cookies. After release, the App may use an analytics tool to understand performance. That tool should receive usage data that does not identify you by name. You can limit advertising identifiers in your device settings.

12. Minors

Tiwala Loan is not for anyone under 18. We do not knowingly collect personal data from children. If you believe a minor has sent us personal data, contact the Data Protection Officer once the contact channel is published and we will delete it, unless the law requires us to keep it. Eligibility to apply is stricter and is set out in the Terms & Conditions.

13. Changes

We may update this Policy when our practices or the law changes. If a change is material, we will post it here and, once the App is live, notify users in the App or by email at least seven (7) days before it takes effect. Continuing to use the App after that date means you accept the updated Policy.

14. Contact

Questions about this Policy can be sent to the Data Protection Officer. The name, email, phone number, and office address will be added to this page before Tiwala Loan is released. Please do not send identity documents or application data to this website in the meantime.

Company: TIWALA LENDING INVESTOR, INC.
App: Tiwala Loan
Related document: Terms & Conditions

Last updated: October 22, 2026.