1 2 3 Finance Group

I hereby CONSENT to and allow 123 FINANCE CORPORATION or any of its Subsidiaries, Affiliates, Partners and accredited Third Party Service Providers to collect, retrieve, process, use and store my personal data such as my name, age, photographs, fingerprints, 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 my loan application. I fully understand and agree that my personal data will be processed for credit investigation, credit scoring, data analytics, collection, automated processing of the loan, data profiling, direct marketing of products and services of 123 FINANCE CORPORATION or any of its Subsidiaries, Affiliates, and Partners.

DATA PRIVACY STATEMENT

1 2 3 Finance Corporation (doing business under the name and style of 123 Finance Group) is committed to safeguard the personal and account information of our LOAN clients. In this regard, please be apprised of the regulatory requirements on data privacy and security. Republic Act No. 10173 known as the Data Privacy Act (DPA) of 2012, issued by the National Privacy Commission (NPC) in August 2012, provides the guidelines on the implementation of this law. Please be informed that 1 2 3 Finance Corporation shall continue to process the personal, sensitive, and privileged information (collectively known as Personal Data) of its LOAN clients (who are regarded as the Data Subjects), in the course of its servicing of the clients’ account/s with 1 2 3 Finance Corporation in accordance with applicable laws and regulations. This Privacy Statement hereafter referred to as “Statement”, explains how we collect, protect, use, and share your information when you access our websites and/or avail of our products and services. This Statement outlines the general practices of 1 2 3 Finance Corporation in relation to our processes and content which are made available through our website and social media page. This Statement also covers the privacy practices for our customers who apply and obtain loan products that 1 2 3 Finance Corporation may offer from time to time. It is, however, the policy of 1 2 3 Finance Corporation to respect and uphold data privacy rights, and to ensure that all personal data collected from clients and employees are processed pursuant to the general principles of transparency, legitimate purpose, and proportionality as stated in DPA.

OUR PRIVACY PRACTICES

The privacy practices described in this Statement are primarily intended for individuals in the Philippines and are designed to comply with the Data Privacy Act of 2012 (R.A. 10173) and its implementing rules and regulations. When accessing our website and/or availing of our services from outside the Philippines, you acknowledge and agree that your information may be transferred to and processed in the Philippines following legal and regulatory standards for data protection that may differ from your current or home jurisdictions. It is the policy of 1 2 3 Finance Corporation to respect and uphold data privacy rights, and to ensure that all personal data collected from clients and employees are processed pursuant to the general principles of transparency, legitimate purpose, and proportionality as stated in the Data Privacy Act of 2012. The following information are necessary for our LOAN clients to know and understand:

Types of information

• Personal information – any information, whether recorded in a material form or not, that will directly ascertain the identity of an individual. This includes your address and contact information.

• Sensitive personal information - personal information that includes
  • About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations;
  • About an individual’s health, education, the 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 Congress to be kept classified.
• Privileged Information - any and all forms of information which, under the Rules of Court and other pertinent laws, constitute privileged communication, such as, but not limited to, information which a person authorized to practice medicine, surgery or obstetrics may have acquired in attending to a patient in a professional capacity.

Information We Will Collect From You

When you apply for or avail of any product or service, we collect your personal information so that we may provide valuable and useful services that we believe you might find interesting and beneficial. Personal information is any data that can be used to identify a person. This may include, among others:

• Your name and personal particulars such as contact details, address, birth date, education;
• Specimen signatures;
• Government ID details;
• Your name and personal particulars such as contact details, address, birth date, education;investments, tax, insurance, financial and transaction history, income, etc);
• Employment details;
• Business interests and assets;
• Images via CCTV and other similar recording devices and processes which may be observed when visiting our offices and/or using our other facilities;
• Voice recordings of our conversations with you

We may, as and when necessary, seek to verify or augment this information with third-party entities, including government regulators, judicial, supervisory bodies, tax authorities, or courts of competent jurisdiction, and, in the process, gain additional information about you.

When you access our website, we may provide information about us as well as information regarding our products and services.

We may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives, agents, and service providers.

How We Use You Information

We use the information collected to deliver and provide the products and services that you are to avail:

• Process applications and transactions for loans;
• Respond to queries, requests, and complaints and to improve how we interact with you;
• Send you statements, billings, notices, and other such documents necessary for continued use of our products and services;
• Conduct studies and researches to develop new or improve our existing products and services;
• Perform profile analysis, modeling, and analytics to better understand needs, preferences, and market trends for the development of more suitable products and services;
• To reach out to you regarding products and services information, including offers, promotions, discounts, rewards; and to know your experience with us thru our various touchpoints such as branches, call center, telemarketing, email, messaging, and other channels;
• Determine the effectiveness and sufficiency of our marketing efforts and initiatives;
• Provide location-based services such as finding the nearest branch to you, as well as reaching out our other services to you;
• Perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;
• Comply with our operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, the Securities and Exchange Commission rules and regulations, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as to the same may be amended or supplemental from time to time
• To comply with applicable laws of the Philippines and those of other jurisdictions including the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (AntiMoney Laundering Act of 2001, as amended (AMLA) and the implementation of know your customer and sanction screening checks;
• Comply with legal and regulatory requirements such as submission of data to credit bureaus, credit information companies, the Credit Information Corporation (CIC) (pursuant to RA No. 9510 and its implementing rules and regulations) responding to court orders and other instructions and requests from any local or foreign authorities including regulatory, governmental, tax and law enforcement authorities or other similar authorities;
• Perform other such activities permitted by law or with your consent.

How We May Share Your Information

We may share your personal information with our subsidiaries, affiliates, and third parties, under an obligation of confidentiality.

• We may share personal information with various units within 1 2 3 Finance Corporation to better understand the way you use our products and services. This will allow us to improve our services and offer you opportunities to obtain such other useful products and services that may deliver greater value to you.
• We may share your information with our subsidiaries and affiliates to likewise offer you additional products and services that we believe you might find interesting.
• We may share with third parties that we engaged to support us in delivering our services to you.
• These may involve anonymous or aggregated information to help improve our products, services, and content.
  • We may also engage third parties to help us operate our business. These include support in:
  • Complying with legal requirements such as court orders;
  • Enforcing our terms of use including, among others, our rights as a creditor to customers availing of our loan products, or such other applicable policies with respect to the services that we provide;
  • Addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property, or security of our customers or third parties;
  • To carry out all other purposes set out above.

All our engagements with third parties shall be fully compliant with our obligation of confidentiality imposed on us under the applicable agreements and/or terms and conditions or any applicable laws that govern our relationship with you.

How We Protect Your Information

We fully recognize the value of your personal information particularly as it may include sensitive personal information such as your age, governmentissued IDs, etc. Appropriately, we strive to maintain the confidentiality, integrity, and availability of your personal information by employing physical, technological, and organizational safeguards. We train our employees to properly handle your information. Whenever we engage other companies to provide services to us, we require them to protect personal information aligned with our security standards.

Do we use 'cookies?'?

We do not use cookies for tracking purposes. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since every browser application is different from one another, kindly use your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your site experience more efficient may not function properly that make your site experience more efficient and may not function properly.

How Long Do We Keep Your Information

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time remains in effect until it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes.

OUR ROLE

We commit to use your personal information in the course of our financing relationship with you.

We shall use your information to determine what products and services we can provide you. Use of your information shall also be to comply with the legal and regulatory requirements of authorities such as the Securities and Exchange Commission (SEC), Credit Information Corporation (CIC) , and our obligation to third parties. Non-identifiable data collected from our website visitors shall only be for tracking and servicing the users’ concerns if any. We may also collect, process, store, and exchange your personal data in accordance with applicable laws and/or as per your agreement with us.

We ensure that your information with us is kept confidential.

We shall safe keep and use your information confidential within the bounds of applicable Philippine laws (e.g. Data Privacy Act of 2012; Credit Information System Act (R.A. No. 9510); Republic Act No. 9160, as amended, otherwise known as the Anti-Money Laundering Act; etc.). We shall provide only the needed information to government agencies, like the Bureau of Internal Revenue (BIR), and third parties when allowed by law and/or per your agreement with us.

We commit that the management of your personal information adheres to established security standards and procedures.
Our improved technology and information security framework shall prevent unauthorized access to your information which undergoes continuous assessment to improve securing your privacy.

YOUR RIGHTS

As provided under the DPA, you have the following rights in connection with the processing of your personal data: the right to be informed, right to object, right to access, right to rectification, right to erasure or blocking, and right to damages.

In respecting your privacy rights, you may opt to tell us:

1. Not to send you marketing materials via email;
2. Not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the services that you have availed with us;
3. To provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the Philippines by certain laws and regulations;
4. To update your information;
5. About your other concerns relating to how we collect, use, share, protect, or dispose of your information.

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you before making the request.

YOUR ROLE

Protect your personal information.
We entice you to be extra cautious in protecting your personal data by ensuring that your name, address, Identification Card Details (ID), and other important contact information are not disclosed to other people, nor written where it will be easily accessible to others.

Report any data breach.
If you think that your personal data was improperly handled in terms of confidentiality or integrity, or if someone tampered with your personal data without your consent, please contact us immediately thru our Data Protection Office, with contact details below:

Use secure means to contact us.
For any queries, clarifications, or requests on any aspect of this Statement, the exercise of your rights pertaining to your personal information, or to provide any feedback that you may have about our processing of personal information, please visit any of our branches or send us an email at privacyconcern@123finance.ph.

You may also write our Data Protection Officer at:

CHANGES TO OUR PRIVACY STATEMENT

We may modify or amend this or amend this Privacy Statement from time to time to keep up with any changes in relevant laws and regulations applicable to us or how we collect, use, protect, store, share or dispose of your personal information. Any relevant updates will be posted on the Company’s website.