Privacy Policy

Introduction

This Privacy Policy governs your access to and use of the Fresh Loan application (“App”), which is made available to you by JUST SMILE LENDING CORPORATION (“we,” “our,” or “us”), and published under the account of The Mandala Lending Corp.

The Mandala Lending Corp. is a duly registered and licensed corporation under the laws of the Republic of the Philippines, with Registration Number CS202005567 and Certificate of Authority No. 3300, acting as the official publisher of the Fresh Loan application.

JUST SMILE LENDING CORPORATION is a duly registered and authorized lending company under Philippine laws, with Company Registration No. CS202011342 and Certificate of Authority No. 3379. It has granted authorization to The Mandala Lending Corp. to publish, distribute, and operate the Fresh Loan application, including user acquisition, customer support, and related services.

At Fresh Loan, we are committed to protecting your privacy and safeguarding your personal information. We ensure that all personal data entrusted to us is handled responsibly and in accordance with applicable laws and regulations of the Republic of the Philippines.

This Privacy Policy explains how we collect, use, disclose, and protect your information. By accessing or using the Fresh Loan application, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

A. Data Collection

We collect various types of information to provide and improve our services. The data we collect includes but is not limited to:

1. Personal Identification Information

• Full name
• Identification document type and number
• Date and place of birth
• Age, gender, and marital status
• Educational background
• Religious affiliation (if voluntarily provided)
• Residential address

2. Approximate Location Data

• We request access to your approximate location to provide location-based services, enhance security, and prevent fraudulent activities. Your approximate location data is handled confidentially and is not disclosed without your consent unless required by law.

3. Camera and Media Access

• We request access to your camera only for scanning and uploading required documents, such as identification cards or bank details, to facilitate the loan application process.

4. Device-Related Data

• Device name and model
• Language and regional settings
• Operating system details and browser version
• IP address
• Battery status

5. Calendar Access

Our application may request access to your device’s calendar to allow you to create or store loan-related schedule information for personal reference.

If you grant this permission, the app may add loan-related entries to your calendar. The application does not read, access, or collect your existing calendar events or personal schedule information.

Granting calendar permission is optional. You may decline or revoke this permission at any time through your device settings.

6. Financial and Employment Information

• Bank account and e-wallet details
• Employment information, including employer’s name and contact details
• Monthly income, income source, and payday schedule
• Outstanding loans and financial obligations

7. Contacts Permission

When using Private Access Mode, we only access the contacts you voluntarily select through the system-provided picker, strictly for identity verification and risk management purposes. We do not access, collect, or upload your full contact list.

8. Advertising ID

We collect the Advertising ID, a resettable and unique identifier generated by your device's operating system. This allows us to improve your experience, deliver personalized financial services, and safeguard your account security.

9. Biometric Data Collection & Usage

To enhance security and prevent fraud, we utilize facial recognition technology for identity verification. During the application process, you will be prompted to provide a live photo of your face. This biometric data serves the following purposes:

• Identity Verification: To confirm you are the legitimate applicant
• Ongoing Authentication: For subsequent validations, including dispute resolution
• Fraud Prevention: To detect and deter unauthorized loan activities

Your facial biometric information is processed securely and used exclusively for these verification purposes.

10. Push_notification

To ensure you receive important information related to your account and loan services, Fresh Loan may request permission to send push notifications to your device.

Push notifications are used to deliver essential service-related messages, including but not limited to:

• In-app messages and system notices
• Loan application status updates
• Repayment reminders and due date notifications
• Account security alerts and important service announcements

Granting notification permission is optional. You may choose whether to enable notifications, and you can modify or disable this permission at any time through your device’s system settings.

Fresh Loan does not use push notifications for unauthorized advertising purposes. Notifications are only sent to support core service functionality and improve user experience.

We do not collect, store, or access any personal content from your notifications. The notification permission is used solely to display service-related messages initiated by our system.

B. Purposes of Data Collection

Your personal information is collected and processed for the following purposes:

1.Loan Eligibility Assessment

To evaluate your creditworthiness and determine eligibility for loan products through credit scoring, background checks, and data analysis.

To facilitate the processing of your loan application, including data sharing with our authorized partners when necessary.

2.Customer Support & Dispute Resolution

To assist you with any inquiries, complaints, or disputes regarding our services.

To provide personalized support based on your service usage.

3.Service Optimization & Communication

To send notifications regarding loan status, payment reminders, and promotional offers.

To update you about changes to our policies, terms, or services.

4.Regulatory Compliance & Fraud Prevention

To comply with legal and regulatory requirements.

To detect and prevent fraudulent or unauthorized activities.

5.Third-Party Service Integration Disclosure

AppsFlyer: Tracks user acquisition channels and in-app behavior to enhance marketing effectiveness and product improvements. We need to collect the following information: Device identifiers, Application installation/launch events, non-sensitive user interaction data.

Dyna.AI: Performs biometric authentication through facial recognition to prevent fraudulent activities. We need to collect the following information: Live selfie images (for liveness detection), Government-issued ID photos (when submitted).

Firebase: Provides push notification services to deliver important service messages, updates, and account-related notifications. We may collect the following information: Device information (such as device model, operating system version, and device identifiers), Application usage information related to notification delivery and interaction.

Alibaba Cloud: Provides encrypted cloud storage for user-submitted verification documents. We need to collect the following information: User-uploaded images (selfies/IDs), Temporary session tokens.

Each integration undergoes rigorous privacy compliance evaluation, with data collection strictly limited to authorized purposes and performed only upon obtaining explicit user consent in accordance with applicable regulations.

C. Managing Your Personal Data

• Access & Modification: You can view and update your personal details within your account settings or by contacting customer support.
• Account Deletion: You may request account deletion, subject to legal and regulatory retention requirements. Some data may be retained for compliance purposes.
• Data Withholding: You may choose not to provide certain information, but this may limit access to Fresh Loan’s services.

D. Data Sharing with Third Parties

To operate efficiently and provide the best possible service, we may share certain personal information with:

1.Credit Bureaus & Financial Institutions

To evaluate your creditworthiness and process your loan application.

2.Service Providers & Partners

Third-party companies providing technical support, payment processing, data storage, and customer service. These entities are bound by confidentiality agreements and may only use your data to fulfill their specific functions.

3.Regulatory Authorities

If required by law, we may disclose information to regulatory bodies or law enforcement agencies to comply with legal obligations.

E. Data Security Measures

We implement industry-standard security measures to safeguard your personal data from unauthorized access, loss, misuse, or disclosure. Our security protocols include:

• Data encryption to protect sensitive financial and personal data.
• Strict access controls ensuring only authorized personnel can access your information.
• Regular security audits to maintain compliance with data protection laws.

We implement rigorous protection measures at every stage of your personal data lifecycle - from collection and processing to storage and transmission. Our multi-layered security framework combines advanced technology with comprehensive policies to safeguard your information.

• Advanced Technical Protections (End-to-end encryption (TLS 1.3/HTTPS) for all data transmissions, Regular security audits and penetration testing, Real-time monitoring for suspicious activities).
• Strict Organizational Controls (Role-based access permissions with multi-factor authentication, Mandatory privacy training for all employees, Comprehensive logging of all data access and modifications)
• Physical Security Safeguards (Secure data centers with biometric access controls, Encrypted storage for all sensitive information).

Despite our best efforts, no system is completely secure. We encourage users to safeguard their account credentials and report any suspicious activity immediately.

We keep your personal data only for the time needed to meet the reasons it was gathered, unless laws or regulations require or allow a longer time.

Identity Verification, Loan Assessment, and Risk Control: We hold this data for up to 5 years after you stop using our service. This is to follow regulations and stop fraud.

Marketing and Behavioral Analysis: We keep this data for up to 2 years after we collect it, or we delete it right away if you take back your permission.

End of Retention Period or Your Request: Once the time is up or if you ask, we will safely delete or make your personal data unrecognizable.

F. Updates to this Privacy Policy

We may periodically update this Privacy Policy to reflect changes in our services, legal requirements, or security standards. When updates occur, we will:

• Publish the revised policy within the Fresh Loan app.
• Update the effective date of the policy.

We encourage you to review this Privacy Policy regularly to stay informed on how we protect your data.

G. Children’s Privacy

Our services are intended only for individuals aged 18 and above. We do not intentionally collect or process personal information from individuals under the age of 18.

If you become aware that a minor has provided us with personal data, please contact us, and we will take appropriate steps to delete such information.

H. Contact Us

For any questions, concerns, or requests related to this Privacy Policy, please reach out to us:

Address:

211-213 Carolina Mall, Santa Rosa-Tagaytay Road, Puting Kahoy, REGION IV-A Silang, Cavite, 4118 Philippines