TS EVO PH FINANCE INC., operating under the name EVO Finance (the “Company”, “EVO Finance”, “we”, “us”, or “our”), operates the website https://www.goevo.ph/ (the “Website”). This Website Privacy Policy (“Privacy Policy”) explains how we collect, use, disclose, retain, and protect personal data when you access or use the Website, and the choices and rights available to you under the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and related issuances of the National Privacy Commission (“NPC”).

By clicking “Next”, using the Website, or otherwise indicating your acceptance, you acknowledge that you have read, understood, and agreed to this Privacy Policy. This Privacy Policy supplements and forms part of the EVO Finance Website Terms and Conditions (“Terms and Conditions”).

Definitions

• “Website” means the EVO Finance website located at https://www.goevo.ph/.

• “Platform” means the Website and the EVO mobile application collectively (used in the Terms and Conditions). This Privacy Policy governs personal data collected on the Website; where data is collected through the EVO mobile application, such collection will be described in relevant product notices and the Platform-level references in the Terms.

• “You” / “User” means any individual who accesses or uses the Website.

• “Loan Provider” means a bank or other financial institution duly licensed by the Bangko Sentral ng Pilipinas (BSP) or  a lending  or financing company licensed by the Securities and Exchange Commission (SEC) to engage in lending.

• “Third Party Service Providers” means processors/subprocessors and other third parties engaged by the Company to support the Website or deliver services.

• “Commission” means the National Privacy Commission (NPC).

This Privacy Policy supplements and forms part of the EVO Finance Terms and Conditions.

1.   Website

1.1  The Website is an online platform provided by EVO Finance that enables You to apply for and access the financial products and services offered by EVO Finance and/or Loan Provider. 

1.2 When You access and submit information as specified on the Website, EVO Finance collects and processes such information from You directly and from third party sources as specified in this Privacy Policy. 

2. Information We Collect and Process

2.1 We obtain personal and non-personal information about You in various ways such as when You use the Website, communicate with us, or interact with our support representatives. 

2.2 Your access to the Website may require the input or use of some of Your personal information and non-personal information for Us to be able to: (a) verify Your identity, (b) assess Your qualifications to apply for an EVO loans, and financial products offered by Loan Providers, (c) to conduct credit risk and fraud detection checking, and (d) authenticate Your transactions using using the Website including but not limited to:

(i) Identifiers such as Your full name (first, middle, last name); date of birth; place of birth; email; selfie / photograph; mailing address; postal code; mobile phone number, gender, civil status, mother’s full maiden name, biometrics, 

(ii) Photo of government- issued photo ID, such as a driver’s license, passport, Philsys;

(iii). Employment information including but not limited to monthly gross income, employer/business name, nature of work, position employment status, years of business / work experience; taxpayer identification number (“TIN”); Home Development Mutual Fund (“HDMF” or “PAG-IBIG”) number; Social Security System number (“SSS”);

(iv) information from third party databases including government regulators, supervisory bodies, tax authorities or courts of or courts of competent jurisdiction and, in the process, gain additional information about You such as credit score, telecommunications usage data or “telco usage score”, bureau score, credit bureau report, and other credit history data from third party data providers such as credit reporting agencies, credit bureaus, credit scoring and data analytics companies;

(v) Reference contact information including, but not limited to the name and mobile number of the reference, relationship with the reference; and

(vi) As a part of our Know Your Customer (KYC) process, collection of Your personal information has become mandatory to ensure the completion and authentication of Your identity. In this regard, permissions for microphone and camera will be mandatorily required. We may also collect voice recordings of our conversations with You,

3. In the course of availing EVO Loans and/or financial products offered by Loan Providers in partnership with EVO Finance, we also collect information about Your transactions and dealings using the aforementioned which include Your account activities, movements and interactions with third parties such as merchants and utility companies. We may also collect information on how the Services are accessed and used (“Usage and Transaction Data”) to enable us to: (a) communicate approval of Your application of EVO Loans and/or financial products offered by Loan Providers in partnership with EVO Finance and other pertinent information, (b) analyze and improve process and services; (c) track, monitor and reconcile transactions for our and Your records, (d) perform data analytics on Your propensity to pay, (e) evaluate and assess Your eligibility and/or preference to receive marketing and/or promotional material or obtain other financial products as EVO Finance may offer, (f) create customized recommendations for a more personalized experience in availing any of the services, (g) develop data science models to optimize processes required to deliver the Services, (h) develop automated solutions to assist with key processes throughout the availment of EVO Loans and/or financial products offered by Loan Providers in partnership with EVO Finance, usage, payment, and (i) conduct studies, statistical analysis, research, automatic and manual profile analysis, behavioral modeling on Your values, scores, metrics from your personal data, your preferences, financial behavior across product and service interactions, along with market trends. This Usage and Transaction Data may include information such as Your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, operating system, information and files that have been downloaded from the Website, device model and manufacturer, internet service or mobile telecommunications provider, device location and other diagnostic data. This information is not matched with Your personal information and will not be used to identify You, except in cases of fraud or as may be required by law or by an order of court of competent authority or other governmental agencies, or as necessary to: comply with EVO Finance’s legal obligations, resolve disputes, and enforce its agreements.

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.

2.4 We use web analytics tools that use cookies and similar tracking technologies to track Your activity on the Website and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to Your browser from a website and stored on Your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of the Website.

If You do not wish some of Your personal information to undergo any of the foregoing processes, send us an email at evofinance_dpo@trustingsocial.com. 

3. Methods of Collection and Processing

3.1 We collect Your information from the documents and information that You may have directly submitted to us, information from third party databases You connect within or through Website such as credit bureaus and customer service providers.

3.2 Where You have provided us with the personal information of individuals other than Yourself, You represent and warrant that You have obtained the necessary consent from such individuals for the disclosure, in accordance with the applicable laws, including DPA, and that You are authorized to disclosure such information to us.

4. Use of Information 

4.1 We use the collected information for the following legitimate, lawful, and specific purposes which are reasonably necessary to provide and enhance our services:

To provide and maintain the services; to assess your credit worthiness; to start the your application process; To ensure that the provided information is accurate by verifying information with third parties; 

To conduct credit checking and/or to perform data analytics on the propensity of a user to pay off financial and loan products, and such other related analytics; To conduct initial KYC process; 

To approve, facilitate, administer and process applications and transactions using the Website;

To communicate with You alerts, approvals, notifications, follow-ups, and recommendations; to respond to queries, requests and complaints and improve how we interact with You; To send You statements, billings, notices and other such documents necessary for continued use of our services;

To process Your application for EVO Loans and/or financial products offered by Loan Providers in partnership with EVO Finance on  Your behalf; 

To conduct studies, statistical analysis and research for the purpose of reviewing, developing and improving the processes and EVO Loans and/or Loan Providers’ products and services  to onboard You more seamlessly, to monitor the usage of the Services; to provide customer care and support; to detect, prevent and address technical issues; to provide analysis or valuable information so that we can improve theWebsite; to monitor, detect and prevent fraud or abuse of the services; To establish, exercise, or defend legal claims; to fulfill any other purposes directly related to the above-stated purposes.

To perform profile analysis, behavioral modeling and analytics to understand needs, preferences and market trends to be able to improve and recommend suitable products and services; 

To perform back-testing, data analytics, train and develop machine learning and data science models to build and improve third party service provider’s credit score products/ telco score services which may be shared with other financial institutions and telecommunication companies with which You have accounts, loans or transactions, and which have separately secured Your consent to receive and process such credit score/ information; to improve third-party service provider’s proprietary algorithms in providing the services and EVO Finance’s other products and services;

To reach out to You regarding products and services information, including offers, promotions, discounts, rewards; and for personalizing Your experience with our various touchpoints such as branches, call center, telemarketing, email, messaging and other channels; to determine the effectiveness of our marketing efforts and initiatives;

To provide location-based services;

To perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;

To comply with EVO Finance operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, relevant rules and regulations, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time;

To comply with applicable laws of the Philippines and those of other jurisdictions including the United States Foreign Account Tax Compliance Act (“FATCA”), the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended (AMLA) and the implementation of know Your customer and sanction screening checks;

To 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;

As required by law or legal instrument, to protect the EVO Finance’s rights or assets, or in pursuit of legal claims;

To perform other such activities permitted by law or with Your consent.

We will not process Your personal information in ways incompatible with the purposes outlined in this Privacy Policy, unless otherwise required by law or authorized by You through prior notice and express consent.

If You do not wish Your personal information to undergo any of the foregoing processes, send us an email at evofinance_dpo@trustingsocial.com. We also may use the information in other ways for which we provide specific notice at the time of collection. Please note that certain features or services may become unavailable as a result of consent withdrawal.

5. Personal Information Controller

5.1 In accordance with Applicable Privacy Laws and Regulations (as defined below), including the Data Privacy Act of 2012 of the Philippines (“DPA”) and its implementing rules and regulations, EVO Finance serves as the Personal Information Controller (“PIC”). This means EVO Finance determines the purposes and means for collecting, using, and processing your personal information. 

5.2 In certain cases, your personal information may be disclosed to third parties under a valid data sharing agreement. These third parties may also act as independent PIC, determining their own purposes for processing the personal data in accordance with Applicable Privacy Laws and Regulations. EVO Finance ensures that such arrangements comply with the requirements set out under DPA, including appropriate contractual safeguards and transparency measures. 

6.   Transfers and Disclosures

 6.1 We will take all steps reasonably necessary to ensure that Your information is processed and stored securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information in compliance with the DPA, its implementing rules and regulations and the issuances of the NPC (“Applicable Privacy Laws and Regulations”).

6.2 Your personal information may be disclosed to our partners and third parties, EVO Finance’s affiliates and subsidiaries under an obligation of confidentiality:

Financial institutions that provide credit and/or other financial products, credit bureaus, credit information service providers, other service providers, third-party partners, telecommunication network partners (e.g., Globe, PLDT, Smart Communications, Sun Cellular), utilities companies (e.g the MVP Group, including but not limited to Kayana Solutions Inc., PLDT Inc., Smart Communications and its affiliates) legal counsel, government regulatory agencies and offices, law enforcement agencies;

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 creditor to customers availing of our loan or credit 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.

We wish to assure You that we do not, and will not, sell personal data to any third parties. 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.

      7.   Data Retention

7.1 Your personal information shall be retained only 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 and until such time as it is no longer required nor necessary to keep Your information for any other legal, regulatory or business purposes. Once the purpose for which it was collected shall have been completed, we will securely dispose of Your personal information unless we are required to retain them for legal or regulatory purposes, to resolve disputes or enforce agreements. 

      8.    Data Protection Measures

8.1 We fully recognize the value of Your personal information particularly as it may include sensitive personal information such as Your gender, government-issued IDs, etc.  Appropriately, we strive to maintain the confidentiality, integrity and availability of Your personal information by employing physical, technological and procedural safeguards designed to help prevent unauthorized access, to maintain data security, and to correctly use the Information we collect and process. We train our employees to properly handle Your information.  Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards.

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8.2 The security of Your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.

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9. Access

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9.1 We encourage You to keep their personal information current and updated. Data subject access requests may be made by emailing the data protection officers at evofinance_dpo@trustingsocial.com 

9.2 The Company may take reasonable steps to confirm the requestor's identity as a data subject before granting access to the personal information and allowing updates thereto.

     10.   Rights of Data Subjects

10.1 In respecting Your rights to privacy, You may opt to tell us:

a. to inform You of what we do with Your personal information;

b. to provide You with information that we currently have about You, subject to restrictions applied to us as a non-bank credit card issuer and a company operating in the Philippines by certain laws and regulations, in an easy-to-access format and easy-to-understand language;  

c. not to send You marketing materials via email or SMS, 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, providing and completing the products or services that You have availed from us;

d. not to process Your personal information upon withdrawing consent, unless processing is legally required;

e. to remove and dispose Your personal information from our records, as allowed by applicable laws and regulations;  

f. to update any personal information upon Your advice;

g. to electronically move, copy, or transfer it securely through available means;

h. to be informed whether personal information pertaining to You shall be, is being, or have been processed, including the existence of automated decision-making and profiling;

i Upon presentation of a valid decision, we recognize Your right to be indemnified for actual and verifiable damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information, taking into account any violation of Your rights and freedoms as a data subject.

10.2 We may charge a reasonable processing fee for responding to Your request/s for access and/or update. Such a fee depends on the nature and complexity of Your request. Information on any reasonable processing fee will be made available to You prior to making the request.

10.3 You may lodge a complaint regarding our use of Your personal information and be assured that we will address Your concerns promptly.  Should we fail to do so, You may address any complaint to our regulators, particularly the National Privacy Commission, consistent with the rights granted to You under applicable laws and regulations.  

11.   Links to Other Sites

11.1 The Website may contain links to third-party websites or services that are not operated or controlled by us. These links are provided for your convenience and information. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

11.2 We have no control over and assume no responsibility for the content, privacy policies, security or practices of any third-party sites, platforms, or services. Your interactions with such third-parties are governed solely by their respective policies and agreements.

12. Modification of Privacy Policy

12.1 We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

12.2 We will let You know via email and/or a prominent notice on the Website, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

12.3 You are advised and encouraged to review this Privacy Policy periodically for any changes to stay informed about how we are protecting your personal information. Changes to this Privacy Policy are effective when they are posted on this page. Continued use of the Website  following any changes signifies your acceptance of those changes.

13. Contact us

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13.1 For any queries, clarifications or requests on any aspect of this Policy, 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, You may email the data protection officers at evofinance_dpo@trustingsocial.com. We are committed to addressing your inquiries in a timely and responsible manner, consistent with our obligations under Applicable Privacy Laws and Regulations.

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14. Validity of Consent

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14.1 This consent and authorization remain valid and subsisting for a limited period consistent with the purposes above or until otherwise revoked or cancelled in writing. You may inform us of the specific personal information You do not want to be processed beyond the requested purpose. We will respect Your request insofar as it is feasible to fulfill the purpose for which the personal information was collected. 

14.2 Please note that the withdrawal of Your consent may impact EVO Finance’s ability to continue providing You with certain products or services.