Disclosure Statement and Privacy Policy
About us:
Company information: MICRODOT LENDING CORPORATION
SEC Registration Number:CS201951287
Certificate of Authority to Operate a Financing/Lending (CA) Company Number：No.: 2921
registered office:6/F Aster Business Center Mandala Park, 312 Shaw Boulevard, Mandaluyong City Metro Manila 1550.
Cash Bay ("Cash Bay", "We", "Us", or "Our", for brevity) hereby adopts this Privacy Policy in compliance with the provisions of Republic Act No. 10173, entitled: An Act Protecting Individual Personal Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission, And For Other Purposes, otherwise known as the "Data Privacy Act of 2012".
For this purpose, this Privacy Policy ensures that the personal data gathered from our clients in the course of transactions, and in accordance with the nature of our business, shall remain secured and protected.This Privacy Policy describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You must read this Privacy Policy in its entirety.
1. What Personal Information We Collect
When you use Cash Bay, in order to process and handle your use, Cash Bay shall in accordance with the law only collect information that is strictly necessary and shall not use it for other purposes. The specific information collected is as follows:
1)SMS
We use the OTP code from the users'SMS to facilitate the auto-fill process when the uses register or log in their accounts. The SMS is also used to auto-fill the verification code during the process of verifying the validation of your financial account when you add your beneficiary's bank account. It's also used for the purposes of risk analysis.SMS data will be encrypted anduploaded to our servers https://systemfile.obs.ap-southeast-3.myhuaweicloud.com
2)PHONE INFORMATION
The device information includes the phone number of the SIM card, device brand, model, operating system version, de vice unique identifier, device network environment, WiFi, device status, identification international mobile device, international mobile subscriber identification, application software information, mobile phone number, device memory information. The authorization to access this information help us to identify your user portrait and preferences and to recommend the suitable credit products. We collect the phone number of the SIM card to facilitate the login process. When we have identified the phone number of the SIM card from the user’s phone, the user can log in directly. without requiring an OTP code. The information is also used to prevent frauds that act on your behalf. The phone number data will beencrypted and uploaded to our https://systemfile.obs.ap-southeast-3.myhuaweicloud.com
3)APP INSTALLED (QUERY_ALL_PACKAGES)
We are a financial application. We need to collect the App installed in your device so as to protect your fun d safety and to prevent frauds. We need this information for your risk assessment and to recommend suitable products.
4)CAMERA
With your consent, we will obtain your permission to take photos. This permission will allow you to upload photos. This permission needs to be manually confirmed by you before we can obtain it.We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the Platform during your loan application journey.Photos are stored encrypted on our servers at https://systemfile.obs.ap-southeast-3.myhuaweicloud.com
Cash Bay shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Cash Bay's products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Cash Bay will only share your information with third parties on an anonymous basis.
5) LOCATION DATA
e.g., mobile device location, time zone setting);Other information:We may collect some of your other personal information only after obtaining your additional explicit consent.
Cash Bay reserve the right to request for additional documentation to verify the information provided by you. Your submission of any information to us, our authorized agents or the Platforms expressly contains your warranty that such information is accurate and not misleading.
6) APP USE INFORMATION
We need permission from appuse information to prevent fraud.We are committed to encrypting the information and ensuring the security of the information.
2.How We Use Your Personal Information
One of our primary purposes in collecting Personal Information is to establish a safe, smooth, efficient and customized experience that allows our users to take full advantage of the products and services available through Cash Bay. During the course of your availment of our service, Cash Bay may utilize, process and/or disclose your Personal Data to Cash Bay’s affiliates, subsidiaries and partner companies for any of the following purposes (“Permitted Purpose”):
1) to authenticate your identity;
2) to assess and process your applications for Cash Bay’s products and/or services;
3) to handle complaints and queries, to communicate with you including but not limited to sending you updates and reminders, responding to your inquiries and/or complaints and resolving disputes;
4) to manage and maintain your accounts/facilities with Cash Bay;
5) to conduct credit checks/credit evaluation to assess or verify your credit/financial worthiness and to assist other financial institutions to conduct credit checks;
6) to evaluate your financial needs;
7) to utilize the same for marketing and promotions;
8) to maintain your credit history for present and future references;
9) to detect and investigate crime, fraud or illegal activities, and to utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions, including know your customer (KYC);
10) to respond to the requirements of a civil or criminal legal process and/or for regulatory compliance purpose and/or as required by law or regulation;
11) to collect any debt due or owing by you, and to enforce your obligations to Cash Bay;
12) to compile, use, research, analyze, and generate data analytics reports to better understand our customer with the aim of improving our products and services and product development;
13) to provide you with the information on our and third-party products and services which may be of interest to you;
14) to compare information/data for accuracy of our record, and to verify the same with third parties;
15) to utilize the same for customize and enhance user experience and improvement of our products and services, operational and business processes;
16) to support our business, financial and risk monitoring, planning and decision-making and to utilize and disclose the same for audit and compliance, no matter from outsourcing of business and internal operations;
17) to transfer or assign our rights and duties under any governing terms and conditions between Cash Bay and yourself;
18) to transfer your Personal Data to local and/or foreign jurisdictions for the purpose of processing and storage and to enable any transactions, for the performance of a contract, products and/or services, for the purposes of legal proceedings;
19) for any other purposes that is required or permitted by any law, regulation, order and/or guidelines.
Cash Bay may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help Cash Bay better understand user behavior, tell Cash Bay which parts of our products/services have visited or used, and facilitate and measure the effectiveness of advertisements and searches.
3.How does Cash Bay use your Information?
a. Automated decisions and profiling
We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.
Lending decisions
When you apply for a loan, we’ll use automated processing to decide whether to lend to you and/or make other decisions about your eligibility for our products and services, based on the Information collected. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.
Our credit and underwriting models utilize data science and machine-learning technology to process your Information and assess your creditworthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Detecting fraudCash Bay also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.
Your rights in relation to automated decision-making
If you apply for a loan and your loan is declined (or you are informed that you are ineligible for other or associated products or services) as a result of an automated credit, underwriting or fraud decision, you may request that one of our underwriters review this decision. You may contact us through the contact information shown on the mobile app
b. Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about Cash Bay products, services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with Cash Bay, including by learning more about you and how you use and interact with Cash Bay Internet Sites, Apps, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.
c. Communicate with you. This may include: (i) informing you of Cash Bay products, services, and promotional activities that may be of interest to you; (ii) providing information about relevant Cash Bay products, services, and transactions, including, for example, pricing, information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
d. Provide and improve our Internet Sites, Mobile Application, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new Cash Bay Internet Sites, Mobile Application, products and services.
e. Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Cash Bay Internet Sites, Apps, products or services; and (v) protecting Cash Bay’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
4. Who do we share your Information with?
Cash Bay shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Cash Bay's products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Cash Bay will only share your Information with third parties in an anonymized format.
You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to:
a subsidiary, affiliate or parent company of Cash Bay (collectively, the "Cash Bay Group");
employees, subcontractors, agents, service providers, or associates of the MICRODOT LENDING CORPORATION (including directors and officers);
intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, credit reference agencies or credit bureaus;
service providers with contractual or fiduciary relationships with Cash Bay (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer);
external collection agencies (to assist in the collection of any unpaid obligations to us);
tax authorities;
a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Cash Bay and/or any company within the Cash Bay Group;
to other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Cash Bay, the Cash Bay Group and/or our customers.
The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy.
Further, Cash Bay may also share your information with law enforcement or other government agencies pursuant to a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you.
5. For how long will we retain your Information?
Your Personal Data will be stored or retained by Cash Bay and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We may also retain your Information (i) as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses.
Your Personal Data will be retained by the Company for the duration of your activities and transactions in connection with the products and services availed of in this Microdot Lending Corporation Corp and/or for such period of time required for legal and regulatory and/or other legitimate business purposes, and will be disposed of in a secure manner that would prevent further processing, unauthorized access or disclosure to any other party or the public or prejudice your interest, provided that the Company may retain copies of your Personal Data in the Company’s archives for the purpose of determining its continuing obligations or pursuant to its bona fide record retention or data back-up policies, access to which shall be restricted on a need-to-know basis, as may be required under applicable laws and regulations.
The Personal Data may likewise be retained for the purpose of fraud prevention, detection, and monitoring in accordance with the Company’s fraud detection and prevention policies, and any requirement imposed by any credit agency, bureau or agency in order to prevent fraud, identify theft, anti-money laundering, terrorist financing and other similar causes which are consistent with public policy and the public good.
6. Where do we process, store or transfer your information?
Your Personal Data including your transaction data is stored in the secure third-party cloud service provided by our cloud service providers (Amazon and Alicloud) who are among the best-of-breed cloud providers in the industry.
We may transfer your Information outside of the Philippines, either to the United States, or Singapore, and/or to the extent we provide prior notice to you, to jurisdictions that may have data protection laws that are less stringent than those of the Philippines. When we do so, we will ensure that adequate safeguards are in place in accordance with applicable law and/or the Philippines'data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your Information. Your Information may be processed by any of the parties described in Section 3. Cash Bay will use all reasonable and appropriate efforts as required by applicable law to protect your Information.
7. Automated decisions and profiling
We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.
Lending decisions
When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.
Our credit and underwriting models utilize machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Detecting fraud Cash Bay also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual's access may be suspended or refused.
Your rights in relation to automated decision-making in the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through :contact.mlc@microdotlending.top.
8. Your rights as a data subject
You may contact us to exercise your rights atcontact.mlc@microdotlending.top.
Rights to notice and consent
We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Cash Bay App and in this Privacy Policy.
Right to access
You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request.
Right to rectification
You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the thereof.
Right to erasure ("right to be forgotten")
You may ask us to delete your personal data (as defined under applicable law) from our system:
If you believe it is no longer necessary for us to retain such personal data;
If you do not believe we have legitimate ground for processing it;
If you think we are using such personal data unlawfully; and/or
If you think applicable law requires that we do so.
Right to restrict processing
You may ask us to stop using your personal data (as defined under applicable law):
if you think such personal data is inaccurate;
if you think it's illegal for us to use such personal data;
if you don't want us to destroy such personal data because you need it for legal proceedings;
if you've informed us that we don't have a legitimate reason for using it and we're considering your request.
Right to data portability
If we're using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller.
Right to object
You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data).
Right to file a complaint
You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject, including the National Privacy Commission of the Philippines.
Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation).
9. Advertising and Marketing
You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request throughcontact.mlc@microdotlending.top and we will remove you from such communication lists.
10. Consequences of not providing us with your Information
You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Cash Bay, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.
11. Consent and Authorization
By downloading the Cash Bay App, you:
accept the terms of this Privacy Policy;
give Cash Bay consent to collect, use, share, or otherwise process your Information, which may include personal information, sensitive personal information or privileged information (in each case, as defined under applicable law), as outlined in this Privacy Policy;
certify that all Information you have provided and will provide to Cash Bay is true and correct to the best of your knowledge;
authorize Cash Bay to verify/investigate the accuracy of your Information; and
acknowledge that Cash Bay may be required to disclose your Information to the Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, credit bureaus and/or any other governmental body, in compliance with its legal obligations.
12. General
If you need to contact us, please do so at:contact.mlc@microdotlending.top
To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Cash Bay App or by email.