Privacy Policy
Copperstone Lending Inc, its assigns, affiliates, and related companies in the conduct of its business in the Philippines (hereinafter referred to as “Company”) value the privacy of our Users and any person who use, access, download, browse, or register with the Services on the MocaMoca website, its application, or other related digital medium or media including social media (hereinafter referred to as “Platform”). This Privacy Policy is part of MocaMoca commitment to respect and protect every personal data and information belonging to the individual uses of the Platform, including prospective lenders or borrowers (hereinafter referred to as “User”, “you”, or “Users) or visitors to the Platform. This Privacy Policy has been prepared in accordance and in compliance with the laws of the Republic of the Philippines, and is for the exclusive use of the Company. This Privacy Policy sets out the policies of the Company, its assigns, affiliates, and related companies in relation to any and all types of Personal Data (as defined below) referred to in this Privacy Policy, including sensitive personal information. In this Privacy Policy, “Personal Data” means any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual, as defined under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (hereinafter referred to as the “Data Privacy Act”). Personal Data may be provided by individual users of the Platform, for the collection, use, and disclosure by the Company, its assigns, affiliates, and related companies.
All names and other Personal Data which relate to Users shall be handled the manner set out in this Privacy Policy. We only collect information where it is necessary for us to do so and we will only collect information if it is relevant in our dealings with Users. We will only keep Users’ Personal Data for as long as we are either required by law or as is relevant for the purposes for which the information was collected.
The scope of this Privacy Policy is limited to information collected or received by us through your use of the Platform. We are not responsible for the actions of third parties or companies, the contents of their facilities, the use of information you provide to them, the information they provide to you or any products or services they may offer. Any link to those sites does not constitute our partnership with, sponsorship or endorsement of, or affiliation with, those parties or companies or their brands.
By using the services provided by the Platform, whether via website or application, you are expressing your agreement to this Privacy Policy and the processing of your Personal Data in the manner provided in this Privacy Policy. If you do not agree to these terms, please do not use and exit the Platform.
Personal Information Collection Items and Collection Measures
We collect information to provide a better service to the users. We will not collect your personal data without your permission.
1.Information provided by users
When joining as a member, we may collect the following information for the user’s personal services: (1)full name,(2)email address,(3) residential address,(4)telephone number, (5)emergency contacts,(6)employment information, (7)monthly income, (8)date of birth, (9)gender, (10)ID information, (11) beneficiary's bank account information（12）facebook account name
2.Information collected during use of service
We collect information about the applications and devices you use to access the services of the Platform, which helps us to provide you with services. The information and permissions we collect includes: (1) location;(2) contacts;(3) camera; (4) calendar; (5)storage; (6)media & photos &files;(7) phone information
Objectives of Personal Information Collection and its Legal Basis
1.LOCATION
We collect your geo-location information when the Platform is running in the foreground so as to auto-fill your address data. We endeavor to cease collection of your geo-location information when the Platform is in the background You can always choose to disable the geo-location tracking information on your Mobile Device temporarily.
2.CALENDAR
The authorization to access your calendar help us remind you the due date of repayment.
3.STORAGE
We require the storage information permission that allows the Platform to enable you to upload photos and/or documents to complete the application form during your loan application journey.
4. PHONE INFORMATION
The phone information includes device brand, model, operating system version, device 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;
VALIDITY AND ACCURACY OF INFORMATION SUBMITTED
1.Submission of True and Accurate Information – You must submit to us information including Personal Data which is true and accurate and not misleading, and you must keep it up to date and inform us of changes as soon as practicable. We reserve the right to request for documentation to verify information provided by you.
2.Voluntary Submission of Personal Data – We will only be able to collect your Personal Data if you voluntarily submit the information to us. If you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with some or all of the services available through the Platform.
Disclose your personal data to third parties
You have the privacy right to your personal data. Our company will only disclose your personal data to third parties under the following circumstances, the relevant institutions will collect, use, and/or disclose your personal data within the scope of your authorization and consent:
• Disclosure to authorized employees of our company and its affiliates, including our company’s auditor or external auditors, financial cooperative institutions, and/or third parties that are related to our company;
• Disclosure to enable you to trade and/or use services that you desire;
• Disclosure to the Credit Bureau (a type of credit reporting agency);
• Disclosure under legal investigation or legal actions;
• Disclosure in accordance with laws, government orders, or regulatory requirements.
To help you successfully apply for the loan, we will disclose your necessary personal data to third-party cooperative institutions, including fund lenders, payment partners, post-loan partners, third-party verification service providers, messages service providers, call-out service partners.
USE/PURPOSE OF PERSONAL DATA
Personal Data shall be processed, collected, used, disclosed, stored, and retained for the following purposes:
• to identify Users;
• to contact Users in relation to their registered account/s or requested information;
• to process registration of account/s and to determine or assist in determination of decisions as part of screening of the investors, borrowers, registrations or loan applications, and/or to deliver our products and/or services to the User and any directly related purposes;
• to facilitate loan processing from application, review, monitoring, payment, collection and other remedial measures;
• to maintain internal records;
• to market and offering new, related or complementary products and services to the User;
• to conduct background check and identity verification;
• to conduct and perform fraud monitoring, detection, analysis and prevention;
• to prevent, detect and investigate actual or suspected crime and analysing and managing commercial risks;
• to conduct data analytics and tracking;
• to conduct market research to enable the Company ·to understand and determine customer location, preferences and demographics to develop special offers, products or marketing programs in relation to products and services, and to improve (i.e. customized offers and products) such products and services;
• to perform research on data to conduct investigations relating to disputes, payment, suspected illegal activities or fraud;
• to carry out marketing and promotions initiatives relating to the Company, local affiliates of the Company, the Company’s partners, and other Company’s products and services, whether by electronic means, by email and post, or by telephone, SMS or social media, or by sending newsletters (for example, for the Users to be updated on new products or features and to publicize events, contests, demonstrations, loyalty programmes, and other activities organized by the Company and/or the Company), also by using automated means. Such communications will relate to products and services of the financial products, services and the like.
• to develop, enhance and maintain a risk assessment process and model, offline and online;
• to develop and generate a credit score, credit model and user model;
• to enrol/participate the user in group credit and/or life insurance, credit risk analysis, credit investigation, credit scoring and credit collection on the User;
• to perform User location search;
• to execute, monitor, manage and analyse the Platform and to develop, enhance, and upgrade the features, functions, products and services in the Platform, including promotions, loyalty and reward programs;
• to respond to User queries and requests;
• to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) of the Company;
• to facilitate and as may be required as part of any financing or capital raising activity (i.e. obtaining loans, credit facility, mortgage, assignment, assignment as a form of security or mortgage of loans);
• to initiate and maintain correspondence with the User via electronic mail (e-mail), SMS (short messaging service), in-app message/communication, registered mail, phone calls or field visits;
• to resolve complaints and handling requests and inquiries;
• to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
• to provide information to external parties such as government agencies, and other institutions as part of scientific research and/or study; and
• for any other legal and/or regulatory purposes (including but not limited to obtaining legal advice and dispute resolution) and legitimate business purposes and to carry out all mandatory administrative, operational and legal duties
SECURITY OF PERSONAL DATA
The Company values Personal Data collected, used, retained and stored through the Platform. The Company has adopted technical, organizational and physical measures to protect your Personal Data.
We take reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration by third parties.
Although we make good faith efforts to store the information collected on the Platform in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our system. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegal obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties.
USER OBLIGATIONS
You agree to inform us promptly, and in any event, within 14 calendar days, in writing if there are any changes to your information supplied to us from time to time, and to respond promptly to any request from us,
1.Where:
1.1. you fail to provide promptly any user information or Personal Data that we reasonably requested;
1.2. you withhold or withdraw any consents that we may need to process, transfer or disclose Personal Data for the purposes of used disclosed above in this Privacy Policy (except for purposes connected with marketing or promoting products and services to you); and/or
1.3. we have, or a member of the Company has, suspicions regarding financial crime or an associated risk.
2.We may:
2.1. be unable to provide new, or continue to provide all or part of the services to you and reserve the right to terminate our relationship with you;
2.2. take actions necessary for us or a member of the Company to meet the compliance or regulatory obligations; and/or
2.3. suspend, transfer or close your account(s) where permitted under local laws.
YOUR PRIVACY CONTROLS
You have the rights to:
1. Access your personal data in possession of the Platform;
2. Revoke the consent to the processing of your personal data, revise and/or delete the personal data in possession of the Platform unless the conservation of the said data is mandatory by laws and regulations, without retroactive effects, in all those cases in which such revocation, revision, and deletion do not imply the impossibility of fulfilling obligation derived from a current legal relationship between you and the Platform or when it comes to non-necessary purposes.
The exercise of the aforementioned rights must be carried out in writing by email to the following email address:ritasisiy@outlook.com.After the application has been submitted in the aforementioned terms, the Platform will issue the adopted determination.
MODIFICATION
This Privacy Policy may be updated from time to time and shall continue to remain in effect unless otherwise amended. If this Privacy Policy is changed, those changes will be posted on the Platform. The change will be effective when posted. Users availing services and/or visitors to the Platform are advised to check the website on a regular basis to remain aware of the policies and practices of how information is collected and used.
If significant changes to this Privacy Policy will affect certain Personal Data, the Company shall notify its Users through the email address provided or by posting a public notice on the Platform.
The foregoing consents and authorizations shall continue for the duration of, and shall survive the termination of any loan agreement(s) signed by the borrower, or any other transactions, dealings, arrangements and accounts which borrower may have with, or avail from, the Company and the lender through services and/or the Platform.
Contact Us
If you need help from us when there are any information, errors, doubts about the changes in your account without your permission or any of your transactions, you shall notify our customer service center via email: ritasisiy@outlook.com or immediately write to the corresponding department with the following information:
• Your name and account name;
• The time and date of such transactions or changes;
• Error description and reference code (if applicable);
• Contact name and address, including email address (if any).
We will immediately investigate any errors or unusual activities reported and will inform you of the results as soon as possible.