• Identification data (e.g., first name, surname, date, and place of birth);
• Data provided by you through your loan application (e.g., information about your income or employment, your proposed use of your loan proceeds, customer-provided information about your mobile device);
• 5 reference from contacts (guarantors);
• Mobile device data (e.g. device identifiers, type of device, device operating system, device settings, user account information for your mobile device or AppStore account, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, etc.), information about network proximity);
• Location data (e.g., mobile device location, time zone setting);
• Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information);
• Moca App usage (e.g., traffic (volume) data, information about your usage of the Moca App);
• Data related to your communications with Moca (e.g., your communications with Moca via in-app chat, email, telephone, or other channels); and Moca may collect your Information from You, when downloading the Moca App and/or indicate that you want to apply for a loan;
• Your other interactions with us, including information you may voluntarily share with our customer support team or other Moca employees or agents;
• Your mobile device (e.g., mobile device data, location data, transaction data, Moca App usage, and/or phone data as more fully described above);
• Collection and processing of your Information by Moca is necessary for the provision of Moca’s products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Moca are subject. Apart from such cases, we do not collect information without your specific prior consent.
• Phone data (e.g., 5 reference from contacts (guarantors), SMS logs);
• We may collect some of your other Personal Information only after obtaining your additional explicit consent.
• ✔Permisslon to Image: the pictures you choose to upload will be collected. This information is mainly convenient for you to use the APP. If your ID is not with you, you can select the ID photo from the album or continue to submit the loan application and get the loan amount.This data will be uploaded to theserver at https://mamamayang.com/. It will be keptconfidential at all times and will not be disclosed toany third party.
• To assess your eligibility to use our products or services (including, but not limited to, by assessing your creditworthiness, determining whether you can afford a product or service you requested, and/or determining whether you are eligible for additional benefits of an existing product);
• To service your loan with Moca (including, but not limited to, by processing your transactions and processing disbursement of your loan and collecting repayment of your loan);
• To verify your identity and/or other information you’ve provided to us;
• To detect, combat, and prevent fraud, attempted fraud, money laundering, and/or other illegal uses of our services;
• To analyze customer behavior;
• To administer our systems, maintain service quality, and compile general usage statistics;
• To analyze and improve our services;
• To troubleshoot any problems you or other customers encounter with Moca’s services;
• To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and/or anti-money laundering;
• To the extent you have not objected to the use of your information for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers;
• To provide service updates;
• To provide staff training (where we may monitor or record customer interactions);
• To interface with credit reference or fraud prevention agencies;
• To provide customer service or support;
• To contact you by telephone using auto dialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.
• To contract you via viber account, just in case you are not contacted via phone call and sms.
• We process your Information for the purposes set out above on the following grounds:
• In connection with our legitimate interest in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others, and (4) administering our systems and keeping our records up to date;
• To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you); and/or with your prior consent.
•Please rest assured that we will not disturb the user's contacts as long as the user's service is not hindered. We may share users’personal information in the following situations:The user’s loan has been overdue for many days, or if the principal and interest are not paid, the user cannot be contacted.In other cases, we will not share your contact information.
• This contact information will be upload the server ( https://mamamayang.com/) and will not share with any third party.
• 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 Moca (collectively, the “Moca Group”);employees, subcontractors, agents, service providers, or associates of the Moca Group (including directors and officers); intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearinghouses, 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 Moca (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 Moca and/or any company within the Moca 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 Moca, the Moca 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, Moca may also share your information with law enforcement or other government agencies in connection with 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.
• Referrals
• To promote its products and services, Moca administers and services a referral program (the “Moca Referral Program”) for its current and future customers. If you choose to accept a referral from another Moca customer and accept a Moca loan in connection with that referral, Moca will provide a bonus to the customer who refers you upon the successful repayment of your Moca loan.
• If you choose to participate in the Moca Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the embedded referral link, and subsequently applying for and accepting a Moca loan through such referral.
• Sharing of your Information in connection with the Moca Referral Program will always be limited to the information described above and will always be anonymized – Moca will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Moca. More information on the Moca Referral Program is available within the Moca App.
Your Information will be stored or retained by Moca 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.
• We may make certain decisions in relation to the 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. 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 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 fraud
• Moca 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 do so by contacting us at: developer@mamamayang.com
• You may contact us to exercise your rights at developer@mamamayang.com
• Rights to notice and consent
• We must provide you with certain information related to how we collect your Information, how we use your information (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 Moca App and in this Privacy Policy.
• Right to access
• You may ask for a copy of the personal data (as defined under applicable law) we hold concerning you (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 any 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 request.
• Right to erasure (“right to be forgotten”)
• You may ask us to erase your personal data (as defined under applicable law):
• If you believe it’s no longer necessary for us to retain such personal data;
• If you do not believe we have a 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 relevant 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’re 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).
We may make certain decisions in relation to the 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. 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 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 fraud
• Moca 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 do so by contacting us at: developer@mamamayang.com.
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, if you do so, we may be unable to provide our current or future products and services to you and we reserve the right to terminate our relationship with you, as permitted under applicable law. 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 Moca, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.
• By downloading the Moca App, you:
• accept the terms of this Privacy Policy;
• give Moca 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 Moca is true and correct to the best of your knowledge; authorize Moca to verify/investigate the accuracy of your Information; and acknowledge that Moca 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.
• If you need to contact us, please do so at:
• 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 Moca App
