RPAX Loan Privacy Policy

Introduction

This Privacy Policy aims to provide a comprehensive explanation of the practices, principles, and specific measures employed by RPAX Fund Lending Corp. (hereinafter referred to as "we," "us," or "our company") regarding the collection, use, processing, storage, protection, and, in certain circumstances, sharing of your personal and non-personal information when you access or use the RPAX Loan application (hereinafter referred to as "the App" or "this application"). We are a corporation duly registered and licensed under the laws of the Republic of the Philippines, authorized and supervised by the Securities and Exchange Commission (Registration No. CS201901931; Certificate of Authorization No. 2887).

Protecting your privacy and securing your personal data is an unshakable cornerstone and core commitment of our business operations. We fully recognize the sensitivity and importance of the information you provide and pledge to manage this information responsibly and with the highest standard of care, ensuring its processing consistently adheres to the requirements of relevant laws and regulations. This policy details our routine data handling procedures throughout your entire engagement with the RPAX Loan services, including but not limited to registration, application, usage, and for a reasonable period thereafter. Your act of accessing, downloading, registering an account, or using the RPAX Loan application and related services in any manner constitutes your full reading, understanding, and unconditional acceptance of all terms contained in this Privacy Policy, including our collection, use, processing, storage, and potential sharing of your information as described herein. If you do not agree with any part of this policy, please cease using the App and related services immediately. Your continued use of the App will be deemed as your ongoing acceptance and acknowledgment of this policy's content, including any updated versions.

A. Information We Collect

To provide, manage, and optimize our loan products and related services, conduct necessary credit assessments and risk management, fulfill our contractual obligations to you, comply with applicable laws and regulatory requirements, and maintain the security and integrity of our services, we will, under the principles of legality, legitimacy, and necessity, collect the following categories of information through various means. These include information you actively provide, information automatically collected during your use of our services, and information obtained from third parties with your authorization or as permitted by law. The scope of information collection is strictly limited to the minimum necessary for achieving the aforementioned purposes.

1. Personal Identification Details

This refers to information that can directly identify you as an individual, either alone or in combination with other information, and forms the basis for establishing your personal account and identity verification.

• Your complete legal name (including surname, first name, and middle name).
• Specific details of your government-issued identification documents, such as type, document number, and validity period.
• Your date of birth and place of birth.
• Your age and gender.
• Your marital status.
• Your educational background and history, such as your highest educational attainment and name of graduating institution.
• Religious belief information (collected only if you voluntarily choose to disclose it for a specific purpose).
• Your complete home address, including house number, street, barangay, city/municipality, and province, used for contact and address verification.

2. Camera and Media

We respectfully request permission to access your device's camera and photo library. This access is required solely to enable the essential function within our App that allows you to directly capture new photos or select and upload existing images from your gallery. This functionality is specifically designed for you to conveniently submit the necessary supporting documents required for your loan application.

We solemnly declare and guarantee that our access will be strictly limited to this specific purpose. Apart from the exact image files you actively choose and confirm for upload through the App's interface, we will not browse, access, retrieve, or transfer any other content, photos, or data from your device's photo library or other storage areas. We implement strict technical and operational controls to ensure this boundary is respected. Your privacy is of paramount importance, and we are committed to handling your data with the highest level of security and responsibility throughout the application process.

3. Device Information

When you interact with our App, to ensure normal service operation, optimize App performance, analyze usage trends, diagnose and resolve technical issues, and maintain service security, we automatically collect certain technical information related to your device and network connection.

• Device name and model
• Language and regional preferences
• Operating system and browser version
• IP address

4. Financial and Employment Data

• Bank account and e-wallet information
• Employment details, including employer name and contact information
• Monthly income, sources of income, and salary schedule

5. Biometric Information

To reinforce security protocols and effectively mitigate fraud risks, our platform employs secure facial recognition technology for identity verification. As part of the standard application procedure, you will be guided to submit a live, real-time photograph.

This biometric data is utilized exclusively for three defined security purposes: to conclusively verify that you are the legitimate applicant; to enable potential future authentication if required for account servicing; and to aid our systems in detecting and preventing fraudulent applications.

We strictly process and protect your facial biometric data using industry-standard security measures. This information is dedicated solely to the verification functions stated above and is handled in full compliance with applicable data privacy regulations to safeguard your personal information.

6. SIM Number

Access to your SIM card's phone number is required to enable login/sign-up and verification code services.

B. Purposes for Data Processing

We collect and process your personal information based on specific, explicit, and legitimate purposes. Our processing activities typically rely on the following legal bases: necessity for the performance of a contract with you (e.g., assessing and disbursing a loan), necessity for compliance with a legal obligation to which we are subject, necessity for the purposes of our or a third party's legitimate interests (e.g., fraud prevention, network security, service improvement) provided those interests are not overridden by your data protection rights, and, where appropriate, your freely given, specific, informed, and unambiguous consent. The primary purposes for which we process your information include, but are not limited to:

• Loan Application Assessment: To evaluate your creditworthiness and eligibility for loan products through credit scoring, background checks, and data analysis. This includes sharing data with authorized partners to process your application.
• Customer Assistance & Dispute Management: To address your inquiries, complaints, or disputes and provide tailored support based on your service interactions.
• Service Improvement & Communications: To send you notifications regarding loan status, payment reminders, promotional offers, and updates about policy, term, or service changes.
• Legal Compliance & Fraud Prevention: To fulfill legal and regulatory obligations and to identify, deter, and prevent fraudulent or unauthorized activities.
• Third-Party Service Integrations:

Advance.AI: Conducts biometric authentication via facial recognition. Data collected: Live selfie images, photos of government IDs (when submitted).

Alibaba Cloud: Provides encrypted cloud storage for verification documents. Data collected: User-uploaded images, temporary session tokens.

All integrations are subject to privacy compliance reviews, with data collection limited to specified purposes and conducted only upon obtaining your explicit consent per applicable regulations.

C. Your Data Management Rights

• Account Deletion: You can request the deletion of your account, subject to legal and regulatory requirements that may necessitate retaining certain data.
• Provision Choice: This Privacy Policy itself is intended to safeguard your right to be informed. You have the choice not to provide certain information; however, please note this may prevent us from providing you with the full scope of our services, as some information is a necessary prerequisite for loan assessment, contract performance, and legal compliance.

D. Sharing of Information with Third Parties

We do not sell, rent, or trade your personal information to third parties for their own commercial marketing purposes. We may share your information with third parties only in the following limited circumstances and with appropriate security safeguards in place:

• Credit Bureaus & Financial Entities: For credit assessment, loan processing, and reporting credit performance as required by regulations, we may share necessary information with licensed credit bureaus, other financial institutions, or information verification service providers when required.
• Service Providers & Partners: We engage trusted third-party vendors, consultants, and partners to provide critical services on our behalf under strict confidentiality and data processing agreements. These services encompass data analytics, payment processing, SMS/notification delivery, customer support, identity verification, and fraud prevention. Such third parties may access and use your information only to the extent necessary to perform their contractual duties and are bound by confidentiality and security obligations no less stringent than those described in this policy.
• Legal & Regulatory Authorities: We may disclose your information when compelled to do so by laws, regulations, subpoenas, court orders, or other legally binding governmental or regulatory requirements to comply with such legal processes or regulatory demands. We may also disclose information, in good faith, when we believe it is necessary to investigate suspected illegal activities, enforce our Terms of Service, respond to security threats, or protect the rights, property, or safety of ourselves, our users, or the public.

E. Our Data Security Commitments

We fully recognize the importance of data security and are committed to implementing robust, industry-standard physical, technical, and organizational security measures to protect your personal information against unauthorized access, use, alteration, disclosure, loss, or destruction. Our comprehensive security framework includes, but is not limited to:

• Encryption of sensitive data during transmission and storage.
• Stringent access controls and multi-factor authentication for authorized personnel.
• Regular security assessments and audits to ensure ongoing compliance.
• A multi-layered security framework encompassing advanced technology, organizational policies (like mandatory staff training), and physical safeguards for data centers.
• Please note that no security system is infallible. We encourage you to protect your account credentials and promptly report any suspicious activity.

Data Retention Period: We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, or as required or permitted by laws and regulations.Specifically, data used for identity verification, loan assessment, and risk control may be retained for up to 5 years after the termination of our business relationship with you, in accordance with regulatory requirements and anti-fraud needs.Data used for marketing and behavioral analysis will be retained for no more than 2 years from the date of collection or deleted immediately upon your withdrawal of consent.Upon the expiration of the retention period or upon your valid request (subject to compliance with legal obligations), we will delete your personal information in a secure manner or anonymize it so that it can no longer be used to identify an individual.

F. Policy Updates

We reserve the right to revise or update this Privacy Policy from time to time to reflect the evolution of our services, changes in technical practices, updates to laws and regulations, or new measures taken to enhance security. We will notify you of material changes to this policy by posting the updated version within the RPAX Loan App, sending push notifications (where applicable), or through other means we deem appropriate. The updated policy will indicate the new effective date upon publication. We advise you to review this policy periodically to stay informed of its latest content. Your continued use of our services after any such updates constitutes your acceptance of the revised policy.

G.For users 18 years and older

Our services are intended for users who are at least 18 years of age. We do not knowingly collect personal information from individuals under this age. If you are under the required age, please do not register for or use our services. If we become aware that we have collected personal information from a minor without verification of parental consent, we will take steps to delete such information. Parents or guardians who believe we may have collected a minor's information are encouraged to contact us.

H. Contact Information

If you have any questions, concerns, or suggestions regarding the content of this Privacy Policy, or if you wish to exercise your data subject rights or have any requests concerning the processing of your personal information, please contact us at:

Email: juliusceasar@rpaxfund.com

Address:

Unit(B-E) Lot 253-A-6, L&M Subdivision, Rosal Street Market Area (Pob.), Sta. Rosa, Laguna, 4026 Philippines