TrustIQ Privacy Policy

Updated last July 18, 2024

Introduction

Trust IQ Pte. Ltd. (hereinafter referred to as “TrustIQ”, “Company”, “We” or “Us”), with its headquarters in Singapore and operations across India, the Philippines, Indonesia, and Vietnam, is committed to complying with the applicable data privacy and security requirements in the countries in which it operates. We adhere to internationally recognized standards of privacy protection, including, but not limited to, the EU General Data Protection Regulation (GDPR). This Privacy Policy applies when providing software and services ("Services") to You and when you access or use our website (hereinafter referred to as the “Platform”). We respect and value Your Individual Customer’s privacy and we employ reasonable measures to protect Your Individual Customer’s personal information in accordance with the Philippine Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and related issuances from the National Privacy Commission (“Commission”).


Please refer to our separate privacy policies regarding the specific situation and/or market, including our Cookie Policy, Candidate Personal Data Consent Form (English/Vietnamese), Vietnam Data Privacy Notice (English/Vietnamese), and issue specific policies.

Definitions

The following words and terms shall have the meanings set forth below, unless repugnant to the context and/or otherwise mentioned:

“You”“User” or “Financial Services Provider” shall mean a bank or a lending company or a business entity duly licensed by the Bangko Sentral ng Pilipinas or by the Securities and Exchange Commission to engage in the business of lending money to third persons, or engaged in the business of aggregating financial services made available by several Financial Services Providers, or engaged in delivery of fintech-related services and is a client or potential client of the Company.

“Company” / “We” or “Us” shall mean Trusting Social AI Philippines, Inc. and includes its successor and assigns.

“Commission” shall mean the National Privacy Commission of the Republic of the Philippines.

“Person” includes any individual, partnership, corporation, company, society, unincorporated organization or association, joint venture company, joint stock company, trust or other entity, whether incorporated or not.

 “Individual Customer/s” means the individual Person who is a potential or current client, borrower, depositor, credit cardholder or financial customer of a Financial Services Provider.

Information We Collect

When you use our Platform, we collect and store several different types of information for various purposes to provide and improve our Platform to you.

We collect the following categories of personal data:

  • Contact Information: We collect information about Individual Customers/ data subjects such as name and contact details (email, phone number, etc.) to communicate and facilitate the provision of our services for You.
  • Services Data: You may provide us with Personal data of Your Individual Clients to the extent required to provide You the Services. At your direction, we may also acquire personal data of Individual Clients  from a third party as required to perform services.
  • Marketing Information: We collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.
  • Website Visitor Information: When you visit our website, we may collect information about your visit such as your IP address and the pages you visited. Please see our Cookie Policy for additional information.


You and other third parties who provide personal information of Individual Customers to TrustIQ must do so in compliance with applicable data privacy regulations, including without limitation  the DPA, its Implementing Rules and Regulations, and related issuances from the Commission. 


Processing of Personal Data

We collect personal data of Individual Customers to offer and administer our services and products. The personal data of Individual Customers that you provide to us will be processed in accordance with the purposes specified in this notice, including but not limited to:

  • Compliance with Legal Obligations: We process personal data to comply with obligations provided by laws, current regulations, and legislation, such as tax regulations and anti-money laundering regulations.
  • Contractual Necessity: We process personal data where it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
  • Legitimate Business Interests: We process personal data for our legitimate business interests, which include providing the products or services requested by you and individuals pursuant to a letter of engagement, statement of work, or similar.
  • Consent: TrustIQ also processes your data and personal data of Individual Customers for specified purposes provided that You have secured the informed, explicit and recorded consent of Your Individual Customer, where such purposes will be clearly provided at the time You secure such consent from the Your Individual Customers.


We collect Your and Your Individual Customer’s data from the documents and information that you may have directly submitted to us, information from third party databases such as telecommunication network partners, credit bureaus and customer service providers.

Where you have provided us with the personal data of Your Individual Customer and other individuals, you warrant that you have obtained their informed and express consent to such disclosure, in accordance with the DPA,  its Implementing Rules and Regulations, and related issuances from the Commission.

Your Individual Customer’s personal data may be processed both by way of computer media, in compliance with the rules in relation to personal data protection, therein including those relating to data security.

Personal Information Controller/ Processor

The Company is the Personal Information Processor under the DPA. You are the Personal Information Controller under the DPA which means that You determine what purposes personal information you will hold will be used for. It may also be that Your Individual Customer’s personal information is disclosed to third parties pursuant to a data sharing agreement. In which case, such third parties are also the personal information controllers of Your Individual Customer’s personal information.

Transfers and Disclosures

The Company will take all steps reasonably necessary to ensure that your data and Your Individual Customer’s personal information are treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data and Your Individual Customer’s personal information 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.

Your personal information and Your Individual Customer’s personal information may be disclosed to the Company’s partners and third parties for the following purposes:

To provide you with Services; To ensure that the provided information is accurate by verifying information with third parties; To communicate with you alerts, notifications, follow-ups, and recommendations; To conduct credit checking and/or to perform data analytics on the propensity of an Individual Customer user to pay off credit products, and such other related analytics; To conduct initial Know-Your-Customer services for the Financial Services Providers pursuant to agreements with such parties; To connect you with our partners on the Platform; To monitor the usage of the Platform; To provide and maintain the Platform; To provide customer care and support; To detect, prevent and address technical issues; To provide analysis or valuable information so that we can improve the Platform; To store and save customer data to improve our services; To monitor, detect and prevent fraud or abuse of the Credit Insight Services; To establish, exercise, or defend legal claims; To fulfill any other purposes directly related to the above-stated purposes.


Marketing Communications

If you are located in regions with specific data protection laws, we will only send you marketing communications with your prior consent or based on our legitimate interests where permitted. You can withdraw your consent or opt-out of receiving such communications at any time.

If you are not located in such regions, you may opt-out of receiving marketing communications at any time.

You can manage your receipt of marketing and non-transactional communications by clicking on the "unsubscribe" link located on the bottom of TrustIQ's marketing emails. Additionally, you may send a request to [email protected]

Storage of Personal Data

Your personal data and Your Individual Customer’s personal information will be retained or stored for as long as the purposes for which they are being processed have not been satisfied. The Company will retain and use your personal information and Your Individual Customer’s personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

Disclosure/Sharing of Personal Data

We share personal data with affiliates and subsidiaries, and with external third parties such as vendors and service providers who perform services on our behalf. 


The Company may also transfer your personal information to third parties as required by law or legal instrument, to protect the Company’s rights or assets, to facilitate acquisition or disposition of the Company’s businesses, and in emergencies where the health or safety of a person is endangered.

The following are the third parties to whom your personal data may be disclosed in accordance with the above-mentioned purposes:

Third-Party Partners, Telecommunication network partners (e.g., Globe, PLDT, Smart, Sun Cellular) Legal Counsel, Government Agencies, stockholders and business partners, law enforcement agencies, government regulatory agencies and offices.


Cross-Border Transfers of Personal Data

TrustIQ operates globally, and personal information may be transferred, accessed, and stored globally as necessary for the uses stated above and in compliance with local regulations.

Cross-Border Transfers of Personal Data

Trusting Social operates globally, and personal information may be transferred, accessed, and stored globally as necessary for the uses stated above and in compliance with local regulations.

Rights of Data Subjects

Under the DPA, it is possible for individuals to request access to any of their personal data held by the Company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer.

The DPA requires the Company to take reasonable steps to ensure that any personal data it processes is accurate and up-to-date. It is your responsibility to inform us of any changes to the personal information that you have supplied to us during the course of your engagement.

Your Individual Customers have the right to object to the processing of their personal information, including processing for direct marketing, automated processing, or profiling. You shall also be notified so that Your Individual Customers shall be given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to you in this Privacy Policy. Please note that some of the personal data you have provided to us is necessary for us to comply with statutory and regulatory requirements, as well as the Company’s administrative policies and is thus mandatorily required to be collected and processed. Withholding of your consent to the processing of certain personal data may prevent you from availing of certain benefits.

Your Individual Customers have the right to suspend, withdraw or order the blocking, removal or destruction of their personal information from our filing system.

Your Individual Customers have the right 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.

Upon presentation of a valid decision, the Company recognizes Your Individual Customer’s 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.

Your Individual Customers are also granted the right to lodge a complaint before the Commission.


Providing Information to TrustIQ

Choosing not to provide certain personal information may limit our ability to provide you with our services or respond to your inquiries.


Contact Us

For questions, concerns, or complaints regarding our Privacy Policy, please contact us via email at [email protected] for a timely response.


Updates to This Policy

We may update our Privacy Policy from time to time to reflect changes to our data processing practices, changes in legal or regulatory requirements, or for other operational reasons. Any changes will be posted on this page, and if significant, we will provide a more prominent notice. Please review this policy periodically to stay informed about how we are protecting your personal data.

Forms


This Privacy Policy applies to all aspects of our operations, including our website and all other places where we interact with clients, candidates, customers, and website visitors. We are committed to protecting your privacy, maintaining your trust, and providing transparency about our data practices.

Validity of Consent

By availing of the Services, You give your express consent to the above and, with regard to TrustIQ’s processing of Your Individual Customer’s Personal Information, You represent and warrant that you have obtained their informed, express and recorded consent to such disclosure to and processing by TrustIQ, in accordance with the DPA,  its Implementing Rules and Regulations, and related issuances from the Commission.

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