Last updated: May 17, 2023
"Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number, and contact information.
This Policy applies in conjunction with other notices, contractual clauses, and consent clauses that apply in relation to the collection, storage, use, disclosure, and/or processing of your personal data by us and are not intended to override those notices or clauses unless we state expressly otherwise.
WHEN WILL CLFC COLLECT PERSONAL DATA?
- We will/may collect personal data about you:
- when you register and/or use our Website.
- when we perform Know Your Customer ("KYC") checks/procedures upon availing of our services as part of customer due diligence and for continuing customer due diligence;
- when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
- when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms, and emails, including when you interact with our customer service agents;
- when you use our electronic services or interact with us via our application or use services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
- when you grant permissions on your device to share information with our website;
- when you provide us with feedback or complaints;
- when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
WHAT PERSONAL DATA WILL CLFC COLLECT?
- The personal data that CLFC may collect includes but is not limited to:
- complete name;
- email address;
- date of birth;
- present and or permanent address;
- bank account and payment information;
- telephone or mobile number;
- source of income
- proof of income
- information sent by or associated with the device(s) used to access our Services
- information about your network and the people and accounts you interact with;
- photographs or audio or video recordings that you share with us, including any customer self-portrait (selfie) and scan;
- government-issued identification or other information required for our due diligence, know your customer, identity verification, or fraud prevention purposes;
- marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;
- usage and transaction data, including details about your searches, orders, the advertising, and content you interact with on the Platform, and other products and services related to you;
- Location data
COLLECTION OF OTHER DATA
As with most websites, your device sends information which may include personal data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device's Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.
Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location with other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.
We or our authorized service providers may from time to time use "cookies" or other features to allow us or third parties to collect or share information in connection with your use of our Website. These features help us improve our Website and the Services we offer, or help us offer new services and features, and/or enable us to serve more relevant content to you, including through remarketing. "Cookies" are identifiers that are stored on your computer or mobile device that record data about the computer or device, how and when the Services or Website are used or visited, by how many people and other activity within our Website. We may link cookie information to personal data. This information is used to keep track of your Website activities, deliver content specific to your interests, and conduct data analysis and monitor the usage of the Services.
CUSTOMER SERVICE & SUPPORT
We provide customer service support through Messenger, email, SMS, and feedback forms. In order to provide customer support, we will ask for your email address and mobile phone number. We only use the information received from customer support requests, including, without limitation, email addresses, for customer support services and we do not transfer to or share this information with any third parties.
From time to time, we may request information from Users via surveys. Participation in these surveys is completely voluntary and you, therefore, have a choice whether or not to disclose your information to us. Information requested may include, without limitation, contact information (such as your email address), and demographic information (such as interests or age level). Survey information will be used for the purposes of monitoring or improving the use and satisfaction of the Services and will not be transferred to third parties, other than our contractors who help us to administer or act upon the survey.
HOW DO WE USE THE INFORMATION YOU PROVIDE US?
- We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
- to consider and/or process your application/transaction with us;
- to manage, operate, provide and/or administer your use of and/or access to our Website, as well as your relationship and user account with us;
- to enforce our Terms of Service or any applicable end user license agreements;
- to protect personal safety and the rights, property or safety of others;
- for identification and/or verification, due diligence, or know your customer purposes;
- to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- to conduct research, analysis and development activities (including, but not limited data analytics, surveys, product and service development and/or profiling), to analyze how you use our Services, to improve our Services or products and/or to enhance your customer experience; (o) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Website Services;
- to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on PJLI and affiliates;
- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- to prevent or investigate any actual or suspected violations of our Terms and Conditions, fraud, unlawful activity, omission, or misconduct, whether relating to your use of our Website or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
- to store, host, and back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
- to prevent fraudulent conduct of behavior that contravenes local and international sanctions and/or to comply with regulations against money laundering, terrorism financing, and tax fraud;
- any other purposes which we notify you of at the time of obtaining your consent.
- As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purposes at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
HOW DO WE PROTECT AND RETAIN CUSTOMER INFORMATION?
- We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can be no guarantee of absolute security.
DO WE DISCLOSE THE INFORMATION WE COLLECT FROM VISITORS TO OUTSIDE PARTIES?
- In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
- our subsidiaries, affiliates, related corporations, and other third-party partners;
- contractors, agents, service providers, and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, and data centers;
- governmental or regulatory authorities;
OUR COMMITMENT TO CHILDREN'S ONLINE PRIVACY
PJLI and Affiliates does not collect personal data from minors. If you are a minor, please do not use our Services. In the event that any personal data has been provided to us by minors, their parents/legal guardians may request the removal of such data.
HOW CAN YOU OPT-OUT, REMOVE, REQUEST ACCESS TO OR CORRECT INFORMATION YOUHAVE PROVIDED TO US?
- Requesting Access and/or Correction of Personal Data
- If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Site. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Data Protection Officer at [email protected]
- We will/may also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
- We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organization to refuse to correct personal data in stated circumstances.
YOUR RIGHT AS A DATA SUBJECT
As a data subject you have the right to be informed, to object, to access, to rectify, to erasure or blocking, to damages, to data portability and to complain in relation to your personal information under the Data Privacy Act. You may thus, as appropriate, opt to tell us not to send you marketing materials, not to share your information, to provide you with information we have about you, to update you information, or any other concerns regarding the processing of your personal data.
By Email: [email protected]
Should you wish to exercise any of your rights as data subject or in case of inquiries regarding your personal data, you may reach out to our Data Protection Officer in the contact details below:
The Data Protection Officer
PJL Corporate Center 1782 Candelaria Corner Nicanor Garcia Street,
Email: [email protected]