For Website and Mobile Apps
HC Consumer Finance Philippines, Inc. (“Home Credit Philippines”) respects the privacy of our customers and users of our online platforms such as this website and our mobile applications. We strive to embed privacy in all of our processes in compliance with Republic Act No. 10173 also known as the Data Privacy Act of 2012, its implementing rules and regulations, and other issuances of the National Privacy Commission.
We recognize the importance of protecting your personal information as well as the importance of transparency in the way that we collect, use, store, transfer/disclose, and dispose information derived from your use of our products, services, online portals, and mobile applications.
Personally Identifiable Information
“Personally identifiable information” is information that can be used to uniquely identify an individual such as name, password, age, civil status, gender, mailing address, email address, telephone number, mobile number, and other personal details. We also consider personal information and sensitive personal information as defined under the Data Privacy Act of 2012 as personally identifiable information.
Collection of Information
We collect personally identifiable information when you apply for our services, and when you register an account on our mobile applications and online platforms. You may be asked to provide us with personally identifiable information through our website, our mobile apps, through our Point of Sale devices or through paper application forms.
With your consent, Home Credit Philippines may collect your name, mobile number and email address connected to Facebook and Gmail. External websites and companies with hyperlinks to and from Home Credit Philippines’ online platforms may collect personally identifiable information about you when you visit their websites. This privacy notice does not extend to those external websites and companies. Please refer directly to their privacy notice regarding their handling of your personally identifiable information.
Use of personally identifiable information
The personally identifiable information you share will be used according to the contracts that you execute with us for our services. In relation to those contracts, we use the personally identifiable information for credit verification, credit scoring, automated processing of the loan applications, and loans collection.
Home Credit Philippines may use your personally identifiable information to send you information about Home Credit Philippines, including news about product updates, events, and other promotional materials, but only if you agree to receive such communications. Home Credit Philippines will not share any personally identifiable information with third parties for marketing purposes without your consent.
Home Credit Philippines may use personally identifiable information for data analytics, data profiling and other legitimate interests, which will help us understand your needs and to help us improve our services.
Storage and Security of Personally Identifiable Information
Personally identifiable information provided to Home Credit Philippines are stored in a secure database under our control. We have taken reasonable and appropriate steps to protect the information you share with us, including, but not limited to, physical and technical security controls, equipment, and software to prevent unauthorized access, use or disclosure of personally identifiable information.
We retain your personally identifiable information only for the reasonable period necessary for us to deliver our services, to meet legitimate business purposes, and to comply with retention periods provided by other laws governing Home Credit.
Disclosure and Transfers of Personally Identifiable Information
Home Credit Philippines does not share any personally identifiable information with other parties except as described in this notice and in the Applicant Consent Form (ACF) signed by customers. As mentioned in your ACF, we may share your information with our partners such as government agencies, partner stores, utility companies, remittance companies, insurance providers, financial service providers, courier service providers, order or payment processors, merchandise warehouse and fulfillment services and other services providers, but only to the extent necessary to provide the services you signed up for.
Home Credit Philippines may release personally identifiable information to comply with court orders or laws that require us to disclose such information. In the event of a reorganization, sale or merger, we may transfer personally identifiable information to the relevant third party with users’ consent if required by law.
Home Credit Philippines may share anonymous data, aggregated or not, with third parties. We ensure that such anonymous data does not allow the identification of customers and users to which they relate.
Persons under the Age of 18
Home Credit Philippines will not knowingly collect personally identifiable information from any person under the age of 18. Home Credit Philippines encourages parents to instruct their children to never give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us.
Cookies and Other Information on a User’s Machine
Home Credit Philippines’ products, services, sites and mobile apps may employ cookies and other similar and applicable technologies. We may use third party website analytic tools that employ cookies to collect certain non-personally identifiable information concerning use of our websites, such as referring web site addresses, page views and browser types.
Mobile App Permissions
The Home Credit mobile application may request that you activate permissions including but not limited to location, emails, messages, phone calls, calendar and contacts. The general description of the mobile app’s behavior can be referenced through the permissions module of your mobile phone. The processing of personal information and metadata by the mobile application is consistent with what we explained in this privacy notice.
Data Subject Rights
Under the Data Privacy Act, you have the right to be informed, the right to object, the right to access, the right to rectification, the right to erasure or blocking, the right to damages and the right to file a complaint. If you wish to exercise any of these rights, you may contact us at (02) 753 5711. We may decline requests that are excessively repetitive, require disproportionate technical effort, jeopardize the privacy of others, or are extremely impractical or unreasonable.
Contact Home Credit Philippines’s Data Protection Officer (DPO)
Home Credit Philippines’ Data Protection Officer provides support for any data privacy related inquiries or complaints. You may contact Home Credit Philippines’ DPO through the following information:
Office Address: 16/F Ore Central Bldg., 31st Street, Taguig City, Philippines
Email address: email@example.com
Individuals with inquiries or complaints regarding our privacy practices should first contact our DPO. Our DPO will always use reasonable efforts to address and settle any requests or complaints brought to our attention.
PLEASE READ CAREFULLY.
Section 1. Notice to Vendors by Home Credit Philippines (“Home Credit Philippines”)
Vendor/ Supplier/ Partner Record Defined
A Vendor/ Supplier/ Partner record is a record of personal data, either in conventional or electronic format, relating to the engagement with a vendor. The record comprises of, but is not limited to, information about the Vendor’s contact person’s information such as full name, work address, work telephone number, work mobile phone number, work fax number, and work email address. Our Vendor’s records are confidential and kept in locked storage.
1.1 What are your Data Privacy Information Rights?
- Right of access to and rectification or erasure of personal data, restriction of processing, right to object to processing. Data subjects have the right to:
a. Obtain from Home Credit Philippines confirmation as to whether or not personal data concerning the Vendor Contact are being processed, and where that is the case, access to the personal data;
b. Obtain from Home Credit Philippines the rectification of inaccurate personal data;
c. Obtain from Home Credit Philippines the erasure of Vendor Contact’s personal data;
d. Obtain from Home Credit Philippines restriction of processing regarding the Vendor Contact’s personal data;
e. Obtain from Home Credit Philippines a copy of personal data, which the Vendor Contact actively provided, in a structured, commonly used, and readable format and to request Home Credit Philippines to transmit those data to another recipient selected by the Vendor Contact; and
f. Object, on grounds relating to the Vendor Contact’s particular situation, to processing of personal data.
- Right to Amend or Supplement. You have a right to request that we amend your personal data that you believe is incorrect or incomplete. You must make a request to amend in writing, and include the reasons you believe the information is inaccurate or incomplete. We may deny your request if we do not have the information, if we did not create the information, if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. If we deny your request, you may submit a written explanation of your disagreement with that decision, and we may, in turn, prepare a written rebuttal. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.
- Right to withdraw consent. In case a Vendor Contact has previously declared its consent for the processing of certain personal data by Home Credit Philippines, the Vendor Contact retains the right to withdraw the consent at any time with future effect. In case consent is withdrawn, Home Credit Philippines may only further process the personal data where there is another legal ground for the processing.
- Right to Erasure or Blocking. You have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data. You can exercise this right upon discovery and substantial proof of any of the following:
a. Your personal information is incomplete, outdated, false, or unlawfully obtained.
b. It is being used for purposes you did not authorize.
c. The data is no longer necessary for the purposes for which they were collected.
d. You decided to withdraw consent, or you object to the processing and there is no overriding legal ground for processing.
e. The data concerns information prejudicial to the Vendor Contact — unless justified by freedom of speech, of expression, or of the press; or otherwise authorized (by court of law).
f. The processing is unlawful.
g. Home Credit Philippines, or its personal information processor/s, violated your rights a vendor.
- 5. Right to Be Notified of a Breach. You have the right to receive notifications of breaches of your personal data, as may be required by law. Aside from protecting you against unfair means of personal data collection, this right also requires Home Credit Philippines to notify you if your data have been compromised. If you have provided us with a current e-mail address, we may use e-mail to communicate information related to the breach.
- Right to a Paper or Electronic Copy of this Notice. You have a right to be notified of our legal duties and privacy practices with respect to your personal data, including a right to a paper copy of this Privacy Notice, even if you have previously requested its receipt by e-mail.
- If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, please contact our Data Privacy Officer listed in Section 3 of this Privacy Notice.
1.2 Purposes of Collection, Categories of Personal Information, Transfer and Disclosure, Retention Periods, and Disposal.
In the context of the business relationship with Home Credit Philippines, Home Credit Philippines may processes personal data for the following purposes:
- Communicating with Vendors about products, services, and projects of Home Credit Philippines or its other Vendors, e.g., by responding to inquiries or requests;
- Planning, performing, and managing the (contractual) relationship with Vendors; e.g., by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing, and collection activities, arranging shipments and deliveries, and providing support services;
- Administering and performing surveys, marketing campaigns, market analysis, or other promotional activities or events;
- Ensuring compliance with data privacy and other legal obligations, Vendor compliance screening obligations, and Home Credit Philippines policies or industry standards; and
- Solving disputes, enforcing our contractual agreements, and establishing, exercising or defending legal claims.
Categories of personal data processed
For the aforementioned purposes, Home Credit Philippines may process the following categories of personal data:
- Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number, and work email address;
- Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers, and other related billing information;
- Further information necessarily processed in a project or contractual relationship with Home Credit Philippines or voluntarily provided by the Vendor Contact (which may contain personal information), such as those included in orders placed, payments made, requests, and project milestones;
- Information collected from publicly available resources (websites), and if reasonably required for Vendor compliance screenings (set by industry or company), information about relevant and significant litigation or other legal proceedings against Vendors.
The processing of personal data is necessary to meet the aforementioned purposes including the performance of the respective (contractual) relationship with Vendors.
Transfer and disclosure of personal data
Home Credit Philippines may transfer personal data to other entities, but only if and to the extent such transfer is strictly required for the purposes mentioned above. If legally permitted to do so, Home Credit Philippines may transfer personal data to courts, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of legal claims. Home Credit Philippines commissions’ service providers (so-called data processors) which only act upon instructions of Home Credit Philippines and are contractually bound to act in compliance with applicable data privacy laws and regulations.
Unless explicitly indicated otherwise at the time of the collection of Vendor Contact’s personal data (e.g., within a consent form accepted by Vendor Contact), we erase personal data if the retention of the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed and no statutory retention obligations under applicable law (such as tax or commercial law) require us to further retain personal data.
Section 2. Updates on Privacy Notice
2.1 Updates to this Privacy Notice. Home Credit Philippines reserves the right to amend this Privacy Notice at any time in the future. After an amendment is made, the revised Privacy Notice will apply to all personal data that we maintain, regardless of when it was created or received. We will keep a copy of the current Privacy Notice posted in our website and a copy will also be made readily available to you, upon your request.
Section 3. Contact Home Credit Philippines’s Data Privacy Officer
3.1 Contact us. Home Credit Philippines’s Data Privacy Officer provides support with any data privacy related questions, comments, concerns or complaints. You may contact Home Credit Philippines’s Data Privacy Officer through the following information:
Home Credit Philippines Office, 15/F Ore Central Bldg., 31st Street, Taguig City, Philippines
Email address: firstname.lastname@example.org
Home Credit Philippines’s Data Privacy Officer will always use best efforts to address and settle any requests or complaints brought to its attention. In addition, you may also approach the competent data protection authority for any requests or complaints.
PLEASE READ CAREFULLY.
This Notice shall be applicable to Customers and Reference Persons by HC Consumer Finance Philippines, Inc. (“Home Credit Philippines”)
1. What are your Data Privacy Information Rights?
You have the following rights regarding your personal data:
- 1.1 Right to Request Special Privacy Protections. You have the right to request restrictions on certain uses and disclosures of your personal data by a written request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information, we will abide by your request, unless we must disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request, and will notify you of our decision.
- 1.2 Right to Inspect and Copy. You have the right to inspect and copy your personal data, with limited exceptions. To access your personal data, you must submit a written request detailing what information you want access to, whether you want to inspect it or get a copy of it, and if you want a copy, your preferred form and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable, or if we can’t agree and we maintain the record in an electronic format, your choice of a readable electronic or hard copy format. We will also send a copy to any other person you designate in writing. We will charge a reasonable fee which covers our costs for labor, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary. We may deny your request under limited circumstances. If we deny your request to access your personal records or the personal records of an individual you are representing because we believe allowing access would be reasonably likely to cause substantial harm to the customer, you will have a right to appeal our decision.
- 1.3 Right to Request Confidential Communications. You have the right to request that you receive your personal data in a specific way or at a specific location. You may ask that we send information to a particular e-mail account or to your work address. We will comply with all reasonable requests submitted in writing which specify how or where you wish to receive these communications.
- 1.4 Right to Amend or Supplement. You have a right to request that we amend your personal data that you believe is incorrect or incomplete. You must make a request to amend in writing, and include the reasons you believe the information is inaccurate or incomplete. We may deny your request if we do not have the information, if we did not create the information, if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.
- 1.5 Right to Revoke Authorization. Your consent is necessary before Home Credit Philippines can lawfully collect and process your personal data.You may revoke (take back) your consent at any time. For the avoidance of doubt, this does not invalidate any previous processing that Home Credit Philippines has performed in accordance with consent originally given.
- 1.6 Right to Erasure or Blocking. You have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data. You can exercise this right upon discovery and substantial proof of any of the following:
- Your personal data is incomplete, outdated, false, or unlawfully obtained.
- It is being used for purposes you did not authorize.
- The data is no longer necessary for the purposes for which they were collected.
- You decided to withdraw consent, or you object to the processing and there is no overriding legal ground for processing.
- The data concerns information prejudicial to the customer — unless justified by freedom of speech, of expression, or of the press; or otherwise authorized by law.
- The processing is unlawful.
- Home Credit Philippines, or its personal information processor/s, violated your rights as a customer.
- 1.7 Right to Be Notified of a Breach. You have the right to receive notifications of breaches of your personal data, as may be required by law. Aside from protecting you against unfair means of personal data collection, this right also requires Home Credit Philippines to notify you in a timely manner if your personal data has been compromised. If you have provided us with a current e-mail address, we may use e-mail to communicate information related to the breach.
- 1.8 Right to a Paper or Electronic Copy of this Notice. You have a right to be notified of our legal duties and privacy practices with respect to your personal data, including a right to a paper copy of this Privacy Notice, even if you have previously requested its receipt by e-mail.
If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, please contact our Data Protection Officer listed in Section 3 of this Privacy Notice.
2. How Home Credit Philippines Collects, Use, Transfer or Disclose, Retain, and Dispose Your Personal Data?
Home Credit Philippines collects personal information about you and stores it in a computer and in an electronic record. To the extent reasonably necessary to effect the relevant purpose, we may use or disclose your personal data for the following:
- 2.1 Payment. We use and disclose personal information about you to other providers under or in partnership with Home Credit Philippines, with an affiliate company or parent company and other vendors to obtain payment for the services we have provided.
- 2.2 Payment Reminders. We may use and disclose your personal data to contact and remind you about due payments. If you are not home, we may leave this information on your answering machine or in a message left with the person answering the phone.
- 2.3 Research. Your personal information may be used and disclosed for research purposes; provided, that it is approved through a special review process to protect customer confidentiality. A researcher may have access to information that identifies you only through the special review process, or with your written consent. Your personal records may be used for data analytics to create customer demographics and trends; however, these reports are generated in such a way that customer identities are anonymized.
- 2.4 Marketing. We may use your contact details to communicate with you and give you information about products, promotions or services related to your loan applications or other services provided by Home Credit Philippines, with an affiliate company or parent company and other business vendors that may be of interest to you.We may also contact you to ensure customer satisfaction regarding services provided, including identification of your concerns so that addressing of issues are assured.
- 2.5 Required by Law. As required by law, we will use and disclose your personal data, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirement set forth below concerning those activities. We may disclose your personal data to an oversight facility for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure.
- 2.6 Law Enforcement. We may, and are sometimes required by law to, disclose your personal data to a law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness or missing person, complying with a court order, warrant, subpoena and other law enforcement purposes.
- 2.7 Other Uses and Disclosures: If Home Credit Philippines wants to use or disclose your personal data for a purpose that is not discussed in this Privacy Notice, Home Credit Philippines will ask for your written consent.
For Reference Persons:
- Additional Information. We may contact you to ask for additional information about our customer who named you as his/her reference person, to verify the information provided in the customer’s application, and/or other information such as the customer’s new address and/or new contact number, in the event that we have an important information for the customer (for example, if the customer defaults on his/her payment obligation to us) and we are unable to reach the customer using the contact information that he/she provided to us.
3. How will Home Credit Philippines Retain/Dispose your Personal Data?
- 3.1 Retention. Home Credit Philippines will retain your personal information due to the following reasons:
- For the fulfillment of the declared, specified, and legitimate purpose, or until the processing relevant to the purpose has been terminated;
- b. For the establishment, exercise or defense of legal claims;
- For legitimate business purposes, which must be consistent with standards followed by the applicable industry or approved by appropriate government agency; or
- In any case provided by law.
- 3.2 Disposal. Home Credit Philippines will dispose of your personal data in a manner that the data will be unreadable (for paper) or irretrievable (for digital records).
4. Updates on Privacy Notice
- Updates to this Privacy Notice. We reserve the right to amend this Privacy Notice at any time in the future. After an amendment is made, the revised Privacy Notice will apply to all personal data that we maintain, regardless of when it was created or received. We will keep a copy of the current Privacy Notice posted in our website and a copy will also be made readily available at each appointment, upon your request.
5. Contact Home Credit Philippines’ Data Protection Officer (DPO)
Home Credit Philippines’ DPO provides support with any data privacy related questions, comments, concerns or complaints. You may contact Home Credit Philippines’ DPO through the following information:
Office address: 15/F Ore Central, 9th Ave. corner 31st Street, Bonifacio Global City, Taguig City, Philippines Email address: email@example.com
Home Credit Philippines’ DPO will always use best efforts to address and settle any requests or complaints brought to its attention.
If you do not want wish for Home Credit Philippines to process any of your personal data for the foregoing purposes or if you feel that your rights as a customer is violated, you may notify our DPO listed above for our immediate and appropriate action. However, we may not necessarily be able to stop any event since there are instances wherein processing of your personal information is allowed under the law.