Privacy Policy

The Pocketcash mobile application is owned and operated by Elending Lending Inc., registered with the SEC under Registration No.CS201912383 and Certificate of Authority No.3044. Elending Lending Inc. is a legally registered domestic corporation in the Philippines (hereinafter referred to as "Pocketcash" or "we"). This agreement is made between Pocketcash and registered users (hereinafter referred to as "user" or "you") and carries full contractual effect, applying to all activities users engage in on Pocketcash.

Before voluntarily registering and submitting user data, please carefully read this Privacy Policy and information regarding user data protection. If you disagree with these terms or cannot fully understand this agreement, do not register as a user of this platform. This Privacy Policy applies to all users accessing Pocketcash services through any functions, processes, and services on the application (including but not limited to loan application services). By registering as a Pocketcash user, you agree to allow Pocketcash to use all data you generate on the platform.

A. Applicable Terms

• 1.This Privacy Policy applies to all personal data provided by natural person users while using or attempting to use Pocketcash services (including loan services).
• 2.By using this application, you accept this Privacy Policy and agree to the collection, processing, storage, and transfer of user data in accordance with Philippine laws and regulations and this policy.
• 3.Upon confirming this Privacy Policy, the relationship between you and Pocketcash will be governed by it. You agree to comply with and fulfill any electronic agreements reached or to be reached and bear the corresponding obligations.

B. User Information Acquisition and User Obligations

• 1.To ensure smooth use of Pocketcash, we need to obtain the following permissions:
• Location Access: We request location access to offer personalized services and to enhance security measures. Please note that we only obtain your approximate address information and your location data is treated with strict privacy and is not shared without consent, except where mandated by law.
• SMS Access: We request access to your SMS for essential purposes such as identity verification, sending important notifications, and enhancing security. We want to assure you that we respect the privacy of your messages and will only access SMS content related to financial transactions and services. We do not access or read any other types of messages. Your message content will not be shared with third parties without your explicit permission, except when required by law.
• App Usage List Access: We may access your app list to customize your experience, improve app functionality, and enhance security. This information is used to better understand your needs and is not disclosed to third parties without your explicit consent.
• Adverstising ID Access: We obtain the Advertising ID, a unique and resettable identifier provided by your device's operating system, to enhance your user experience, offer personalized financial services, and ensure the security of your account.
• Camera&photo gallery Access: To protect your account security and improve your service experience, Pocketcash needs to access your camera and photo album permissions for the following purposes only: identity verification, material submission. We promise that we will never access the album content unrelated to the above purposes without authorization.
• Device-specific Information: Encompassing the device model and designation, preferred language options, locale configurations, detailed operating system specifications, browser edition, IP address, and battery level.
• Biometric Information：We gather your facial biometric data through a live photo of your face during facial recognition. This data is used to verify your identity, ensure that the loan application is made by you (both initially and during any follow-up verifications, including in disputes), and to prevent fraudulent loan activities.
• 2.User data is collected when users submit loan application forms in the mobile app.
• 3.User data includes both personal information and non-personal information. Personal information refers to all information filled in by users during application, such as name, gender, date of birth, address, phone number, email, and proof of identification. Non-personal information includes device information authorized by the user, such as phone model, operating system, unique device identifier, network address, location information, financial-related SMS, app installation list, and usage.
• 4.Users guarantee that the source of funds used in this application is legal and that they have the right to use and manage these funds. Borrowers commit to using loans solely for personal or family purposes and are prohibited from using funds obtained from this app for illegal activities such as gambling or lending.
• 5.Users commit to submitting truthful and valid information and ensuring the completeness and accuracy of the information provided. Users are solely responsible for any loss resulting from false information. If false or fraudulent information is discovered, we reserve the right to cancel loan requests at any time without prior notice and may suspend or terminate user eligibility. Issued loans will remain unaffected, and users must repay in full according to the loan agreement.
• 6.Users commit not to use any data obtained from this app for commercial purposes, including copying or disseminating information displayed on the app without our consent, although this does not impact users’ use of their personal data.
• 7.Users agree to the conditions for using the service. If users choose not to provide the necessary personal information, we reserve the right to decline the request or terminate the service.
• 8.Users may withdraw their consent to collect, process, or store personal information at any time, provided that all legal obligations are met.
• 9.Users must comply with the laws and regulations of the Republic of the Philippines and government directives when using our services. Illegal activities are strictly prohibited, including: posting, transmitting, disseminating, or storing content that infringes on others' intellectual property rights, personal rights, trade secrets, or other lawful rights; creating false identities, posting false information, conducting misleading or deceptive activities; performing acts that endanger computer network security, including but not limited to placing or embedding viruses, trojans, worms, time bombs, or other computer programs intended to damage, maliciously interfere, secretly intercept, or infringe upon systems, data, or personal data in any information posted; posting information prohibited by the state or other content that may constitute illegal or violation of this agreement and other rules.
• 10.Users must keep their registered details accurate, current, and complete. If Pocketcash determines that any information is incorrect, false, outdated, or insufficient, it reserves the right to suspend or cancel the account and restrict access to Platform services. In such instances, Pocketcash bears no liability, and users are solely responsible for any resulting costs or damages.

C. Notice of User Information Processing

• 1.Evaluate user credit limits and assess fraud risk.
• 2.Verify user identity.
• 3.Contact the user.
• 4.Disburse loans.
• 5.Manage and recover outstanding debt.
• 6.Enhance user experience and optimize product features.
• 7.Send reminders for withdrawals and provide service and commercial information related to products.
• 8.Identify whether users comply with safety, public service, or legal requirements.
• 9.Engage in other purposes explicitly outlined in loan agreement statements.
• 10.Use non-personal data for statistics, analysis, and research, creating anonymous analytical reports.
• 11.We will not share user personal information with any third party for commercial purposes without the user's explicit consent and authorization.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable laws and regulations. Specifically:

• Identity Authentication, Loan Assessment, and Risk Control: We will retain such data for up to 5 years after you cease using our service. This is to comply with regulatory requirements and to prevent fraud.
• Marketing and Behavioral Analysis: We will retain this data for up to 2 years from the date of collection, or we will delete it immediately upon your withdrawal of consent.

Upon the expiration of the retention period or at your request, we will securely delete or anonymize your personal data.

D. Sharing and Disclosure of User Information

We may share your personal information with the following third-party entities to support service provision:

• 1.Affiliates or subsidiaries: for providing a complete loan service and assisting in evaluating user credit risk and preventing potential illegal activities.
• 2.Philippine courts, law enforcement, or other regulatory bodies: to meet requirements of Philippine legal procedures.
• 3.Banks or financial partners: where permitted by law or required by contractual business relationships.
• 4.Service providers: for supporting our business operations, including marketing, customer service, debt collection, fraud prevention, and technical services.

In processing user personal data, we will respect the rights granted to users under the 2012 Data Privacy Act, including: (1) Right to be informed, (2) Right to object, (3) Right to access, (4) Right to rectify, (5) Right to erasure or blocking, and (6) Right to damages.

E. Third-Party Websites

• 1.Our application may contain links to websites owned, controlled, or operated by third parties (hereinafter referred to as "Third-Party Websites"), including new business partners or co-branded sites. We cannot guarantee or take responsibility for the accuracy or effectiveness of information on Third-Party Websites. Users understand and agree that accessing Third-Party Websites is subject to their independent agreements and rules, not this Agreement. Users must assess and assume all risks associated with content, products, advertisements, and other information on Third-Party Websites, which is unrelated to us.
• 2.Third-party links (such as advertisements and external services) in the application are for reference only and are unrelated to us. Once users leave the application through these links, any information provided to third parties will no longer be protected by this Privacy Policy. We cannot ensure the security and privacy of such information. Before accessing or providing information to any Third-Party Websites, users should carefully read and understand their privacy policies and practices (if any) and take necessary protective measures. We are not responsible for the content, privacy, and security policies of any Third-Party Websites, services, or applications. Users should proceed with caution and review relevant privacy statements.

F. Third-Party SDK Disclosure

To enhance the quality of our services and improve user experience, Pocketcash has integrated the following third-party software development kits (SDKs). Before integration, we have thoroughly assessed their data collection practices. All data collection is conducted in compliance with relevant regulations, platform policies, and with the explicit consent of users.

• Alibaba Cloud SDK
  

  Securely uploads user-authorized images (e.g., ID cards, selfies) to the cloud for identity verification. We only collect images that users actively choose to upload. We do not access data from other devices or galleries.

  Data Processing: Data is transmitted using HTTPS and is strictly used for real-name authentication. It is not used for any other purposes.

• Advance.AI
  

  Verifies user identity during real-name authentication and prevents fraud. Selfies and ID photos uploaded by users are used solely for face comparison.

  Data Processing: All image data is collected with the explicit consent of the user, transmitted through a secure encrypted channel, and is only used for identity verification.

• AppsFlyer
  

  Analyzes user acquisition sources, behavioral processes, and advertising conversion efficiency to help us optimize marketing and product performance. We collect information such as device identifiers (e.g., Android ID, GAID), app install/open events, and in-app user actions.

  Data Processing: Data is securely transmitted using encryption. AppsFlyer does not access users' sensitive personally identifiable information.

• Facebook SDK
  

  Tracks user behavior, performs advertising attribution analysis, and improves the effectiveness of marketing campaigns. We collect device information, app usage data, and ad click/display events.

  Data Processing: All data is securely transmitted to Facebook in accordance with Facebook's privacy policy and data protection standards.

G. Disclaimer

• 1.Policy Risk: Changes in laws, regulations, and policies may cause abnormal price fluctuations and result in losses.
• 2.Default Risk: Potential losses due to the inability or unwillingness of other parties to fulfill obligations.
• 3.Interest Rate Risk: Market interest rate changes may impact the actual return on investments or products.
• 4.Transaction Risk: Disputes between transaction parties during the transaction process should be resolved as agreed. Unless otherwise provided by law, we do not offer any express or implied warranties to any user or transaction. Users should make decisions based on independent judgment and bear transaction risks themselves. Losses arising from misjudgment are solely borne by the user, and transaction disputes should be resolved by the parties themselves. We cannot guarantee the authenticity, completeness, timeliness, reliability, and effectiveness of data entered by users and third-party content, nor assume any legal responsibility arising therefrom.
• 5.Due to the uncontrollable nature of the internet, we cannot guarantee uninterrupted service. We are not responsible for any consequences if users cannot use the service normally due to system failure.
• 6.We will not be liable to users for delays or failure to perform services due to force majeure events beyond reasonable control, including but not limited to natural disasters, strikes, riots, government actions, and communication failures.
• 7.Losses caused by user errors (e.g., misjudgment, password loss or disclosure, improper operation) are the sole responsibility of the user.
• 8.The above content does not cover all risks associated with using this service. Users should fully understand transaction risks, make prudent decisions, and assume associated risks independently.

H. User Information Security

• 1.Protecting the security of users' personal information is our top priority. Except as described in this Privacy Policy, we will not disclose user personal information to any third party without explicit user consent. We will undertake reasonable procedures and make every effort to ensure the security of all user information received.
• 2.To achieve this, we employ various technical and managerial security measures to protect user information from loss, misuse, unauthorized access, disclosure, or alteration. We continuously improve security methods and update security measures in line with technological advancements. These include firewalls, data encryption, strict access controls, and physical security at data centers to maximize the protection of user information.
• 3.We implement robust security measures to safeguard your data against unauthorized access, disclosure, loss, misuse, or alteration. For data transmission, we utilize industry-standard encryption technologies, such as HTTPS and SSL, to ensure data confidentiality and integrity. Internally, we enforce strict access controls and audit mechanisms, allowing only authorized personnel to access sensitive information.
• 4.While we strive to maintain a secure environment for storing your information, we cannot guarantee absolute security during transmission or storage. Additionally, despite our efforts to ensure network and system integrity, we cannot assure that our security measures will prevent unauthorized access by third-party "hackers." We do not guarantee or warrant that your information will always be protected from loss, misuse, or alteration by such third parties.

I. Privacy

• 1.Pocketcash's Privacy Policy is formulated under Philippine law, specifically the 2012 Data Privacy Act (Republic Act No. 10173) (hereinafter "Data Privacy Act"), which governs the requirements for Pocketcash and its assignees, affiliates, and related companies in the collection, use, storage, analysis, and processing of information.
• 2.We place a high priority on user privacy and are committed to protecting all personal data provided by users. Before accessing or using this application, please read this Privacy Policy carefully. This policy includes important terms that impact your legal rights. You understand and agree that, upon submitting an application form, you will be bound by the terms of this policy and consent to our collection, use, storage, analysis, and processing of your data. If you do not wish to accept these terms, please choose not to use this application and its services.
• 3.To keep the Privacy Policy up to date, we may occasionally issue revised versions. Users are encouraged to review this Privacy Policy periodically for the latest information. Updates to the Privacy Policy will take effect from the date of publication. By continuing to use our services, you accept and agree to the updated policy terms.

J. Application usage restrictions

• 1.Pocketcash's services are exclusively available to Filipino citizens who possess full legal capacity. Failure to meet these eligibility criteria may result in the restriction or termination of your account and access to the app.
• 2.The Pocketcash platform may only be used in accordance with Philippine laws and regulations. Users must not exploit the app's features unlawfully, breach any provisions of this Agreement, or engage in activities that contravene applicable legal requirements, including government directives.
• 3.Upon completing registration, users may not share, transfer, or grant access to their accounts to others. All activities conducted through the account remain the sole responsibility of the registered user.

K. Intellectual property

• 1.All proprietary materials on Pocketcash's platform—including but not limited to text, graphics, software, source code, platform architecture, proprietary technology, and interface designs—are protected by intellectual property laws. These rights (encompassing trademarks, patents, copyrights, and trade secrets) belong exclusively to Pocketcash, regardless of explicit labeling.
• 2.All users of the Pocketcash platform must comply with intellectual property protections. Any infringement resulting in damages will hold the user fully liable for legal consequences.

L. Breach of Contract

If a user's conduct potentially violates applicable laws, regulations, or this Agreement, Pocketcash reserves the right to implement necessary measures. These may include, without limitation:

1.Immediate account suspension/termination

2.Removal of prohibited content

3.Service discontinuation

In cases where user negligence or willful misconduct causes damages (including third-party claims), the user shall bear full financial responsibility. This encompasses all associated costs such as:

• 1.Legal proceedings
• 2.Attorney fees
• 3.Investigation expenses
• 4.Other related charges

M. Communication and Complaints

• 1.After you agree to this Privacy Policy and use this application, we are authorized to communicate with you via the contact information provided during registration, including email, SMS, or postal mail. Please monitor your email and SMS notifications regularly. We are not responsible for any failure, delay, or lack of notice received due to user-related issues.
• 2.If you believe that your account or personal data may be misused or that data security may be threatened, you may submit inquiries and complaints using the contact details below, along with your contact information.

N. Contact Information

By using Pocketcash, you expressly consent to our authority to amend, remove, or disclose platform content as necessary to:

• (a) comply with legal and regulatory obligations;
• (b) maintain service operations; and
• (c) protect the rights of both Pocketcash and its legitimate users.

Users bear responsibility for staying informed of all platform updates and modifications.

If you have any questions or suggestions, please feel free to contact us:

• • Company Name: Elending Lending Inc.
• • Email: jemaicaguzman@elendinglending.com
• • Address: Marajo Tower, North Penthouse Unit, 312, 26th St. cor. 4th Ave., Taguig, Metro Manila, 1634 Philippines