Privacy Policy
The Pocket cash mobile application is owned and managed by ELENDING LENDING INC., a duly registered domestic
corporation in the Philippines, under Registration No.CS201912383 and Certificate of Authority No.3044. ELENDING
LENDING INC. (hereinafter referred to as “Pocket cash,” “we,” or “our”) serves as the operator and lawful provider
of the services offered through this application. This Agreement constitutes a binding contract between Pocket
cash
and each registered user (“user” or “you”) and governs all activities conducted on the Pocket cash platform.
Prior to registering or voluntarily submitting any personal information, you are advised to review this Privacy
Policy and the related provisions regarding the protection of user data. If you do not agree with any part of this
Policy or are unable to fully understand its contents, you should refrain from creating an account or using our
services. This Privacy Policy applies to all individuals who access Pocket cash and utilize any of its functions,
processes, or services, including but not limited to loan application features.
By completing the registration process and becoming a user of Pocket cash, you acknowledge and consent to our
collection, processing, and use of the data you provide or generate in connection with your use of the platform,
in
accordance with this Privacy Policy.
Pocket cash is committed to operating in full compliance with all applicable laws, regulations, and platform
policies, including the Google Play Developer Program Policies for financial services.
In adherence to these policies, we explicitly state that our loan products are designed with a minimum tenure
that
exceeds the required thresholds.
Minimum Loan Tenure: All loan products offered through this Application have a minimum repayment period of
ninety-one (91) days.
Maximum Loan Tenure: The maximum repayment period for our loan products is three hundred and sixty (360) days.
Compliance Statement: We affirm that we do not offer, facilitate, or provide any loan product with a repayment
period of less than sixty (60) days. Our loan tenures strictly range from 91 days to 360 days, ensuring full
compliance with platform requirements aimed at promoting responsible lending practices.
We are committed to protecting your personal information in compliance with the Data Privacy Act of 2012 (RA
10173)
and Google Play’s Personal Loan Policy.
A. Applicable Terms
- This Privacy Policy applies to all personal data provided by natural person users while using or attempting to
use Pocket cash services (including loan services).
- 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.
- Upon confirming this Privacy Policy, the relationship between you and Pocket cash 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
- To ensure smooth use of Pocket cash, 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.
Detailed explanation of SMS Access
1.Access to your SMS is strictly limited to the following purposes:
Financial Behavior Analysis: To automatically identify and parse messages from financial institutions (e.g.,
banks,
credit card companies, other licensed lenders) for the sole purpose of assessing your financial stability and
creditworthiness.
Income Verification: To help verify stated income by identifying regular salary or deposit messages from known
employer or business entities.
Identity Verification: To assist in the user identification process as part of our comprehensive KYC (Know Your
Customer) checks.
Fraud Prevention: To help detect and prevent fraudulent loan applications and identity theft.
2. Scope and Limitations of Data Processing
We implement strict technical and operational controls to minimize data access and protect your privacy:
Selective Parsing: Our systems are designed to use automated filters to identify and process only SMS messages
from
senders identified as financial entities. We do not intend to read, store, or process personal, non-financial
conversations.
No Permanent Storage: Raw SMS content is not permanently stored on our servers. Only the extracted, relevant
financial data points (e.g., transaction amount, sender name, date) are encrypted and stored for risk assessment.
User Consent is Revocable: You have the right to deny or revoke this permission through your device settings at
any
time. Please note that revoking this permission may impact our ability to process your loan application and could
result in application rejection.
3. Data Security
All data, including any information derived from SMS messages, is encrypted in transit and at rest using
industry-standard protocols to prevent unauthorized access.
- 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, Pocket cash 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.
- User data is collected when users submit loan application forms in the mobile app.
- 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.
- Phone Number Collection for Registration and Login: When you register for an account or log in to our
application, we collect and verify your mobile phone number to complete the authentication process. Your phone
number is used for the following purposes:
To send verification codes for identity confirmation
To create and manage your user account
To maintain the security of your account and prevent unauthorized access
To support customer service and account recovery when necessary
We do not use your phone number for any purposes unrelated to account registration, login, or security.Your phone
number will not be shared with third parties without your explicit consent, unless required by applicable laws or
regulatory authorities.All information transmitted during the verification process is protected using secure
encryption protocols.
- 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.
- 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.
- 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.
- 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.
- Users may withdraw their consent to collect, process, or store personal information at any time, provided that
all legal obligations are met.
- 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.
- Users must keep their registered details accurate, current, and complete. If Pocket cash 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, Pocket cash bears no liability, and users are
solely
responsible for any resulting costs or damages.
C. Notice of User Information Processing
- Evaluate user credit limits and assess fraud risk.
- Verify user identity.
- Contact the user.
- Disburse loans.
- Manage and recover outstanding debt.
- Enhance user experience and optimize product features.
- Send reminders for withdrawals and provide service and commercial information related to products.
- Identify whether users comply with safety, public service, or legal requirements.
- Engage in other purposes explicitly outlined in loan agreement statements.
- Use non-personal data for statistics, analysis, and research, creating anonymous analytical reports.
- 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:
- Affiliates or subsidiaries: for providing a complete loan service and assisting in evaluating user credit risk
and preventing potential illegal activities.
- Philippine courts, law enforcement, or other regulatory bodies: to meet requirements of Philippine legal
procedures.
- Banks or financial partners: where permitted by law or required by contractual business relationships.
- 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
- 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.
- 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, Pocket cash 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.
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.
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.
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.
This application makes use of the Google Firebase SDK (by Google LLC) to support the following functions:
Monitoring and improving overall app performance, Analyzing user interactions and behavioral trends, Optimizing
advertising effectiveness.
Data Processing: Please note that Firebase is not used to collect sensitive personal or financial data, such as
names, phone numbers, or bank card details.
G. Disclaimer
- Policy Risk: Changes in laws, regulations, and policies may cause abnormal price fluctuations and result in
losses.
- Default Risk: Potential losses due to the inability or unwillingness of other parties to fulfill obligations.
- Interest Rate Risk: Market interest rate changes may impact the actual return on investments or products.
- 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.
- 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.
- 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.
- Losses caused by user errors (e.g., misjudgment, password loss or disclosure, improper operation) are the sole
responsibility of the user.
- 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
- 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.
- 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.
- 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.
- 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
- Pocket cash'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 Pocket cash and
its
assignees, affiliates, and related companies in the collection, use, storage, analysis, and processing of
information.
- 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.
- 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
- Pocket cash'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.
- The Pocket cash 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.
- 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
- All proprietary materials on Pocket cash'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 Pocket cash, regardless of explicit labeling.
- All users of the Pocket cash 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, Pocket cash 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
- 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.
- 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. Protection of Minors
- Eligibility and Intended Users
Our loan products and services are strictly intended for and directed to individuals who are of legal age to
enter
into a binding contract in their jurisdiction. In the Republic of the Philippines, this requires the user to be at
least eighteen (18) years old.
2. Prohibition for Minors
Our Application and services are not designed for, targeted at, or offered to individuals under the age of 18
("Minors" or "Children"). We do not knowingly collect, solicit, or process any personal data from individuals
under
the age of 18.
3. Actions upon Discovery
If we become aware that we have inadvertently collected personal information from a Minor without verified
parental
consent, we will take immediate and reasonable steps to delete such information from our servers.
O. Contact Information
By using Pocket cash, 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;
(c)
protect the rights of both Pocket cash 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.
• Address: Block 23 Lot 55 / 57 Crane St Amaris Homes, Molino 4 Bacoor, Cavite, 4102
Philippines