Personal Data Processing Policy

Controller

1. 1. The Controller is TREEUM HOLDINGS LIMITED (hereinafter referred to as the Company), incorporated in Cyprus under registration number HE 321681.

2. 2. To contact the Company, please send an email to this address [email protected]. Otherwise, please send your correspondence to the following address:

TREEUM HOLDINGS LIMITED
Romanou, 9, Latsia 2237, Nicosia, Cyprus    

3. To contact the Company’s Data Protection Officer, please send your email to: [email protected].

Data Protection Officer
TREEUM HOLDINGS LIMITED
Romanou, 9, Latsia 2237, Nicosia, Cyprus           

Why We Contact You

4. 4. We, along with our group of Lenders and Credit Brokers, will keep you regularly informed about the progress of your credit application. Unless you have explicitly indicated otherwise, we may contact you by phone, SMS, postal mail, email, and/or automated messages: WhatsApp, Viber, Telegram.

Legal Basis for Collecting Your Personal Information

5. Our use of your personal information will always have a legal basis. We rely on various legal grounds for processing your personal information.

Consent

6. 6. When you provide your personal information through a loan application, we process it to fulfill our obligation to provide you with a credit history. The Company and our group of Lenders and/or Credit Brokers will contact you to share information related to your loan application.

7. 7. When you apply for a loan at https://broker.fintree.ph/ (hereinafter referred to as the Website), you give your consent to the Company to contact you, along with our group of Lenders or Credit Brokers, in connection with your online loan application. We process your personal information on this basis. If you wish to withdraw your consent to the processing of your personal information for marketing purposes, you may do so at any time. Simply click the "Unsubscribe" option in any marketing SMS message or email sent to you by us or any related third party. You may also withdraw your consent by sending an email to our Data Protection Officer at [email protected]. Withdrawal of your prior consent to the processing of your personal information will not affect the lawfulness of the processing we carried out before you withdrew your consent.

Methods of Communication and Contact with You

8. 8. We will contact clients by phone, SMS, mail, email, and/or automated messages to provide information, credit application notifications, and statements from our affiliated companies, unless the client requests otherwise. Third parties may also provide us with personal information/data so that we can offer products to potential clients who have been identified and have expressed interest. We review any information/data received from third parties to ensure its accuracy. Additionally, we will make efforts to periodically verify your information with you.

Push Notifications

9. 9. If you agree, we may send push notifications to your mobile device or web browser. These push notifications may contain marketing messages from us or from third parties. You can change push notification settings at any time in the notification settings of your browser or mobile device.

Updating Personal Information

10. You are responsible for ensuring the accuracy and up-to-dateness of any of your personal information/data that we store. Please contact us as soon as possible if you need to update or correct your information.

Personal Data Processing

11. 11. We acknowledge the importance of your privacy. To maintain the confidentiality of your information, we have taken steps to ensure that any personal information we receive from you is processed and stored by Republic Act No. 10173, also known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, other relevant laws and regulations of the National Privacy Commission, any other legislation protecting the fundamental rights and freedoms of individuals, and proper data processing practices. In this statement, we outline the types of information the Company may collect about you, our client. It will also contain detailed information on how we obtain, process, and protect any information we may hold.

12. 12. This privacy policy applies only to us and all personal information that we may collect and receive. We reserve the right to periodically change the content of this privacy policy. In such a case, we will publish the revised policy on this website.

13. 13. When you apply for a credit product online, we collect your personal information to obtain a credit quotation. In providing you with our services, we may also collect information about how you use our Website. We may collect information about pages viewed, the website that referred you to our Website, changes you made to the personal information you provided, details of the quotations you requested, and the content of your applications, including details of your financial information, such as your bank account or employer data. We need to collect your personal information to provide you with a relevant credit quotation. When you request a credit quotation, you give your express consent to the processing of this information by us, along with third parties such as lenders and credit brokers. We store the information you provide. This information may use to pre-fill fields on the Website and facilitate your use of the Website during subsequent visits. We will not store your information longer than permitted by law. We will periodically review your information to ensure this.

14. 14. The Company processes personal data for the following purposes: 

14.1. fulfilling its contractual obligations, including sending personal data to lenders, by the Terms and Conditions. The legal basis for processing personal data is Article 6 (1) (b) of Republic Act 10173 Data Privacy Act of 2012. The contract concluded between the Company and the data subject specifically states that the Company may transfer personal data provided by the data subject to the service provider. Please note that not all personal data provided by the data subject will be transferred to every lender. Different lenders request different data. However, since the Company does not know in advance which lender the data subject's data will be sent to, it collects enough data for each lender with whom the Company maintains professional relations to conduct an initial assessment, approving or rejecting the loan; (to obtain a final decision, the lender may request additional data, given the principle of data minimization, the Company does not collect such data): settlements with transaction partners. Lenders pay the Company for sending them data and information about data subjects who wish to receive loans, to lend money to these data requesters.

14.2. taking necessary measures to prevent fraud. The legal basis for processing personal data is Article 6 (1) (b) and (c) of Republic Act 10173 Data Privacy Act of 2012. The Company is interested in not being deceived and may be obligated to lenders to ensure that it does not send any data or information to lenders interested is fraudulent or misinformation.

14.3. compiling an analysis of the use of the Website and services provided by the Company. Conducting analyses is necessary for the Company to have sufficient information about its operations to develop and implement its business plans (e.g., information about successful marketing channels, information about which users use functions of this website, etc.). This is necessary, among other things, to provide better service to interested parties.

14.4. direct marketing. The Company does not accept money from data subjects for services available to them through the Website. Given the marketing costs within the overall line, this would be impossible without direct marketing.

15. 15. The Company will not be able to perform its tasks as provided in the Terms and Conditions if interested parties do not fill in all fields of the application form.

16. 16. In addition to personal data entered by the data subjects themselves, the Company collects personal data belonging to the following categories: 16.1. Location (including IP address) from which and when the data subject accesses the Website, how the user arrived at this website (e.g., via a Company partner who placed an advertisement on the Website, or a partner who collects user personal data and then sends it to the Company, etc.). Data is received from the website through which the user navigated to this Website.

17. 17. The Company transfers the personal data it collects to recipients belonging to the following categories: 

17.1. loan providers 

17.2. email providers

17.3. SMS service providers 

17.4. analytics service providers 

17.5. server and network access providers (e.g., Internet).

18. 18. In addition, the Company's IT and marketing subcontractors may have access to this personal data, processing personal data on the same servers where the Company stores personal data.

Inclusion of Your Personal Information

19. 19. You are free to visit and browse our website, https://broker.fintree.ph/, at your discretion. You are not required to provide any personal information/data. (Please refer to our Cookie Policy for more information.)

20. 20. To be able to entrust you with a loan offer, we typically collect the following information from you:

    • Name

    • Address

    • Residential status

    • Date of birth

    • Email address

    • Phone number

    • Income

    • Marital status details

    • Passport details

    • Details of movable and immovable property

    • Education details

    • Bank account

    • IP address

    • Website activity: the results of this activity will be used to inform the Company which aspects of the website are used most and least. (Please refer to our Cookie Policy for more information.) If you contact us for information about our services or send an email to [email protected], we may also collect certain personal information from you to best respond to your inquiry.

21. 21. The list of personal data we collect is not exhaustive and depends on the type of service you wish to receive, the legal requirements for providing personal services to obtain such a service, and the requirements set by the lenders who are the providers of the service you request.

Use of Your Personal Information

22. 22. We may use your personal information:

    • to provide you with access to and the ability to use our Services;

    • to improve and customize various parts of our Services;

    • for market research;

    • to communicate with you, including one or more of the following methods:

    • sending you information about additional services and products that we believe may be of interest to you. This may include new product launches, alternative financial solutions, newsletters, and opportunities to participate in market research;

    • sending loan offers. We may also share the information you provide with our partners (such as our group of lenders and credit brokers) and our affiliates so they can calculate personalized offers for you. In doing so, our partners may perform soft checks on your credit history;

    • sending you confirmation of your offer by email or SMS. When you apply for a loan, we will automatically send you confirmation of receipt of your application by email or SMS for your records;

    • to process the application between you and a third party;

    • to track sales. This may include transferring your data to your product provider in connection with the products you have purchased;

    • to match our data with data from other sources. We may verify, analyze, and compare your information with data collected by a third party to ensure the most consistent, accurate, and well-organized information we have about you;

    • to send customer feedback surveys, which we provide to all applying clients;

    • to transfer your data to third parties for marketing purposes.

Ensuring the Timeliness of Your Service Information:

23. 23. By using our Website, you agree that we and (with your consent) our affiliates, partners, and other trusted third parties have the right to contact you via email, SMS, phone, postal mail, and/or automated messages or other electronic means regarding services, products, and other promotions that may interest you. In any case, if you provide us with personal data/information, where necessary, we will request your consent and/or provide you with an opportunity to opt out of the sharing of your information for marketing and other purposes. Unless you indicate otherwise, you consent to such use.

Providing Access to Your Personal Information

24. By completing and submitting a loan application, you agree to the transfer of your personal information to the following parties:

• The Website, the Company, and its affiliates: (i) to contact you, including sending you information about services and products that may interest you; (ii) to expedite form completion or to customize or improve your experience on their website or mobile application; or (iii) in accordance with their Privacy Policy.

• Lenders and credit brokers. If permitted by data privacy and protection law, we may also need to access your account and/or disclose information about you (including electronic identifiers such as IP address):

• if permitted or required by law;

• if required by a court or any relevant regulatory, law-abiding, governmental, or law enforcement authority;

• if necessary in connection with ongoing or future legal proceedings; and/or

• in connection with the sale or potential sale of all or part of our business.

Transferring Your Personal Information to Third Parties

25. 25. Some providers from the Website may use your personal information to verify your situation (including information about third parties specified in your application) and check the accuracy of any information you provide before providing a price quote. Some providers may perform checks with fraud prevention and credit information agencies. They may verify your personal and public data using this method. Some providers may check data they already hold about you, such as data from existing financial products, account information, or information from previous transactions, to determine your credit amount. When providers conduct these searches, your credit report will contain a record of the check. Some providers may perform education checks to also obtain information about your previous education. This allows providers to verify any information you provide during the quotation process. This also helps detect fraudulent loans. These standard checks are common when obtaining credit quotations from other sources. If you choose to take out a loan, the data you provide to us, as well as additional information provided to third parties, will be stored by the provider in accordance with the provider's privacy policy. We strongly recommend that you review the privacy policy of your chosen provider before entering into a loan. We are not responsible for how the provider uses your personal information.

Your Rights

26. 26. Under this Policy and applicable law, you have the following rights, among others: 

Right to Information – The Company provides all clients with this Privacy Policy for review to ensure transparent and clear information regarding the procedures for collecting, controlling, and processing personal data. 

Right of Access – Stored personal data can be requested based on an access request and will be fulfilled within the 30 days stipulated by law, usually free of charge. Any extension of these requirements will be communicated depending on the nature of the request, but will occur in exceptional cases and be subject to verification. 

Right to Rectification – If we hold inaccurate data, please inform us of the correct information, and records will be updated within 72 hours, with appropriate confirmation provided (subject to identity verification).

Right to Restriction of Processing – Data processing will be restricted while you challenge any claim regarding accuracy, or you dispute the legal basis or legitimate grounds for processing for a specific purpose and for the establishment, exercise, or defense of legal claims at your request. 

Right to Object – You may object to the Company's data processing on the grounds that it conflicts with your rights. Any objection concerning direct marketing will be addressed within 48 hours; other objections will be treated as a complaint and evaluated against our documented legal grounds. 

Right to Erasure – Also known as the right to be forgotten, the Company will generally fulfill your request within 72 hours if the legal basis is solely or partially consent. Any data required for legal, regulatory, or legitimate interests may be retained in accordance with documented retention schedules. However, our team will confirm and discuss your request to ensure continuous compliance with your rights. 

Right to Data Portability – You have the right to receive personal data you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller in a timely manner, typically within 72 hours, unless it is proven to be excessive or unreasonable. 

Rights Regarding Automated Decision-Making and Profiling – You have the right to object to automated decision-making, to express your point of view, to request human intervention, and to obtain an explanation of the decision with the possibility of challenging it.

27. 27. The Company has established clear policies and procedural requirements to ensure the observance of your rights as a data subject; however, if this is not possible for the reasons mentioned above, we will confirm the details of such a decision.

28. 28. Regarding all these rights, please write to us or contact us at the address specified in this Policy. Please note that we will need to verify your identity.

Storage of Your Personal Data

29. 29. Depending on why you provided us with your personal data, the retention period will vary: 

29.1. If you choose to opt out of marketing communications, we will retain your information to remember your preferences. 

29.2. Any information related to applications you submit on our website will be stored for a minimum of 10 years (starting from the termination of our relationship). We store information for this period to assist with potential future complaints.

Opt-out of Communications

30. 30. You can opt out of future contacts from the Company at any time. All our marketing communications contain an opt-out or unsubscribe link. Processing your request may take up to 48 hours.

Deletion of Your Personal Information

31. 31. If you wish to exercise your right to be forgotten and request the deletion or destruction of your personal information, please send a corresponding letter to the email address [email protected]. We will also ensure that our marketing partners are informed of your request. We are not responsible for the actions of partners, but only for notifying them of your request.

Complaints

32. We strive to always provide you with a satisfactory level of service. However, if you wish to file an official complaint, please send an email to [email protected].