RPAX Loan Privacy Policy

Introduction

This Privacy Policy governs your access to and use of the RPAX Loan application (“App”), which is made available to you by Monee (Credit) Finance Philippines, Inc. (“we,” “our,” or “us”), and published under the account of WE RESPOND (WR) INTERNATIONAL LENDING Corp.

WE RESPOND (WR) INTERNATIONAL LENDING Corp. is a duly registered and licensed corporation under the laws of the Republic of the Philippines, with Registration Number CS201916431 and Certificate of Authority No. 3109, acting as the official publisher of the RPAX Loan application.

Monee (Credit) Finance Philippines, Inc. is a duly registered and authorized lending company under Philippine laws, with Company Registration No. CS202005382 and Certificate of Authority No. 1279. It has granted authorization to WE RESPOND (WR) INTERNATIONAL LENDING Corp. to publish, distribute, and operate the RPAX Loan application, including user acquisition, customer support, and related services.

At RPAX Loan, we are dedicated to safeguarding your privacy and securing your personal information. We guarantee that all personal data entrusted to us is managed responsibly and in compliance with the relevant laws and regulations of the Republic of the Philippines.

This Privacy Policy outlines how we collect, utilize, share, and protect your information. By accessing or using the RPAX Loan application, you confirm that you have read, understood, and accepted the terms set forth in this Privacy Policy.

A. Information We Collect

To provide, manage, and optimize our loan products and related services, conduct necessary credit assessments and risk management, fulfill our contractual obligations to you, comply with applicable laws and regulatory requirements, and maintain the security and integrity of our services, we will, under the principles of legality, legitimacy, and necessity, collect the following categories of information through various means. These include information you actively provide, information automatically collected during your use of our services, and information obtained from third parties with your authorization or as permitted by law. The scope of information collection is strictly limited to the minimum necessary for achieving the aforementioned purposes.

1. Personal Identification Information

Complete full legal name Type and corresponding number of your official identification documents Date and place of your birth Age, gender, and current marital status Personal educational background Religious affiliation (only if you choose to provide this information voluntarily)Current residential address

2. Approximate Location Data

We may ask for permission to access your approximate geographic location in order to deliver location-based services effectively, strengthen overall account security measures, and proactively prevent and combat fraudulent activities within our platform. All of your approximate location data is treated with strict confidentiality, and we will not disclose this information to any third party without your explicit consent, unless such disclosure is mandated by applicable laws and legal requirements.

3. Camera and Media Access

We will only request access to your device’s camera and media storage for the sole purpose of scanning, capturing, and uploading necessary official documents. These documents may include your government-issued identification cards, bank account information, and other required paperwork to smoothly facilitate and process your loan application.

4. Device-Related Data

Name and specific model of your mobile device Language and regional configuration settings of your device Detailed information about your operating system and browser version Unique IP address associated with your device Current battery status of your mobile device.

5. Calendar Access

Our mobile application may seek access to your device’s built-in calendar feature, so that you can conveniently create and save loan-related schedule reminders for your own personal reference and tracking.

If you choose to grant this calendar access permission, our app will only add loan-specific reminders and schedule entries directly to your calendar. It is important to note that our application will never read, retrieve, collect, or store your pre-existing personal calendar events or private schedule information.

Please be advised that granting calendar access permission is completely optional. You have the full right to decline this permission when prompted, or you may revoke this access permission at any time later through the system settings on your mobile device.

6.Financial and Employment Information

Details of your bank accounts and registered e-wallet accounts Employment-related information, including your employer’s full name and official contact information Monthly income amount, primary source of income, and scheduled payday dates Existing outstanding loan balances and other personal financial obligations

7.Contacts Permission

When you use our Private Access Mode, we will only access the specific contact information that you voluntarily select via the official contact picker tool provided by your device’s system. This access is strictly limited to the purposes of identity verification and effective risk management for your loan application. Under no circumstances do we access, collect, upload, or store your entire contact list from your device.

8.Advertising ID

We collect your device’s Advertising ID, which is a unique, reset table identification code generated automatically by your device’s operating system. Collecting this identifier allows us to optimize and improve your overall user experience, deliver tailored and personalized financial services that suit your needs, and further protect the security of your user account on our platform.

9.Biometric Data Collection & Usage

To strengthen our security protocols and effectively prevent fraudulent behavior, we employ advanced facial recognition technology to conduct strict identity verification for all applicants. During the loan application process, you will be guided to provide a real-time, live facial photograph as part of the verification step. This biometric facial data is used exclusively for the following key purposes:

• Identity Verification: To confirm that you are the genuine and authorized loan applicant
• Continuous Authentication: For follow-up identity checks, including the resolution of any potential account disputes
• Fraud Prevention: To identify and stop unauthorized or illegal loan-related activities

Your facial biometric information is processed using high-level security measures, and it is only used for the identity verification purposes outlined above, with no additional or unauthorized usage.

10.Push Notifications

To ensure that you receive timely and important updates regarding your user account and loan-related services, RPAX Loan may request permission to send push notifications directly to your mobile device.

Push notifications are designed to deliver critical service-related messages to you promptly, including but not limited to the following:

In-app announcements and system-wide important notices Real-time updates on your loan application status Payment reminders and upcoming loan due date alerts Account security warnings and essential service announcements

Granting push notification permission is entirely optional. You may decide whether to enable this feature at the time of installation, and you can adjust, restrict, or fully disable this permission at any time through your device’s system settings.

RPAX Loan will never use push notifications for unauthorized advertising or marketing purposes. All push notifications are sent solely to support our core loan services and enhance your overall user experience.

We do not collect, store, or access any personal content from your device’s notification center. The push notification permission is only used to display official service-related messages that are initiated and sent by our system.

B. Purposes for Data Processing

Your personal data is collected and used for the following purposes:

1.Loan Eligibility Assessment
To determine your creditworthiness and eligibility for loan products by conducting credit scoring, background checks, and data analysis.
To support the processing of your loan application, including sharing data with our authorized partners when necessary.

2.Customer Support & Dispute Resolution
To respond to your inquiries, complaints, or disputes concerning our services.
To offer tailored support based on how you use our services.

3.Service Optimization & Communication
To send you updates on loan status, payment reminders, and promotional offers.
To inform you of changes to our policies, terms, or services.

4.Regulatory Compliance & Fraud Prevention
To meet legal and regulatory requirements.
To identify and prevent fraudulent or unauthorized activities.

5.Third-Party Service Integration Disclosure

AppsFlyer: Monitors user acquisition sources and in-app behavior to improve marketing effectiveness and product development. We collect the following data: device identifiers, app installation/launch events, and non-sensitive user interaction data.

Dyna.AI: Performs facial recognition for biometric authentication to combat fraud. We collect the following data: live selfie images (for liveness detection) and government-issued ID photos (when provided by you).

Firebase: Delivers push notifications for important service messages, updates, and account-related alerts. We may collect the following data: device information (e.g., device model, OS version, and device identifiers), and app usage data related to notification delivery and interaction.

Alibaba Cloud: Provides encrypted cloud storage for verification documents you submit. We collect the following data: user-uploaded images (selfies/IDs) and temporary session tokens.

Each integration undergoes strict privacy compliance reviews. Data collection is strictly limited to authorized purposes and carried out only after obtaining your explicit consent, in line with applicable laws.

C. Your Data Management Rights

• Account Deletion: You may request that your account be deleted, though legal and regulatory obligations may require us to retain certain data.
• Provision Choice: This Privacy Policy is designed to protect your right to be informed. You may choose not to provide specific information; however, please understand that this could limit your access to our full range of services. Some information is essential for loan assessment, contract performance, and legal compliance.

D. Sharing of Information with Third Parties

We never sell, rent, or exchange your personal information with outside parties for their own commercial marketing purposes. Any sharing of your information with third parties occurs only in the specific situations described below, and always with appropriate security protections:

• Credit Bureaus & Financial Institutions: Where necessary for credit checks, loan processing, or regulatory credit reporting, we may provide required information to licensed credit bureaus, other financial entities, or identity verification service providers.
• Service Providers & Partners: We work with trusted external vendors, advisors, and partners who deliver essential services on our behalf under strict confidentiality and data processing terms. These services include data analysis, payment handling, sending SMS or notifications, customer assistance, identity checks, and fraud detection. These third parties may only access and use your information as needed to perform their contracted tasks, and are held to confidentiality and security standards at least as rigorous as those outlined in this policy.
• Legal & Regulatory Authorities: We may release your information when compelled by laws, regulations, subpoenas, court orders, or other binding government or regulatory demands to comply with legal procedures. Additionally, we may disclose information in good faith if we believe it is necessary to look into suspected unlawful activities, enforce our Terms of Service, respond to security risks, or protect our own rights, property, or safety, as well as those of our users or the public.

E. Our Data Security Commitments

We fully understand how critical data security is, and we are dedicated to applying robust, industry-standard physical, technical, and organizational safeguards to protect your personal information from unauthorized access, use, alteration, disclosure, loss, or destruction. Our comprehensive security framework includes, but is not limited to:

• Encrypting sensitive data both while it is being transmitted and when it is stored.
• Enforcing strict access controls and multi-factor authentication for authorized staff.
• Conducting regular security reviews and audits to ensure ongoing compliance.
• A layered security approach combining advanced technology, organizational policies (such as mandatory employee training), and physical protections for data centers.
• That said, no security system is completely foolproof. We urge you to safeguard your account credentials and to report any suspicious activity promptly.

Data Retention Period: We will keep your personal information only for as long as needed to achieve the purposes described in this policy, or as mandated or allowed by applicable laws and regulations.

Specifically, data related to identity verification, loan assessment, and risk management may be retained for up to 5 years following the end of our business relationship with you, in line with regulatory requirements and anti-fraud considerations.

Data used for marketing and behavioral analysis will be kept for no more than 2 years from the date it was collected, or will be deleted immediately if you withdraw your consent.

Once the retention period expires, or upon receiving a valid request from you (while still complying with legal obligations), we will securely delete your personal information or anonymize it so that it can no longer identify you as an individual.

F. Policy Updates

We may update or modify this Privacy Policy from time to time as needed to reflect changes in our services, improvements in technical practices, updates to relevant laws and regulations, or new security enhancements. Should any material changes be made, we will inform you by posting the revised version within the RPAX Loan App, sending push notifications (when available), or through other appropriate methods. The updated policy will show a new effective date upon release. We encourage you to check this policy regularly to stay informed of its most current version. By continuing to use our services after any such updates, you acknowledge and agree to the revised terms.

G.For users 18 years and older

Our services are designed for users aged 18 or older. We do not knowingly gather personal information from anyone under that age. If you are below the minimum age, please refrain from registering for or using our services. Should we discover that we have collected personal data from a minor without verified parental consent, we will promptly take steps to erase that information. Parents or guardians who suspect that we may have collected their minor child's information are welcome to reach out to us.

H. Contact Information

Should you have any questions, worries, or feedback about this Privacy Policy, or if you would like to exercise your data subject rights or make any requests regarding how your personal information is processed, please reach out to us at:

Number: 0960 596 8728

Address:

Ancar Motors Azure Building EDSA, Munoz, Katipunan, Quezon City, Metro Manila, 1105 Philippines