XLKASH LENDING CORP.
SEC Registration No. CS201917309 CA No. 3136.
Address：19B East Wing, 19th Floor, Octagon Center, San Miguel Avenue,
Ortigas Center, San Antonio,
If you have any questions, concerns, or suggestions, please contact us at 09774871003.The Information We Collect
To avoid fraud, when you sign up for XLKASH LENDING account, in addition to your login username and password, we will also ask for your name, email address birthday, gender. We need your authorization and/or permission to your Call Log Information,camera,Media/Photos/Files,SMS,Contacts,APP Installed,location, phone book, internet and any other information access.Call Log Information
By making voice calls to you and collecting your call records, This will allow us to verify that you have installed our app on your phone and received a voice call from us with a code. Specifically, we will monitor your call logs to see if you received the dynamic password verification logs sent by our app.On the other hand,this helps us evaluate your credit, detect fraud and secure your account. You can disable the authorization access in the system settings, but this may affect your loan assessment result.
The call record information (such as call duration, call number, call status) that we collect with your authorization will be transmitted and uploaded to our server (https://lpj-xlkash.leapgen.net/api/common/upload) with HTTPS encryption. And we don't share any of your personal data with third parties.Camera
We require the camera information permission to allow you to click photos of your KYC documents and other requisite documents and upload the same on the Platform during your loan application journey to complete your loan application form.Media/Photos/Files
We require permission for media, photos, and files, allowing the Platform to enable you to upload photos or documents to complete the application form during your loan application journey.
Monitor and Collect: When you upload photos using features such as photography, the App collects your images as part of the information with your permission to assess your risk profile and determine your loan eligibility.
Purpose: To help you fill in relevant pictures and other information during the loan application process. In addition, this information is required for risk analysis so that we can check and refer to it to assess your risk profile and confirm your eligibility for a loan.
Data storage: With your consent, data will be encrypted and uploaded to our dedicated server https://lpj-xlkash.leapgen.net/ via HTTPS protocol. We do not share this data with third parties.SMS
Monitoring and Collection: With your consent, all SMS data will be encrypted and uploaded to the server by the application. We collect SMS content from your inbox, including sender number, sender name and SMS content, this SMS data also includes your historical calendar information, but we only use financial related information and analyze whether the user is qualified for a loan.
Purpose: To identify and analyze your behavior and risk when you have multiple loans, to assess whether a loan can be processed by anti-fraud collection, by collecting and tracking detailed transactions and amounts for financial and non-personal text messages. It will be used to check the eligibility and risk assessment of the customer. Other SMS messages will not be evaluated. We analyze the user's text messages, verify and track their financial transactions in the dashboard, and give accurate credit limit based on their spending budget and ability to pay. This helps us identify the different bank accounts you may have, cash flow patterns, and the amount of transactions you as a user can process.In addition,we use SMS to auto-fill the verification code during the process of verifying the validation of your financial account when you add your beneficiary's bank or e-wallet account. It's alsoused for the purposes of risk analysis.
Data storage: With your consent, data will be encrypted and uploaded to our dedicated server https://lpj-xlkash.leapgen.net/ via HTTPS protocol. We do not share this data with third parties.Contacts
We also need to collect your guarantors' information. We will request the "Read Contacts" permission so that users can select contacts from the contact list and automatically fill them into the guarantor list. The contact information will only be used for our “Know Your Customer” purpose but not be provided to any third parties. If you agree to the authorization, we will upload the guarantor information to https://lpj-xlkash.leapgen.net/api/user/contacts using the most secure data transfer protocol (HTTPS). We will store your personal information through DES and AES encryption. Storage time will not exceed your usage time.APP Installed
Use installed APPs help us identify your credit level and recommend suitable credit products;Third-party SDK Directory
We integrate third-party software development kits (SDKs) for thorough evaluation and will promptly disclose the latest updates regarding their integration. Please refer to the official privacy policies of each respective third-party SDK for detailed information.
SDK Name: tongdun
Purpose of use: App Device fraud risk identification.
Collected Personal Data Types: Mobile terminal unique identification information (IMEI/IDFA), Android ID, IMSI, MEID, MAC address, SIM card serial number, device serial number, device type, device model, system type, geographical location, login IP address, application Program list, running process information, sensor (light sensor, gravity sensor, magnetic field sensor, acceleration sensor, gyroscope sensor) related device information.
SDK Name: Kochava
Purpose of use: App attribution analysis
Collected Personal Data Types: Device information, advertising identifiers (adid/oaid)
SDK Name: Udesk
Purpose of use: Online customer service
Collected Personal Data Types: Device information
SDK Name: Advance
Purpose of use: Facial data collection and verification
Collected Personal Data Types: Device information, facial information
SDK Name: Firebase
Purpose of use: App attribution analysis
Collected Personal Data Types: Device information, advertising identifiers, etc.
The data is used only for the credit assessment process and will not be shared with third-party organizations without your permission. We are committed to encrypting the data and ensuring the security of the information. By ticking on the check the box, you confirm that you are fully aware of and agree to the application and related terms. If you do not agree to the authorization, the application will stop working and will not be able to serve you. If you are not granted a loan, the information you provided will not be leaked, and the information you provided will only be used for loan assessment purposes, and the information will never be used for other purposes. If you do not repay during the repayment period, we have the right to access and use the your personal contact information, including FB, Instagram, Google+, etc.
You may visit the XLKASH Lending Facility and browse without having to provide personal details. During visits to the XLKASH Lending Facility, you may choose to remain anonymous and at no time can we identify Users of the XLKASH Lending Facility unless you have a XLKASH Lending Account and log on with a username and password.
When a User uses the XLKASH Lending Facility, creates or registers an account, uses the XLKASH Lending Application, receives a disbursement, pays using a bank, a payment gateway, a payment provider, or through other collections partners, or when a User avails of any other feature or products and services of the XLKASH Lending Facility and those provided by its service providers, the following personal information (“Personal Data”) may be collected:
The Personal Data may be collected through the following means:
You must submit to us information including Personal Data which is true and accurate and not misleading and you must keep it up to date and inform us of changes. We reserve the right to request documentation to verify information provided by you.How do you submit Personal Information / Personal Data?
We will only be able to collect your Personal Data if you voluntarily submit the information to us. If you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with some or all of the services available through the XLKASH Lending Application or XLKASH Lending Facility. You may access and update your Personal Data submitted to us at any time.What is the relation of my social media accounts with my XLKASH Lending account?
When you use the XLKASH Lending Application on a mobile platform, we may collect and record certain information such as your unique device ID (persistent/non-persistent), the hardware type, media access control (“MAC”), address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address, your profile information (if connected to any social media account including Facebook), and your location based on your Internet Protocol (“IP”) address. This information is useful to us for troubleshooting and helps us to understand usage trends. Whenever you use the XLKASH Lending Application, we may collect data about all of your interactions with the XLKASH Lending Application or usage of certain features of the XLKASH Lending Facility via server log files. This data is stored offshore within our cloud server.What is my log data and how will it be used?
When a User or visitor visits the XLKASH Lending Facility, the User’s or visitor’s browser may send the Company Personal Data which the Company collects for statistical and internal record-keeping purposes. The process of collecting this information is called “Log Data”, and may include information such as the computer’s IP address, browser type, browser version, the visited pages of the XLKASH Lending website, the time and date of the visit, time spent on the pages or other channels of the XLKASH Lending Facility including the XLKASH Lending Application, and other statistics.What are the other ways to collect my personal information?
We may also acquire information from you through (1) your access and participation in the XLKASH Lending service and/or the XLKASH Lending Application or Facility; (2) your participation in surveys regarding the XLKASH Lending service and/or the XLKASH Lending Application or Facility; and/or (3) your participation in a promo or contest through the XLKASH Lending service and/or the XLKASH Lending Application or Facility.What are cookies?
A cookie is a small text file which asks permission to be placed on the visitor’s computer hard drive. A cookie may be transferred to your computer or device, to identify a user’s computer or device and to “remember" things about your visit through your computer or device, such as your preferences or a user name and password. Once the visitor agrees, the file is added and the cookie helps analyze web traffic or provides internet usage information. Information contained in a cookie may be linked to your Personal Data for purposes such as improving the quality of the XLKASH Lending service, tailoring recommendations to your interests, and making the XLKASH Lending service easier to use. A visitor can instruct his or her browser to refuse all cookies or to indicate when a cookie is being sent. You can disable cookies at any time, although you may not be able to access or use some or all of the features of the XLKASH Lending service or the XLKASH Lending Application. A cookie in no way gives the Company access to the visitor’s computer or any information about the visitor, other than the data the visitor chooses to share with the Company.
We may feature recommendations served by third parties that deliver cookies to your computer or device so the content you access and recommendations you see can be tracked.What are third-party recommendations?
The User expressly and unconditionally consents to the access, possession, collection, storage, processing, use, analysis and/or distribution, disclosure, display, and delivery of any information (including Personal Data) related to the User, and to the transfer of such information to any third parties, including, but not limited to, the organizer/operator of payment facilities, third-party service providers, and third-party sellers, credit bureau and governmental bodies/agencies. The User acknowledges and authorizes: 1) the regular submission and disclosure of the User’s basic credit data (as defined under Republic Act No. 9510 and its Implementing Rules and Regulations) to the CREDIT BUREAU as well as any updates or corrections thereof; and 2) the sharing of the User’s basic credit data with other lenders authorised by the CREDIT BUREAU, and credit reporting agencies duly accredited by the CREDIT BUREAU.
By downloading and using the XLKASH Lending Application and/or the XLKASH Lending Facility, the User hereby expressly gives consent and authorization and is deemed to make the following statement:
“By downloading XLKASH Lending, I hereby give consent to the collection and processing of my personal information for legitimate business purposes, included but not limited to determining my credit score and providing a loan. I hereby certify that all the information provided by me is true and correct to the best of my knowledge, and that any misrepresentations or falsity therein will be considered as an act to defraud XLKASH Lending Corp. (COMPANY), its partners and affiliates. I authorize COMPANY to verify and investigate the above statements/information as may be required, from the references provided and other reasonable sources. For this purpose, I hereby waive my rights on the confidentiality of client information and expressly consent to the processing of any personal information and records relating to me that might be obtained from third parties, including government agencies, my employer, credit bureaus, business associates and other entities you may deem proper and sufficient in the conduct of my business, sensitive or otherwise, in accordance with Republic Act No. 10173 for the purpose of determining my eligibility for a loan which I am applying for. I further agree that applications and all supporting documents and any other information obtained relative to this application shall be used by and communicated to COMPANY, and shall remain its property whether or not my credit score is determined, or the loan is granted. I expressly and unconditionally authorize COMPANY to disclose to any bank or affiliate and other financial institution any information regarding me including the handling thereof to the Bangko Sentral ng Pilipinas, the Securities and Exchange Commission, Anti-Money Laundering Council, Credit bureaus and/or any other governmental body. In particular, I hereby acknowledge and authorize: 1) the regular submission and disclosure of my basic credit data (as defined under Republic Act No. 9510 and its Implementing Rules and Regulations) to the credit bureau as well as any updates or corrections thereof; and 2) the sharing of my basic credit data with other lenders authorized by the CREDIT BUREAU, and credit reporting agencies duly accredited by the CREDIT BUREAU.”
The User hereby consents to and authorizes COMPANY and the lender and/or their third-party partners for the purpose of providing the Services, including conducting user profiling, identify check and verification, fraud detection, monitoring and prevention, credit investigation, credit scoring and credit collection, to obtain pertinent credit, transaction and Personal Data from his/her employer, banks, credit card companies, retailers, telecommunications providers, IT services, and other relevant institutions in the course of such investigation, to verify any and all of the collected information of User, to collect any and all information related thereto, and to process any such information, from whatever relevant source. The User further acknowledges, understands, accepts and agrees that the User’s Personal Data may be shared to a business and/or or marketing partner, corporate (i.e. registration using a referral code, link, banner or similar referral identification method) or individual who have referred the User to register, obtain a loan or otherwise obtain or avail of the services from the XLKASH Lending Facility using a unique identifier (i.e. reference code) for such corporation or individual.
The User hereby consents to and authorizes the release by COMPANY, its subsidiaries and affiliates, his/her employer, the banks, the credit card companies, to release any and all information required by COMPANY, its subsidiaries and affiliates and/or its third-party partners, such as, but not limited to, the following:
For the avoidance of doubt, the User hereby acknowledges and agrees that COMPANY and/or a lender in the XLKASH Lending Facility, may, conduct the processing of Personal Data on its own, or at its sole discretion and option, outsource the processing and use of such information to third-party subcontractors and/or service providers, within or outside the Philippines. Such third parties may include, but is not limited to, any member of the Company, COMPANY and its subsidiaries and affiliates, which in each case shall be subject to an outsourcing agreement in accordance with law.
For avoidance of doubt, the User hereby acknowledges and agrees that lender, its third-party subcontractors, COMPANY and its subsidiaries and affiliates may share any and all information relating to User to each other for any legitimate business purpose including, but not limited to, credit investigation, credit scoring, credit collection, product and systems development, sales and marketing activities, communications relating to their products and/or services, and the like.What are the use/purpose of personal data?
The Personal Data shall be processed, collected, used, disclosed, stored and retained for the following purposes:
As some practical examples in connection with the above-mentioned uses and purposes, we may use information of Users to:
Your Personal Data may be shared with the Company and its affiliates in the conduct of its business for processing as may be required in the maintenance and performance of its duties and responsibilities under the XLKASH Lending Facility, in accordance with applicable laws, rules and regulations. The Company or entities which are its subsidiaries or within its affiliate network may, as necessary, be engaged by COMPANY as subcontractors or data processors in each case with respect to the purposes enumerated above.
Personal Data in connection with a lender may be shared with borrowers availing the XLKASH Lending services. As a borrower, your Personal Data will be shared with the lenders in order to allow the lenders to assess your credit history and such other information the lender will require to confirm your credit history and credit score and to determine or assist in determination of decisions as part of screening of borrowers, registrations, pre-approval of the lender’s financial products and services or loan applications. Your information may also be shared with third-party purchasers of any loans including Non-Performing Loans. In the event that your loan or other financial product is assigned, ceded, taken over, purchased or is otherwise transferred to any other party, all your records, transactions, any other information (including personal and sensitive personal information) about you, as it relates to the issuance, history, basis, and status of such loan or financial instrument, shall be shared, transferred and delivered to such third party.
In general, User Personal Data may be disclosed to the following:
All data processing, subcontracting or data sharing agreements will be in accordance with the requirements under the Data Privacy Act of 2012, or applicable laws and regulations as may be hereafter passed and implemented. To the extent that such processing, subcontracting, or data sharing requires notice or consent, we will provide or request for such notice and/or consent, in each case, prior to any processing or sharing of your Personal Data.
Please note that should you agree to sharing of information with other third parties for their own marketing purposes, handling of your Personal Data shall be subject to their separate privacy policies and should you wish to opt-out of marketing or promotional emails from these third parties, you should contact these parties directly.
We may release your information including Personal Data as permitted by law or when we believe that release is appropriate to comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another Company. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.
Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of the XLKASH Lending Facility, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted through the XLKASH Lending Facility, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.How will your personal data be retained?
Your Personal Data will be retained by the Company for the duration of your activities and transactions in connection with the products and services availed of in this XLKASH Lending Facility and/or for such period of time required for legal and regulatory and/or other legitimate business purposes, and will be disposed of in a secure manner that would prevent further processing, unauthorized access or disclosure to any other party or the public or prejudice your interest, provided that the Company may retain copies of your Personal Data in the Company’s archives for the purpose of determining its continuing obligations or pursuant to its bona fide record retention or data back-up policies, access to which shall be restricted on a need-to-know basis, as may be required under applicable laws and regulations. The Personal Data may likewise be retained for the purpose of fraud prevention, detection, and monitoring in accordance with the Company’s fraud detection and prevention policies, and any requirement imposed by any credit agency, bureau or agency in order to prevent fraud, identify theft, anti-money laundering, terrorist financing and other similar causes which are consistent with public policy and the public good.How does the Company secure your personal data?
The Company values Personal Data collected, used, retained and stored through the XLKASH Lending Facility. The Company has adopted technical, organizational and physical measures to protect your Personal Data,
We take reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration by third parties.
Although we make good faith efforts to store the information collected on the XLKASH Lending Facility and/or the XLKASH Lending Application in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our system. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers" from illegal obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties.How do you access and correct your personal data?
If you wish to exercise your right to access, correction, cancellation, portability and objection rights as described below, or for complaints and other inquiries, please email email@example.com to the attention of Data Privacy Officer:
Please note that if your Personal Data has been provided to us by a third-party (e.g. a referrer), you should contact that organization or individual to make such queries, complaints, access and correction requests.How can you exercise control over your personal data?
Users retain control over their Personal Data, and may amend their Personal Data registered over the XLKASH Lending Facility database.
The User shall be responsible for maintaining the confidentiality of his or her own XLKASH Lending Account and password, as well as any and all applications submitted, obligations agreed to or entered into and all other activities occuring under the said account. The User agrees to immediately notify the Company of any unauthorized use or disclosure of the User’s account or password, any unauthorized activities under the User’s XLKASH Lending Account or any other breach of security.
The Company and/or the Company will not be liable for any loss that the User may incur as a result of a third-party’s use of the User’s XLKASH Lending Account or password, either with or without the User’s knowledge, without fault or negligence on the part of the Company and/or the Company.
The User may be held liable for any damage or loss incurred by the Company or the Company in connection with or arising from a third-party’s use of the User’s XLKASH Lending Account or password, without fault or negligence on the part of the Company or the Company.What are the implications of third-party service?
You may opt-out of receiving promotional emails or other notification channels from us by following the instructions in those emails or notification channels. If you opt out, we may still send you non-promotional emails or notifications, such as emails or notifications about your accounts or pertaining to our ongoing business including where due notices are required under law or regulation, for the purposes of User protection, or in the circumstances the Company deems that it is necessary to keep Users updated via written notice. Please note that should you agree to sharing of information with other third parties for their own marketing purposes, handling of your Personal Data shall be subject to their separate privacy policies and should you wish to opt-out of marketing through promotional emails or other notification channels from these third parties, you should contact these parties directly.What are your obligations as user?
You agree to inform us promptly, and in any event, within 14 calendar days, in writing if there are any changes to your information supplied to us from time to time, and to respond promptly to any request from us.
Users have the following rights regarding Personal Data:
3. Additional Information. If you are identified by a XLKASH Lending User as a Reference Person, Related Party Contact or Third Party Contact, we may contact you to ask for additional information about our User who named you as his/her reference person, to verify the information provided in a User’s application, and/or other information such as the User’s new address and/or new contact number, in the event that we have an important information for the User (for example, if a borrower defaults on his/her payment obligation to us) and we are unable to reach the User or borrower using the contact information that he/she provided to us.Statement For Users in relation to verification with Related Party Contacts and Third Party Contacts
4.1 If you provide information of nominated Related Party Contacts and/or Third Party Contact, you understand, accept, and expressly and unconditionally consent to the sharing and disclosure of any information related to the you (including your Personal Data and/or sensitive personal information), to your nominated Related Party Contacts and/or Third Party Contacts, as such Related Party Contact and Third Party Contact may be changed from time to time, for the purpose of:
4.2 In some instances, we also share Personal Data with our suppliers, including Company entities and other business partners who provide services to us, such as IT and technology service providers, marketing providers, communication services and printing providers, debt collection, tracing, debt recovery, fraud prevention, and credit reference agencies, and others. When we do so we take steps to ensure they meet our data security standards, so that your Personal Data remains secure.
The foregoing consents and authorizations shall continue for the duration of, and shall survive the termination of any loan agreement(s) signed by the borrower, or any other transactions, dealings, arrangements and accounts which borrower may have with, or avail from, the Company and the lender through XLKASH Lending service and/or the XLKASH Lending Facility.
As of August 2023ACCEPTANCE AND DIGITAL SIGNATURE