Privacy Policy
Thank you for using Finplo Cash, a personal loan application operated by LENDORA LENDING CORP. (“LENDORA,” “we,” “us,” or “our”).
This Privacy Policy explains how we collect, use, process, store, disclose, retain, and delete personal information when you use Finplo Cash and its related services. We are committed to protecting your personal information and respecting your privacy rights.
We operate in the Philippines and are committed to complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations (“IRR”), and applicable issuances of the National Privacy Commission (“NPC”).
LENDORA LENDING CORP. is a duly registered and licensed lending company in the Philippines under Certificate of Authority No. 3101.
Before you accept a loan, Finplo Cash clearly displays the principal amount, applicable APR, all fees and charges, repayment schedule, total amount due, and each payment due date.
Please read this Privacy Policy carefully. Where consent is required, we will request your specific and affirmative consent before carrying out the relevant processing.
Information We Collect
To provide our loan services, verify user identity, evaluate loan applications, prevent fraud, and comply with legal obligations, we may collect and process the following categories of information:
Phone Number Information: We collect your mobile phone number to create and secure your account, verify your identity during registration and login, and send essential service-related communications.
Approximate Location permission: With your permission, we may collect approximate location information while you use Finplo Cash to confirm service availability and help protect against suspicious account activity.
Loan Application Information: We may collect information you voluntarily provide during the loan application process, such as your name, date of birth, address, employment information, identification details, loan application details, and other information necessary for identity verification, credit assessment, loan processing, repayment management, and legal compliance.
Identity Verification Information: For KYC and identity verification purposes, we may process government-issued ID documents, selfie images, facial verification results, and related authentication information submitted by you. Such information is used only for identity verification, fraud prevention, loan application review, and compliance purposes.
Camera Permission: We may request camera permission to allow you to capture ID documents, selfie images, or other required supporting documents for identity verification and loan processing.
Calendar Access:This app will obtain calendar access permission with the user’s consent to provide repayment reminders. You can always reject this permission at any time.
User-Selected Image Submission: You may choose to submit specific images or documents through a secure system image picker or file selection function. We only process the images or files that you actively select and submit.
Device,Network and Security Information: We may collect basic device and security information, such as device model, operating system version, network status, app version, and technical logs, to improve service stability, detect security risks, prevent fraud, and troubleshoot technical issues.
Loan and Service Records: We may process loan application records, approval results, disbursement records, repayment records, customer service records, and related transaction information necessary to provide and manage our loan services.
Advertising and Tracking: Your KYC data, government-issued ID, selfie, financial records and loan application details will not be utilized for advertising or behavioral marketing. Finplo Cash requests your permission through Apple’s App Tracking Transparency framework to access the Identifier for Advertisers (“IDFA”). Consent for tracking is not a prerequisite for loan application, loan disbursement or loan servicing.
Children’s Privacy Protection
Target Audience: Our services are intended for adults aged 18 years and above. We do not knowingly collect personal information from anyone under 18.
No Minor Data: If we discover that a minor (under 18) has submitted personal information, we will promptly delete such data and suspend or cancel the associated account.
Parental Rights: If you are a parent or guardian and discover that your child has provided us with personal information, please contact us. We will take necessary measures to delete the personal information of the minor.
How We Use Your Information
We may use your personal information for the following purposes:
To create, maintain and support your account.
To verify your identity and evaluate your loan applications.
To deliver loan services, process fund disbursement and repayments, and keep transaction records.
To notify you of application updates, service announcements, payment details, security alerts, and reply to your inquiries.
To identify suspicious behaviors, prevent fraud, secure accounts and ensure stable service operation.
To fix technical issues, analyze service performance, and enhance system stability and user experience.
To process complaints, settle disputes, enforce contractual terms, and comply with relevant operational requirements.
Information Protection Measures
The information will be retained for a reasonable period necessary for providing services, completing transactions, protecting users, preventing fraud, resolving disputes, executing agreements and fulfilling related obligations, and will be deleted, anonymized or securely destroyed once it is no longer needed. No storage or transmission method can guarantee absolute security; you should properly keep your passwords, verification codes and devices. If you suspect that your account has been accessed without authorization, please contact customer service immediately. We adopt a multi-level security framework to prevent personal information from being accessed, modified, leaked or damaged without authorization.
Third-Party Disclosure
General Principle: We do not sell, lease, disclose, or provide your personal information to any third party for their independent marketing, advertising, or commercial use, unless required by applicable Philippine laws and regulations or authorized by your explicit consent.
To ensure the proper operation of our loan services and provide a secure and efficient user experience, we may use the following third-party SDKs and service providers:
1.Dyna.AI (Facial Recognition and Identity Verification)
● Purpose: This service is used to confirm the user’s identity during the verification process and to help detect and prevent fraudulent, unauthorized, or suspicious activities.
● Information Collected: The service may process selfie photos and related facial biometric information submitted by the user for identity verification.
● Data Handling: Such information is collected only after obtaining the user’s consent. The data is transmitted securely through encryption and is used only for identity verification, security checks, and fraud prevention purposes.
2.Alibaba Cloud SDK (Image Upload Service)
● Purpose: This service is used to securely upload images authorized by the user, such as ID documents or selfie photos, for identity verification and authentication purposes.
● Information Collected: Only the images selected and submitted by the user are uploaded. The service does not access other photos, files, or gallery content on the user’s device.
● Data Handling: The uploaded data is transmitted via a secure HTTPS connection and is only used for real-name verification, related authentication processes, and feedback, and will not be used for any other unrelated purposes.
3. AppsFlyer
● Purpose: AppsFlyer is used for app-install attribution, advertising campaign measurement, and app-performance analytics.
● Information Collected: If you grant permission through Apple’s App Tracking Transparency framework, AppsFlyer may process the Identifier for Advertisers (IDFA), limited device information, and in-app event data, including app launches and loan application initiations.
● Data Handling: AppsFlyer does not receive your government-issued ID documents, selfie images, facial-verification results, bank account or e-wallet details, income information, loan application content, loan approval results, or repayment records for advertising or tracking purposes. Information is transmitted through secure HTTPS connections and used only for attribution, advertising measurement, analytics, and service improvement.
Our service providers may retain personal information only for the period necessary to provide their services or for the retention period described in this Privacy Policy, unless a different period is required by applicable law. We require service providers to securely delete or anonymize the information after the applicable retention period expires.
Your Rights as a Data Subject
Subject to applicable Philippine laws, you may exercise the following rights:
• Right to Be Informed
• Right to Access
• Right to Object
• Right to Rectification
• Right to Erasure or Blocking
• Right to Data Portability
• Right to Withdraw Consent, where applicable
• Right to File a Complaint with the National Privacy Commission
• Right to Damages
To exercise any of these rights, please contact us at:
lendoramark@lendora-lending.com
We may take reasonable steps to verify your identity before processing your request. Certain requests may be limited where continued processing or retention is required or permitted by applicable law.
Applicable Law
Philippine law governs and controls this Privacy Policy. We will make necessary revisions and updates to ensure your information remains effectively protected under applicable local privacy laws.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, or if you wish to exercise your rights as a data subject, please contact us through the following channels:
Email: lendoramark@lendora-lending.com
Account Deletion and Data Retention
You may request the deletion of your Finplo Cash account through either of the following methods:
1. In Finplo Cash
Open Finplo Cash and go to:
Me > Delete Account
2. By Email
Send your account deletion request to:
lendoramark@lendora-lending.com
Please provide your registered mobile number or other information reasonably
required to identify your Finplo Cash account.
You may submit an account deletion request at any time. However, deletion of your account cannot be completed while your account has any outstanding loan, unpaid balance, overdue payment, pending repayment, pending transaction, active dispute, investigation, or other unresolved obligation.
You must fully settle all outstanding amounts and resolve any pending matters before your account can be deleted. Submitting an account deletion request does not cancel, reduce, suspend, or waive any loan, repayment obligation, applicable charge, or other amount owed under your loan agreement.
After all outstanding obligations and pending matters have been resolved, you may contact us to complete the account deletion process. We may take reasonable steps to verify your identity before processing the deletion.
Following account deletion, personal information associated with your account will be deleted or anonymized, except for information that we are required or permitted to retain for legal, regulatory, accounting, audit, security, fraud prevention, dispute resolution, enforcement of loan agreements, or other lawful purposes.
Such retained information may include account registration information, identity verification records, loan applications, loan agreements, disbursement records, repayment records, transaction records, customer service records, fraud prevention records, and records relating to disputes or regulatory compliance.
Unless a longer period is required by applicable law or a lawful regulatory requirement, retained information will be kept for five (5) years from the date the account is deleted or from the date all loan obligations, transactions, disputes, and other pending matters are fully resolved, whichever occurs later.
During the retention period, the information will be used only for the applicable lawful purpose. After the retention period expires, it will be securely deleted, anonymized, or otherwise disposed of.
Legal Bases for Processing and Consent
We process personal information only when there is an appropriate legal
basis under applicable Philippine law.
Depending on the processing activity, the applicable legal basis may include:
• Your consent, where consent is required;
• Taking steps at your request before entering into a loan agreement;
• Performing and administering a loan agreement;
• Complying with legal and regulatory obligations;
• Preventing fraud and protecting account and service security;
• Establishing, exercising, or defending legal claims; and
• Pursuing legitimate interests that do not override your fundamental rights.
Consent is not inferred solely from installing, opening, or using Finplo Cash .
Where processing is based on consent, you may withdraw your consent, subject to applicable legal and contractual limitations. Withdrawal of consent will not affect processing lawfully carried out before the withdrawal.