PAYWAGE APP DATA PRIVCY POLICY

• Overview

In order for PayWage PHP Inc. to provide quality services, we rely heavily on personal information, including personal information of our users or any other individual in connection with any matter that we handle.

Given the importance of privacy of our users, we are committed to the highest standards of privacy and data protection compliance and expect everyone in our Company to adhere to these standards. We demand from our management, employees, and third party suppliers and service providers the highest standards of ethics and compliance with the Data Privacy Act of 2012 (“DPA”), its Implementing Rules and Regulations, and related issuances from the National Privacy Commission (collectively, “Privacy Laws”).

This Privacy Policy will help you understand: (i) what personal information we collect; (ii) how we collect, hold, use and disclose that information; and (iii) the purposes of such collection, holding, use and disclosure.

Please read carefully this privacy policy before accessing and using our Platform. This Policy serves as our notice to the user as to what, how, and why we process personal information. This Policy aims to inform the users of our data processing activities and make them aware of their rights and responsibilities.

• Consent

By checking the checkbox “I have read and understood this Privacy Policy and I consent to the processing of my personal information in accordance with this Policy” and clicking on the “Next” button, (1) you are indicating your desire to proceed with the creation of your account and usage of the Platform; and (2) you consent and agree to the collection, the use, processing, and disclosure of information in accordance with this Policy.

By using the Platform, you also warrant that prior to the creation of your account, you have authorized your employer and the Third Party Entities to provide us your Personal Information as identified below so you may use the Platform.

• Definitions

The following words and terms shall have the meaning set forth below, unless repugnant to the context and/or otherwise mentioned:

1. “Company” / “We” / “Our” / “Us” shall mean PayWage PHP Inc.
2. “Commission” shall mean the National Privacy Commission of the Republic of the Philippines.
3. “Personal Information” shall mean any information in the possession of, or likely to come into the possession of the Company, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the Company, or when put together with other information would directly and certainly identify an individual. It does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
4. “Platform” shall mean the mobile application and/or website operated by the Company called “PayWage” used by Users to allow the Users to access information regarding their earned wages before the end of the current payroll cycle.
5. “Third Party Entities” shall refer to third parties, such as but not limited to our advertisers, our clients, or such other counterparties which may offer their own information, products and/or services on the Platform which users may avail of
   
6. “You” / “Your” / “User” shall mean the users accessing or using the Platform or submitting any information on the Platform.

• To what does this Privacy Policy apply?

This Policy applies to the processing of Personal Information through the services we offer through our Platform.

This Policy does not apply to any website, product or service of any third-party organization even if the website links to (or from) our Platform. Please always review the privacy practices of any third-party organization before deciding whether to provide any information.

• Our Services

To know more about our services, please read our terms and conditions at https://paywage.ph/app-terms-conditions/. Through the Platform, the Company provides technological services to its customers or their clients which would allow their employees, such as yourself, to access information about their earned wages. Necessarily, if you are using this Platform, you do so in relation to our provision of services to your employer and your bank or such other third party service providers, and your availment of their products and services.

In this regard, we are a personal information processor (PIP), as defined under the Privacy Laws. Meanwhile, the personal information controllers (PIC) are the Third Party Entities whose products and services you avail of, and your employer who provides your information to us. You are able to use this Platform pursuant to our agreement with the Third Party Entities, and their agreement with other third parties. The identity of the PIC may be seen during the registration process. As such, we only process our users’ personal information in accordance with the instructions of the Third Party Entities. PayWage is the operator of this Platform and is only a technology provider.

Further, PayWage does not provide any payment, lending or financing products or services.

If you have any concern with respect to how the Third Party Entities, or the other parties which you have authorized, process your personal information, kindly contact them directly.

• What Information do we Collect?

When you use the Platform or when you make use of the services in this Platform pursuant to our agreement with the Third Party Entities, we may ask you to provide us, and we may collect and process the following Personal Information (“User Data”) as required by the Third Party Entities whose services or products you avail:

From you…	From parties you have authorized to provide us with the information, or the Third Party Entities…
●      Full Name ●      Phone Number ●      Tax ID Number ●      Current Address ●      Permanent Address ●      Date of Birth ●      Place Of Birth ●      Nationality ●      Sex ●      Marital Status ●      Employment Address	●      Full Name ●      Internal Employee ID ●      Phone Number ●      Payroll Account Number ●      Date of Birth ●      Email ●      Employment Address ●      Employment Start Date ●      Gross Salary ●      Salary Type (Regular / Hourly)

We process User Data based on the following legal bases:

1. Consent: We process your data if you have given us specific consent to use your personal information for the specific purposes set out in this Privacy Policy.
2. Performance of a Contract: We process your User Data pursuant to our contractual obligations to the Third Party Entities and in order to provide our services in accordance with those agreements. You may directly contact the Third Party Entities, who are identified when you use the Platform and avail of their products or services, or your employer if you have concerns or questions as to their legal basis in processing your personal data.
3. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Pursuant to our legitimate interests, we may also collect information on how the Platform is accessed and used (“Usage Data”) which may include information such as your device type, operating system, your device’s Internet Protocol (IP) address, the pages of our Platform that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, operating system, other diagnostic data, and your general location. We use cookies and similar tracking technologies to track the activity on our Platform and hold certain information.

We may also collect the following information:

• • Information you choose to include in your profile or post in public areas of the Platform;
  • Information you may provide in connection with specific features of the Platform; and
  • Non-personal information which may be linked to your Personal Information, including Personal Information about your use of our Platform.

• Why do we Process your Personal Information?

We process User Data for the following purposes:

• To comply with our legal obligations under contract with your employer which you have authorized to give us your personal information, and the Third Party Entities whose products and services you may avail;
• To provide the platform whereby the salary-on-demand or earned wage access services of the Third Party Entities is made available to you by providing you the necessary information on your earned wages in the Platform;
• To perform lead generation services for the Third Party Entities in relation to their products and services;
• To facilitate the delivery of our other products and services in the Platform;
• To communicate with you about your account and our Platform (including responding to inquiries and sharing information about new features, as well as offerings from the Third Party Entities that may be of interest);
• To establish and defend legal rights.

We process Usage Data for the following purposes:

• To understand and improve our Platform and develop new or improved services;
• To personalize your experience in the Platform.

We may also use de-identified or aggregated information for product development, research, analytics and other purposes, including for the purpose of analyzing, improving or marketing our Platform, for demonstrating the impact of our Platform or conducting educational research.

We will not process your personal information in ways incompatible with the above-stated purposes.

• Processing And Disclosure of Information

We will only disclose your Personal Information to our service providers, such us our legal counsel, in all cases pursuant to the purposes stated above, or as may be authorized by law and regulations.

We take great care to protect the Personal Information you provide to us, and we do not sell your Personal Information to third parties.

We may also share de-identified or aggregated information that does not reasonably identify any individual.

As may be required by law, we may disclose your personal information to law enforcement authorities or other relevant government agencies pursuant to their lawful purposes and mandate.

• What are your rights as a data subject and how do you exercise them?

As a data subject whose Personal Information will be collected and processed by us, you are entitled to the following rights, pursuant to Section 16 of Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and Section 34 of its Implementing Rules and Regulations:

1. 1. Right to be informed
   2. Right to object
   3. Right to Access
   4. Right to Rectification
   5. Right to Erasure or Blocking
   6. Right to Lodge a Complaint with the NPC and the Right to Damages

You may exercise your rights by sending an email to our Data Protection Officer, as instructed below. However, as we are a PIP, we, where necessary and appropriate, shall coordinate your request with, and oftentimes direct you to, the appropriate PIC who can adequately address your request.

• Data Retention

Whatever Personal Information given to us by you or pertaining to you shall only be retained for as long as necessary:

• For the fulfillment of the declared, specified, and legitimate purpose, or when the processing relevant to the purpose has been terminated;
• For the duration of our agreement with our customers;
• For the establishment, exercise, or defense of legal claims; or
• For legitimate business purposes, which must be consistent with standards followed by the applicable industry or approved by the appropriate government agency.

Upon termination of the relevant contract of the Company with a PIC, all Personal Information of the Users identified to be a data subject of such PIC shall be removed or anonymized within six (6) months from the date of termination.

Personal Information provided to us by you shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party, or prejudice the interests of our customers.

• How do we protect your personal information?

The Company has put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to correctly use the Personal Information we collect. These safeguards vary based on the sensitivity of the Personal Information that we collect and store.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact our Data Protection Officer immediately.

• What about changes to this policy?

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Company’s Platform, website, premises, or when distributed to its Users.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Information collected by posting them on our Platform and/or website. By using our services, you agree that electronic disclosures and notices have the same meaning and effect as if we had provided you with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Information shall be considered to be received by you within twenty-four (24) hours of the time they are posted on our website.

• Third Party Links And Cookies

Occasionally, at our discretion or under the instruction of the Third Party Entities, we may include or offer third party products or services on our Platform. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Platform and welcome any feedback about these sites.

We may use cookies and other similar technologies for storing data to help provide you with better, faster, safer, and personalized experiences when you use the services or access the Platform. When you visit the Platform through your computer, mobile device, or any other device with internet connectivity, our servers may automatically record data that your browser sends whenever you visit a website. This data includes:

1. your computer or device’s IP address;
2. browser type;
3. device and operating system type;
4. the pages/screens within the Platform which you visit; and
5. the time spent on those pages/screens, items and data searched for on the Platform, access times
6. and dates, and other statistics.

This data is collected for analysis and evaluation for the purposes stated in this policy and in order to help us improve our Platform and the services and products we provide.

Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser and help us to personalize the content to match your preferred interests more quickly, and to make the Platform more convenient and useful to you. You may be able to manage and delete cookies through your browser or device settings. For more information on how to do so, visit the help material of your browser or device.

• How can you reach us?

If you have any questions or suggestions about this Privacy Policy or would like to access or seek correction of your Personal Information, or if you have any complaints regarding our privacy practices, please contact our Data Protection Officer:

Data Protection Officer

Address: Paywage Inc. Unit 1702 High Street South Corporate Plaza Tower 2, BGC, Fort Bonifacio, Taguig

Tel. No.: 09177207524

E-mail: data_protection@paykey.com

Please note that you, as the requesting party, would have to pay the reasonable costs and expenses incurred by the Company for producing the requested information.

Because email communications are not always secure, you are asked not to include credit card or other sensitive data (such as racial or ethnic origin, political opinions, religion, health, or the like) in emails sent to us.