Privacy Policy

Last updated: November 12, 2023

The Company values the privacy and secures personal and sensitive data of its users. This Data Privacy Policy explains how we collect, use, disclose, and safeguard Your information when You visit, access, and use our mobile application (“Application”). Please read this Privacy Policy carefully. If You have any questions or comments about this Policy, please feel free to contact us through partnerships@cartera.com.ph. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.

We reserve the right to make changes to this Privacy Policy at any time and for any reason by updating the link or through other means of notifications, which modifications shall become effective on the day such modifications are posted or sent as notification. If You object to the updated Privacy Policy, as Your sole and exclusive remedy, You may choose to stop using, accessing and utilizing the Application.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by Your continued use of the Application after the date such revised Privacy Policy is posted.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to CARTERA REWARDS SOLUTION, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to CARTERA INTERCHANGE CORP with business address at 17C Citibank Tower 8471 Paseo de Roxas, Makati City 1226.
Country refers to the Philippines where the Application can only be downloaded, used and accessed
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet
Personal Data is any information that relates to an identified or identifiable individual
Service refers to the Application
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

When You download the Application and create an account (“Account”), we may collect certain Personal and Sensitive Personal Information (“Registration Information”) about You, such as:

Name;
Username;
Email address;
Mobile number;
Date of birth;
Present and/or permanent address; and
Login information

The above Personally Identifiable Information or PII are required to create an account to access and use the Application which is in accordance with the MINIMUM CUSTOMER DUE DILIGENCE (CDD) requirement under the Anti-Money Laundering Act of the Philippines (Republic Act No. 9160).

You will also be required to create a password in connection with the registration of Your Account. Once You register, You will be able to review and change Your access information at any time by accessing Your “Settings” page. You control Your user Profile and are able to correct or update Your user information through sending us an e-mail with proof documents at partnerships@cartera.com.ph

Information from Your Device's Phone Book (Contacts List)

As an e-wallet application, the app has the (1) send money and; (2) request money functions that require keying in the mobile application of another application user (“recipient”) as the account number. For convenient customer experience of these functions, You can allow access to Your device’s Contact List only accessing the mobile number of Your Contact as the recipient.

The application has the standard prompt on access permission on Your device’s Contact List. The data on the device’s contact list that the app has accessed to are not uploaded to our servers and/or our Service Providers for this Application. Alternatively, access to Contact List can be disabled anytime through the device’s settings.

The process of allowing access to a user device’s Contact List for a seamless user experience is an industry practice in the Philippines by banks, Electronic Money Issuers (EMIs) and other financial institutions that are mandated to follow the Data Privacy Act of 2012.

WE TREAT INFORMATION THAT WE ACCESSED ON YOUR PHONE BOOK OR CONTACT LIST AS PERSONAL INFORMATION AND ARE PROTECTED BY LAW UNDER THE DATA PRIVACY ACT OF THE PHILIPPINES (REPUBLIC ACT 10173).

Sensitive Personal Information

Nature of work or occupation;
Financial data such as source of funds or income;
Attestation on Political affiliation or ties via a checkbox;
Government or private ID numbers;
Gender identity;

Occupational and Financial Data

You also consent us to collect Your financial-related information such as source of funds, nature of work, etc. as a requirement for us to verify Your account in accordance with the ENHANCE CUSTOMER DUE DILIGENCE (EDD) as required under Anti-Money Laundering Act of the Philippines (Republic Act No. 9160) to be eligible for a higher transaction amount and access and use other features of the Application.

Political Affiliations and Ties (PEP Checkbox)

To combat anti-money laundering, You will be asked to do a self-attestation on whether You are holding a prominent government position or affiliated to one whether as a close associate or a family member (Politically Exposed Person or PEP). This attestation shall be in a form of a checkbox which You can untick if You’re not a PEP.

WE TREAT SENSITIVE INFORMATION ACCORDING TO THE RULES OF THE DATA PRIVACY ACT OF THE PHILIPPINES (REPUBLIC ACT 10173).

Collection of Image and Access to Camera and Photo Gallery

We collect the following through access permission of Your device’s camera or photo gallery:

Photos or images captured through Your device’s camera for critical application functionality
Photos or images saved on Your image or photo gallery for critical application functionality

Our application collects images and photos for critical application functionalities such as:

User verification which requires image capture of the following through Your device’s camera:

capture of image of Your valid proof of identification
capture of Your facial image to verify You as the Account Holder against Your submitted proof of identification

Application security through collection of Your biometric information stored on Your device for the biometric security feature to securely access the Application. We keep Your biometric login information for as long as You have it.
We upload the above images captured through the Application and biometric information in our Service Provider’s cloud storage which is a secured storage as part of the customer due diligence process mandated by Republic Act 9160 or Anti-Money Laundering Act (AMLA).

We also require Your access permission on Your device’s camera and photo gallery for application functionalities:

In-app payments via camera scan of a valid Quick Response (QR) code which is the main feature of our Application.
Other in-app transactions such as:

Send Money which can be done either (1) image scan via camera or (2) upload of QR code from Your image or photo gallery
Request Money which can be done either (1) image scan via camera or (2) upload of QR code from Your image or photo gallery

We do not collect or store images for the above functions and are not stored in any of our cloud storage.

The Application has the standard prompt on access permission on Your device’s camera. You also acknowledge and consent us to have access to Your device’s camera, image or photo gallery for You to be able to use critical Application functions above. To change our access or permissions, You may do so in Your device’s Settings.

Please be aware that any images or photos submitted to our platform may be stored on our servers for future use. However, we do not share these images or photos with third-parties and are used only for the above mentioned. By submitting an image or photo to our platform, You acknowledge and consent to our collection and storage of Your image or photo.

WE DO NOT HAVE ACCESS TO ANY OTHER FILE STORAGE OR THIRD-PARTY APPLICATIONS ON YOUR DEVICE ASIDE FROM YOUR DEVICE’S CAMERA, PHOTO OR IMAGE GALLERY.

YOU UNDERSTAND THAT NOT GRANTING THE APPLICATION ACCESS TO YOUR DEVICE’S CAMERA, IMAGE OR PHOTO GALLERY SHALL RESULT TO YOU BEING UNABLE TO USE CRITICAL FUNCTIONS OF THE APPLICATION.

In-App and Push Notifications

We may request to send You push notifications regarding Your account, transactions You executed using the Application. If You wish to opt-out from receiving these types of communications, You may turn them off in Your device’s settings.

Purpose for Which Data is Used

Data Collected	Interest / Legal Obligations	Consent
Name E-mail address Date of Birth Address	Contractual necessity	To take payment for premium services
Payment card details	Contractual necessity and legitimate interests – we have a legitimate interest in receiving payment for our premium services or facilitating Your transaction from accounts You hold with third-parties	To serve targeted advertisements to Users of the App
Demographic and location information	Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue	To send You marketing information about our offers and services
E-mail address	Legitimate interests – it is in our legitimate interests to promote our products and services and respond to Your queries to ensure that we provide a good service to Users and troubleshoot problems	To carry out research and analysis to help us improve the App
Log and usage data such as session information	Legitimate interests – it is in our interests to analyze the way in which Users are accessing and using our services so that we can further develop the Application and improve the service and its security (block accounts as part of our anti-spam procedures; prevent unauthorized behavior and to maintain the safety and security of our services)	To respond to correspondence and queries that You submit to us and provide security services to protect You as our Users
Gender identity	Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements	To send You marketing information about our offers and services
Occupation and financial information	Legitimate interests – we have a legitimate interest in making sure that Application Users have legal fund sources and that the Application are not funded by illegal sources and dirty money (i.e. trafficking and terrorism funds, cartels, etc.)	To comply with Anti-Money Laundering Act of the Philippines (Republic Act No. 9160)
Political affiliations and ties	Legitimate interests – we have a legitimate interest in making sure that Application Users have legal fund sources and that the Application are not funded by illegal sources and dirty money (i.e. political bribes, graft and corruption, etc.)	To comply with Anti-Money Laundering Act of the Philippines (Republic Act No. 9160)

Use of Your Personal Data

Having accurate information about You permits us to provide You with a smooth, efficient, and customized experience. Specifically, we may use information collected about You via the Application to:

Provide You with the features and functions for which You sign up for including to enable user-to-user communications, increase the efficiency and operation of the Application through requesting feedback about Your use or resolve disputes and troubleshoot problems.
Process payments, refunds, loyalty and rewards redemption and prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
Conducting analysis for purposes of research and marketing initiatives, including the creation of Account Holder’s personal profile based on his/her interests, preferences, mobility patterns from physical locations that he/she may visit, and other information that may be relevant for marketing and market research purposes;
Managing Account Holder’s account, providing customer care activities, monitoring the quality and security of the network, training the staff, and providing services in a timely and efficient manner, and ensuring Your fair and lawful use of the products and services provided by us;
Generating statistical insights based on Account Holder’s usage and other information to assist the Government in planning for healthcare, disaster, and other similar initiatives;
Credit scoring programs and initiatives, including but not limited to providing information to the Credit Information Corporation in furtherance of the objectives of Republic Act No. 9501, otherwise known as the Credit Information System Act;
Sending commercial and promotional advertisements and campaigns, loyalty and rewards offers, surveys, customer care, and after sales communications, and other broadcast push messages;
Sharing Account Holder’s personal data with our business partners, authorized third-party content providers, service provider for the Service and other authorized third-party services; and such other processing or disclosure that may be required under law or regulations.
Liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with our Service Provider to process, collect, store, monitor and analyze Your data and use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates:[ We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We require all third parties engaged by us to respect the security of Your personal data and to treat it in accordance with the law. Such third parties are only allowed to process Your personal data in accordance with our instructions, and not for their own purposes.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Our retention policy is seven (7) years in which we will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction (i.e. for data back-up purposes and recovery based on the Company or Service Provider’s Business Continuity and Disaster Recovery Policy) where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or change some of Your information at any time by signing into Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us by e-mailing us at partnerships@cartera.com.ph and providing us proof of identification to effect the change, update or modification of Your information.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by updating this link or through other means of notifications, which modifications shall become effective on the day such modifications are posted or sent as notification. If You object to the updated Privacy Policy, as Your sole and exclusive remedy, You may choose to stop using, accessing and utilizing the Application.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact us:

By visiting this page on our website: www.cartera.com.ph