FDS ASYA PHILIPPINES, INC., is committed to protect and secure your privacy and information. We acknowledge and regard your right to know how we collect, use, share, secure, disclose, retain and dispose your personal information and sensitive personal information.

This data privacy policy may be updated as we deem necessary to ensure responsiveness with the latest Data Privacy requirement, coverage, and security innovations and keep the best security to your personal information. We encourage you to check for privacy policy updates, especially when notified. This privacy policy is available in our website and application for your information and reference.

This privacy policy is to inform our customers and other owners of personal data regarding our compliance to the privacy principle of: transparency, legitimate purpose, and proportionality, and such other relevant requirements in the collection, processing, storage, disclosure, sharing, transmission, and retention of personal data as required by applicable privacy laws that specifically include the Philippine Data Privacy Act of 2012 (“DPA”), and its implementing rules and regulations (“DPA IRR”). This also outlines how Kplus collects and processes your personal information during the use of Kplus’ platforms such as but not limited to its app and website.

OUR SERVICES

As a mobile financial application, we have established the following online services:

Daily transfers and payments such as bills payment, fund transfers, pay loan dues to microfinance institution, rural bank, or cooperative that the user is associated with
Financial services such as cash-in and cash-out
Others - E-loading transaction, Kplus agent services

WHAT TYPES OF INFORMATION DO WE COLLECT, PROCESS, AND SHARE

We may collect, process, use, and share your personal data, as may be applicable, which may include your personal information or sensitive personal information.

Personal Information (PI) includes any information that can be used to identify an individual, reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual. This may include name, date and place of birth, specimen signature or biometrics (fingerprint, face recognition, palm print, etc.), photo, present and permanent address, source of fund or income, name of employer or the nature or self-employment or business, contact details such as personal telephone number, personal mobile number and personal email address, mother’s maiden name, marital status, and location.

Sensitive Personal Information (SPI) is any information that falls under the category of personal information with higher security impact which we gather from the supporting documents presented, such as: government issued IDs and/or documents, cardholder data (CVV/CVC, Expiry Date) user credentials (i.e. username and password, PIN/MPIN, etc), IDs issued by private companies that are duly registered with the Securities and Exchange Commission, student IDs for those who are not yet of voting age (below 18 years old), and device ID.

The information we collect are as follows:

A. Personal User Information

We may collect your personal information that will be used for your identification to prevent fraudulent actions to be made in our application. This may include:

Your full name and personal information such as birthdate, contact details, present address, age, marital status, citizenship, place of birth, gender, government issued ID and number, educational attainment;

Your sources of funds such as occupation, nature of business (if applicable) other sources of funds, and monthly income.

Your account information with your bank or institution such as customer identification, institution/branch, unit, and center;

Your username, password, MPIN, biometrics, and/or other details used for authentication credentials for verification purposes;

Mobile phone number:
a) for sending of SMS as a formal notification of the transaction made in the application, and
b) in sending OTP for security and validation purposes; and

Email address to be used in the future as another medium to send the OTP or the formal notification of the transaction made in the application.

B. User Contact List

We may collect information from your phone book contact list for user's convenience when doing the following transactions:

For E-Load transactions in the app - user can import from his/her contact list instead of typing contact number; and

For filling out a transactional form in the app that requires a mobile number from the contact list (e.g., fund transfers, agent assisted payment).

C. Device Information

We automatically gather the information of your device for tracking and preventing fraudulent transactions as well as for user credentials and identification. We collect the following items:

Device identification for tagging transactions with your device (e.g., financial transactions);

Device location to be used to analyze if the transaction made with Kplus is fraudulent; and

Device model and manufacturer for performing analysis in determining fraudulent transactions.

D. Network Provider

We automatically check your network for the purpose of the following:

To know if your network have enough connection strength to perform a transaction to prevent encountering an error during your transaction.

E. Camera, Photos and Files

We may request access to your camera, photos, and/or files for the following purposes:

To import or scan QR Codes for faster filling out of transactional forms (e.g., fund transfers, agent-assisted cash-in or cash-out); and

For saving user identification, QR Codes, transaction summary, and user settings.

F. Biometrics

We may collect your biometrics, such as fingerprints, stored in your device when you enable the use of biometrics when logging in and as mobile key in authorizing your transactions instead of typing your MPIN.

G. Information Provided When You Contact Us

When you contact us via chat or phone, we record our conversation and collect your personal details and your concerns.

WHY WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information in order to facilitate your transaction needs as you avail the features of the Kplus app.

1. To verify your identity during registration (Know-Your-Customer or KYC information)

Before you can create and use your Kplus e-wallet, we're required by law to verify your identity. This helps us monitor your transactions and report any suspicious activities to financial regulators, ensuring compliance with anti-money laundering laws. These laws prevent the hiding of money from illegal sources.

2. To deliver our financial services

We collect your personal information to enable easy and instant access to our financial services. For example, to process bill payments via the Kplus App, we collect your name, account and contact information, and payment method, ensuring accurate payment application by the receiving company.

We also look at how you use the Kplus features to identify potential special offers. This may include checking if your account is set up correct, if you keep enough fund, how many times you use services like bill payments, e-loading, loan repayment history (early/on-time).

3. To prevent potential fraud and manage risk

Your personal information helps us protect you, our partners, and our business against potential fraudulent activities. We also use it for risk analysis. For example, we may verify your biometrics during transactions to confirm it is really you.

4. To personalize your experience

We collect and analyze your personal information to personalize our offerings. By understanding what you like and need, we can recommend products, services, and features designed to meet your needs. This makes your experience even better.

5. To improve customer experience and product research

We process your information to identify market trends and understand your needs. This helps us enhance your experience when using the Kplus and develop innovative products to meet your preferences and needs.

We may also process your personal information to study how you use the application and its features, helping us improve our services.

6. To improve our customer service

Our Customer Service Team may collect other personal information from you to answer your concerns or questions properly. We also record any calls and chats to also improve our customer service better.

7. To advertise related services or products

We may use your personal information to display ads related to our services that may fit your preference or need and be able to evaluate effectiveness and reach of ads and services;

8. To send you communications and updates

We may use your personal information to send you updates about our products and/or advisories that are relevant to you; and

9. To follow any safety, security, public service, or legal, or regulatory agency requirements and processes.

We collect your Personal Data abiding to the rules and regulations of the Bangko Sentral ng Pilipinas and the Data Privacy Act of 2012 and its Implementing Rules and Regulations to ensure there will be no imminent harm to you and the public safety and security.

Before we use and process your information, we ensure that we ask for your consent especially when required by the law’s rules and regulations.

OUR WAY OF COLLECTING PERSONAL DATA

We may collect your Personal Data when you:

complete the application form distributed by our partner institution or the rural bank/MFI you are member with;

use of the Kplus features through the mobile application;

give access to the biometric saved in your mobile phone to enable biometric login and mobile key for authorizing transactions;

authorize another company to transact with us or when they send us your personal data if you exercise your right to data portability;

disclose your personal information through phone calls, emails, SMS or verbal communication with our authorized representatives and partners; and,

visit and contact us through our official websites.

Collection of your Personal Data rely to the fullest extent possible on the original source.

SECURITY AND PRIVACY OF YOUR PERSONAL DATA

Because we care about the security of your Personal Data, either in paper or electronic format, we take reasonable steps to protect it from misuse, interference, loss, unauthorized access, modification, and unauthorized disclosure by establishing and enforcing different security measures: technical, organizational, and physical.

Should there be a need to store your Personal Data with a third party data storage provider, we ensure to have a contract with providers containing appropriate measures that are aligned with FDSAP’s Data Privacy and Security Policies.

THE NEED TO SHARE YOUR PERSONAL DATA

In compliance with legal and regulatory requirement, there will be a need to submit your Personal Data to appropriate government agencies. When we are to share your Personal Data with other parties, we will ensure that it is secured and protected by ensuing an agreement for the data sharing which will demonstrate sufficient organizational, physical and technical security measures to protect your Personal Data.

1. Our Affiliates: we partner with different business to provide you with our services. For example, if you decide to register and use Kplus, we partner with rural banks and microfinance institutions (MFI) to reach you. We may share your information with the one you are associated with for KYC process. If you also decide to use Kplus to receive your loan proceeds, we may share your account information to the rural bank or MFI you are associated with.

FDS AP is the main company that runs Kplus. FDS AP is an associate member of CARD MRI in the Philippines and subsidiary of PT Sarana Pactindo in Indonesia. We may share your information with our CARD MRI affiliates either to provide you with services or when you avail a certain feature via the Kplus app. The member institutions of CARD MRI can be viewed at our website via this link: https

2. Partners: We team up with other businesses to bring you a wide variety of financial services. If you pay a bill using Kplus, we may share your personal details with that billing company.

3. Service Providers: To keep our services smooth and efficient, we share your personal information with trusted partners. These partners help us in many ways, from answering your questions and analyzing data to managing risks, preventing fraud, and processing your payments.

4. Fraud Detection Partners: We are committed to protecting you and all Kplus users from fraud and other criminal activities. By sharing certain personal information, we help create a safer and more transparent financial system for everyone.

5. Law Enforcement, Regulators, and Courts: We may share your personal information with law enforcement agencies, regulatory bodies, courts, and other public authorities. We only do this when legally required or when necessary to protect our rights, prevent fraud, and ensure the safty of Kplus users and the public.

6. Changes within Kplus: If Kplus/FDS AP merges with or is acquired by another company, or if our assets are purchased, we may need to share your personal information with that entity. Should this occur, we will inform you beforehand if your information will be transferred or if there will be any new privacy rules regarding its handling.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

We value and respect your rights provided in the terms of the privacy of your Personal Data under the Data Privacy Act of 2012.

Right to be Informed: You have the right to know how we handle your personal information.

Right to Access: You can request to see the personal information we hold about you.

Right to Object: If we're processing your information based on your consent or our legitimate interest, you can object to that processing.

Right to Erasure or Blocking: You can ask us to stop processing, withdraw, block, delete, or destroy your personal information.

Right to Damages: If your privacy rights have been violated and you've suffered harm, you have the right to claim compensation.

Right to File a Complaint: If you believe your personal information has been misused or your privacy rights infringed, you can file a complaint with the National Privacy Commission.

Right to Rectify: You can dispute and request us to correct any mistakes or errors in your personal information.

Right to Data Portability: You can ask us to securely move, copy, or transfer your personal information from our company to another.

We're here to help you access, correct, or move your personal information, unless legal restrictions apply. You can always ask for a copy of the information we hold, and we'll assist you in updating anything that needs correction. For more details on managing your personal information, you may contact our customer service representative or our Data Protection Officer.

RETENTION/DISPOSAL/DESTRUCTION

When you register to Kplus, we will collect, process, and share different types of information. This information will be kept safe and secure and will be kept and used as long as it is needed to comply with legal and regulatory requirements. Our retention for this information is as follows:

1. Personal Data (KYC): 5 years after account closure or last transaction made. If the account or a covered transaction involving the account is under investigation, all relevant records shall be retained, until the investigation is completed.

2. Transaction Records (Kplus Transactions): 5 years from the date of transaction.

3. Financial Reports and Audit Logs: 5 years, for audit purposes.

4. Submitted Reports to BSP: 5 years from the date of submission

5. Customer Support Communications: 5 years from the date of communication to support customer service and dispute resolution.

Once the data retention period has expired, the data must be securely disposed of. Data disposal applies to both physical records and digital data and must follow the following procedures:

Digital Data Disposal:

Data stored on servers, databases, and cloud storage will be deleted securely using industry-standard methods, ensuring the data cannot be recovered or read.

Hard drives and other digital storage devices will be degaussed or destroyed physically to ensure all data is permanently erased.

Physical Record Disposal:

All paper documents containing sensitive or personal information must be shredded then buried to prevent unauthorized access or data recovery.

CONTACT INFORMATION OF FDSAP

Should you need to get in touch with us for any data privacy concerns or requests or should you have any questions or clarifications regarding this Data Privacy Statement, you may our Customer Service Hotline at 09190986970. You may also e-mail us at [email protected].

Alternatively, for any pressing concerns, you may reach our data protection officer at the following contact information:

E-mail Address: [email protected]

Telephone Number: 09190986970

Address: GF 1519 D. Oliman St., Santiago Village, Brgy. Valenzuela, Makati City

CHANGES TO OUR PRIVACY STATEMENT

We may amend or modify the terms of this Statement from time to time to ensure relevance with the relevant laws and regulations applicable to FDSAP. Any relevant modification will be posted on our website and updated in other platforms as applicable.

CONSENT

FDSAP is committed to fully comply with the Data Privacy Act of 2012 and its implementing rules and regulations, as well as future amendments thereof, and therefore seeks your consent for FDSAP to collect, process, use, share, disclose, retain, and dispose your personal data for the purposes described in this document. By ticking on the checkbox agreeing to the consent form, you hereby voluntarily agree that you have given consent to the collection and processing of your personal information by FDSAP, as outlined in the consent form and in these terms and conditions.