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Privacy Policy

PXT LENDING INVESTORS INC., its assigns, affiliates, and related companies in the conduct of its business in the Philippines (hereinafter referred to as "Company") values the privacy of our Users and any person who uses, accesses, downloads, browses, or registers with the Services on the PXT Loan website, its application, or other related digital medium or media, including social media (hereinafter referred to as "Platform"). This Privacy Policy is part of PXT Loan commitment to respect and protect every personal data and information belonging to the individual users of the Platform, including prospective lenders or borrowers (hereinafter referred to as "User", "You", or "Users") or visitors to the Platform. This Privacy Policy has been prepared in accordance and in compliance with the laws of the Republic of the Philippines, and is for the exclusive use of the Company. This Privacy Policy sets out the policies of the Company, its assigns, affiliates, and related companies in relation to any and all types of Personal Data (as defined below) referred to in this Privacy Policy, including sensitive personal information. In this Privacy Policy, "Personal Data" means any information 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 entity holding the information, or when put together with other information would directly and certainly identify an individual, as defined under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (hereinafter referred to as the "Data Privacy Act"). Personal Data may be provided by individual users of the Platform, for the collection, use, and disclosure by the Company, its assigns, affiliates, and related companies.

All names and other Personal Data which relate to Users shall be handled in the manner set out in this Privacy Policy. We only collect information where it is necessary for us to do so and we will only collect information if it is relevant in our dealings with Users. We will only keep Users' Personal Data for as long as we are either required by law or as is relevant for the purposes for which the information was collected.

The scope of this Privacy Policy is limited to information collected or received by us through your use of the Platform. We are not responsible for the actions of third parties or companies, the contents of their facilities, the use of information you provide to them, the information they provide to you or any products or services they may offer. Any link to those sites does not constitute our partnership with, sponsorship or endorsement of, or affiliation with, those parties or companies or their brands.

By using the services provided by the Platform, whether via website or application, you are expressing your agreement to this Privacy Policy and the processing of your Personal Data in the manner provided in this Privacy Policy. If you do not agree to these terms, please do not use and exit the Platform.

Revolving Credit Services

The Platform may provide users with a revolving credit facility, which allows qualified users to repeatedly draw, repay, and reuse available credit within an approved credit limit, subject to applicable terms, risk assessment, and account status.

To support these revolving credit services, we may continuously process and evaluate user information, repayment behavior, account activity, transaction history, device information, and risk-related indicators during the lifecycle of the user's account and credit relationship with the Platform.

Such processing is necessary to:

manage available credit limits;

assess eligibility for additional withdrawals or loan orders;

restore or adjust available credit after repayment;

conduct ongoing credit evaluation and fraud prevention;

ensure platform security and regulatory compliance;

improve risk control models and service quality.

By using the Platform and its revolving credit features, you acknowledge and consent to such continuous processing of your personal data in accordance with this Privacy Policy and applicable laws.

Personal Information Collection Items and Collection Measures

We collect information to provide a better service to the users. We will not collect your personal data without your permission.

1.Information provided by users

When joining as a member, we may collect the following information for the user's personal services: (1) full name, (2) email address, (3) residential address, (4) telephone number, (5) emergency contacts, (6) employment information, (7) monthly income, (8) date of birth, (9) gender, (10) ID information, (11) beneficiary's bank account information

2.Information collected during use of service

We collect information about the applications and devices you use to access the services of the Platform, which helps us to provide you with services. The information and permissions we collect includes: (1) LOCATION; (2) CAMERA; (3) STORAGE; (4) PHOTOS(GALLERY); (5) PHONE INFORMATION; (6) ADVERTISING ID; (7) INSTALLED APPLICATIONS; (8) APP USAGE; (9) Biometric Information; (10) SMS (11)Push_notification (12) ACCESS_WIFI_STATE

Objectives of Personal Information Collection and its Legal Basis

1.LOCATION

We collect your approximate geo-location information when the Platform is running in the foreground so as to auto-fill your address data. We endeavor to cease collection of your approximate geo-location information when the Platform is in the background. You can always choose to disable the approximate geo-location tracking information on your Mobile Device temporarily.

2.CAMERA

We need to use your camera to allow you to take photos of your ID or a selfie for identity verification and authentication purposes. This action will only be performed with your authorization, and all collected data will be securely transmitted via encrypted channels.

3.STORAGE

We require the storage information permission that allows the Platform to enable you to upload photos and/or documents to complete the application form during your loan application journey.

4.PHOTOS(GALLERY)

We may need access to your photo gallery so that you can upload ID documents or other required files to complete identity verification or support your application. We will only access photos with your explicit consent, and all data will be securely transmitted and stored.

5.PHONE INFORMATION

The phone information includes device brand, model, operating system version, device unique identifier, device network environment, WIFI, device status, identification international mobile device, application software information, mobile phone number, device memory information. The authorization to access this information help us to identify your user portrait and preferences and to recommend the suitable credit products.

6.ADVERTISING ID

We collect your Ad ID, a unique identifier assigned to your device by your operating system, which can be reset when needed. This allows us to provide you with more personalized financial services, optimize ad content, and ensure the security and customization of your account.

7.INSTALLED APPLICATIONS

We may collect limited application environment information from the device, strictly for fraud prevention, device security verification, and risk control purposes.

We do not access application content, personal communications, or unrelated user data.

We do not collect the content of other applications, user credentials, personal communications, or unrelated personal files.

8.APP USAGE

We collect data related to your behavior while using the app, such as feature usage frequency, time spent on pages, and click actions. This helps us improve user experience and service quality. All data will be collected only with your consent and will be kept strictly confidential, never used for unauthorized purposes.

App usage data is collected in aggregated or behavior-based form and is not used to access personal content unrelated to the Platform.

9.Biometric Information

We collect your facial biometric data by requesting a live photo of your face during the facial recognition process, and use it to verify your identity, confirm that the loan application is submitted by you (both at the time of application and during any subsequent verification, including in the event of a dispute), and prevent fraudulent loan activities.

10. SMS

With your explicit consent, the Platform may access limited SMS information strictly related to financial transactions and identity verification, such as one-time passwords (OTPs), repayment reminders, salary notifications, or bank transaction messages, solely to support account security, fraud prevention, and loan application verification.

We do not collect personal conversations, social messages, promotional content, or unrelated SMS data.

All accessed data is encrypted during transmission and storage and is processed in accordance with applicable laws and platform policies.

11.Push_notification

We may request permission to send push notifications and in-app messages to keep you informed about important account activities and service-related updates.

These notifications may include:

· loan application updates;

· repayment reminders;

· due date alerts;

· account security notifications;

· transaction confirmations;

· important policy or service announcements;

· in-app messages related to your account and credit services.

Push notifications are used solely to support the normal operation of the Platform and improve user experience. You may disable push notifications at any time through your device settings.

We do not use push notifications to collect personal data from your device.

12. ACCESS_WIFI_STATE

We may collect limited Wi-Fi connection information from your device to support risk control, fraud prevention, security monitoring, and service stability.

This permission allows the App to access basic Wi-Fi network status information, such as:

• Whether Wi-Fi is connected or enabled
• Network connection status and type
• Basic network identifiers necessary for device and risk assessment

We use this information solely for:

• Fraud detection and prevention
• Risk assessment and account security
• Device and network environment verification
• Improving service reliability and preventing abnormal activities

We do not use this permission to access your personal files, messages, browsing content, or unrelated personal data.

Third-Party SDK Disclosure

To ensure service quality, enhance user experience, and provide necessary features, our application integrates the following third-party Software Development Kits (SDKs). Prior to integration, we have assessed their data collection behaviors. All data is collected only after obtaining user consent and in compliance with relevant regulations and platform policies.

1.AppsFlyer (User Behavior Analytics)

• Purpose: Used for analyzing user acquisition sources, behavior flows, and ad conversion efficiency to optimize marketing and product performance.
• Information Collected: Device identifiers (such as Android ID, GAID), app installation/open events, and in-app user actions.
• Data Handling: Data is transmitted securely using encryption. AppsFlyer does not access users' sensitive personal identity information.

2.Dyna.AI (Facial Recognition and Identity Verification)

• Purpose: Used to verify user identity during the authentication process and help prevent fraudulent or unauthorized activities.
• Information Collected: Selfie images and related facial biometric data submitted for identity verification purposes.
• Data Handling: Data is collected only with the user’s explicit consent and is securely transmitted using encryption technologies. The information is used exclusively for identity authentication and fraud prevention purposes.

3.Firebase SDK

• Purpose: To ensure optimal app functionality and a seamless user experience, we employ Firebase SDKs for performance monitoring, error diagnostics, and service enhancement.
• Information Collected: Information automatically gathered includes technical device details (e.g., hardware type, operating system), patterns of app interaction, and diagnostic logs such as crash reports and latency metrics.
• Data Handling: Collected data remains anonymized and is used exclusively in aggregate form. No personally identifiable information is extracted or stored.

4.Alibaba Cloud SDK (Image Upload Service)

• Purpose: Used to securely upload images authorized by the user (e.g., ID cards or selfies) to the cloud for identity verification.
• Information Collected: Only the images explicitly selected by the user for upload; no other device or gallery data is accessed.
• Data Handling: Data is transmitted using HTTPS and is solely used for real-name authentication, never for other purposes.

VALIDITY AND ACCURACY OF INFORMATION SUBMITTED

1.Submission of True and Accurate Information - 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 as soon as practicable. We reserve the right to request for documentation to verify information provided by you.

2.Voluntary Submission of 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 Platform.

Disclose your personal data to third parties

You have the privacy right to your personal data. Our Company will only disclose your personal data to third parties under the following circumstances, the relevant institutions will collect, use, and/or disclose your personal data within the scope of your authorization and consent:

• Disclosure to authorized employees of our company and its affiliates, including our company's auditor or external auditors, financial cooperative institutions, and/or third parties that are related to our company;
• Disclosure to enable you to trade and/or use services that you desire;
• Disclosure to the Credit Bureau (a type of credit reporting agency);
• Disclosure under legal investigation or legal actions;
• Disclosure in accordance with laws, government orders, or regulatory requirements.

To help you successfully apply for the loan, we will disclose your necessary personal data to third-party cooperative institutions, including fund lenders, payment partners, post-loan partners, third-party verification service providers, messages service providers, call-out service partners.

USE/PURPOSE OF PERSONAL DATA

To process account registration, establish and manage revolving credit facilities, evaluate and re-evaluate user eligibility, determine credit limits, support repeated loan withdrawals, monitor account activity, and conduct ongoing credit, fraud, and risk assessments throughout the duration of the user relationship with the Platform:

• to identify Users;
• to contact Users in relation to their registered account/s or requested information;
• to process registration of account/s and to determine or assist in determination of decisions as part of screening of the investors, borrowers, registrations or loan applications, and/or to deliver our products and/or services to the User and any directly related purposes;
• To facilitate the full lifecycle management of loan and revolving credit services, including application processing, repeated withdrawals, repayment processing, available credit restoration, credit limit adjustment, monitoring, collection activities, and related risk management measures;
• to maintain internal records;
• to market and offering new, related or complementary products and services to the User;
• to conduct background check and identity verification;
• to conduct and perform fraud monitoring, detection, analysis and prevention;
• to prevent, detect and investigate actual or suspected crime and analyzing and managing commercial risks;
• to conduct data analytics and tracking;
• to conduct market research to enable the Company to understand and determine customer location, preferences and demographics to develop special offers, products or marketing programs in relation to products and services, and to improve (i.e. customized offers and products) such products and services;
• to perform research on data to conduct investigations relating to disputes, payment, suspected illegal activities or fraud;
• to carry out marketing and promotions initiatives relating to the Company, local affiliates of the Company, the Company's partners, and other Company's products and services, whether by electronic means, by email and post, or by telephone, SMS or social media, or by sending newsletters (for example, for the Users to be updated on new products or features and to publicize events, contests, demonstrations, loyalty programs, and other activities organized by the Company and/or the Company), also by using automated means. Such communications will relate to products and services of the financial products, services and the like.
• To develop, enhance, maintain, and continuously optimize credit scoring systems, revolving credit evaluation models, fraud detection systems, behavioral analytics, and ongoing risk assessment mechanisms;
• To manage users' available credit limits, restore reusable credit after repayment of principal amounts, monitor outstanding balances, and support continuous or repeated borrowing within approved credit facilities;
• to develop and generate a credit score, credit model and user model;
• to enroll/participate the user in group credit and/or life insurance, credit risk analysis, credit investigation, credit scoring and credit collection on the User;
• to perform User location search;
• to execute, monitor, manage and analyze the Platform and to develop, enhance, and upgrade the features, functions, products and services in the Platform, including promotions, loyalty and reward programs;
• to respond to User queries and requests;
• to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) of the Company;
• to facilitate and as may be required as part of any financing or capital raising activity (i.e. obtaining loans, credit facility, mortgage, assignment, assignment as a form of security or mortgage of loans);
• to initiate and maintain correspondence with the User via electronic mail (e-mail), SMS (short messaging service), in-app message/communication, registered mail, phone calls or field visits;
• to resolve complaints and handling requests and inquiries;
• to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
• to provide information to external parties such as government agencies, and other institutions as part of scientific research and/or study;
• for any other legal and/or regulatory purposes (including but not limited to obtaining legal advice and dispute resolution) and legitimate business purposes and to carry out all mandatory administrative, operational and legal duties.

Personal Data Security

We highly value the security of your personal data collected, used, retained, and stored through our platform. The Company has implemented technical, organizational, and physical safeguards to protect your personal information.

We take reasonable steps to prevent unauthorized access, disclosure, loss, misuse, or alteration of your data. During data transmission, we use industry-standard encryption technologies (such as HTTPS and SSL) to maintain data confidentiality and integrity. Internally, we enforce strict access control and audit mechanisms to ensure that only authorized personnel can access sensitive information.

While we make every effort to store your information in a secure environment, we cannot guarantee absolute security during transmission or storage. Furthermore, although we strive to ensure the integrity and security of our networks and systems, we cannot guarantee that our security measures will prevent unauthorized access by third-party “hackers.” We do not warrant or represent that your information will always be protected against loss, misuse, or alteration by such third parties.

Data Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable laws or regulations. Specifically:

• For data used for identity verification, revolving credit management, loan servicing, fraud prevention, and risk control purposes, we retain such data for up to 5 years after the termination of the user's credit relationship with the Platform, closure of the account, or as otherwise required by applicable laws and regulations;
• For data used for marketing and behavioral analysis, we retain it for up to 2 years after collection, or delete it immediately upon your withdrawal of consent;
• Once the retention period has expired or upon your request, we will securely delete or anonymize your personal data.

Ongoing Risk Monitoring

We may conduct ongoing monitoring and evaluation of account behavior, repayment activities, transaction patterns, device environment, and risk indicators during the validity of the user's account and credit relationship with the Platform.

Such monitoring is conducted solely for:

• fraud prevention;
• credit risk management;
• regulatory compliance;
• platform security;
• prevention of financial abuse;
• maintaining the stability and safety of revolving credit services.

All such processing shall be conducted in accordance with applicable laws and based on legitimate business and regulatory purposes.

The Platform may automatically adjust, restore, reduce, suspend, or terminate available credit limits based on repayment behavior, account status, risk evaluation results, regulatory requirements, fraud detection measures, or other legitimate business considerations.

USER OBLIGATIONS

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,

1.Where

1.1.you fail to provide promptly any user information or Personal Data that we reasonably requested;

1.2.you withhold or withdraw any consents that we may need to process, transfer or disclose Personal Data for the purposes of used disclosed above in this Privacy Policy (except for purposes connected with marketing or promoting products and services to you);

1.3.we have, or a member of the Company has, suspicions regarding financial crime or an associated risk.

2.We may:

2.1.be unable to provide new, or continue to provide all or part of the services to you and reserve the right to terminate our relationship with you;

2.2.take actions necessary for us or a member of the Company to meet the compliance or regulatory obligations;

2.3.suspend, transfer or close your account(s) where permitted under local laws.

YOUR PRIVACY CONTROLS

You have the rights to:

1.Access your personal data in possession of the Platform;

2.Revoke the consent to the processing of your personal data, revise and/or delete the personal data in possession of the Platform unless the conservation of the said data is mandatory by laws and regulations, without retroactive effects, in all those cases in which such revocation, revision, and deletion do not imply the impossibility of fulfilling obligation derived from a current legal relationship between you and the Platform or when it comes to non-necessary purposes. The exercise of the aforementioned rights must be carried out in writing by email to the following email address: service@pxtlending.com. After the application has been submitted in the aforementioned terms, the Platform will issue the adopted determination.

MODIFICATION

This Privacy Policy may be updated from time to time and shall continue to remain in effect unless otherwise amended. If this Privacy Policy is changed, those changes will be posted on the Platform. The change will be effective when posted. Users availing services and/or visitors to the Platform are advised to check the website on a regular basis to remain aware of the policies and practices of how information is collected and used.

If significant changes to this Privacy Policy will affect certain Personal Data, the Company shall notify its Users through the email address provided or by posting a public notice on the Platform.

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 services and/or the Platform.

Contact Us

Company information:

Corporate Name: PXT LENDING INVESTORS INC.

Company Registration No.CS201803298

Certificate of Authority No.2651

PXT Loan is owned and operated by PXT LENDING INVESTORS INC.

If you need help from us when there are any information, errors, doubts about the changes in your account without your permission or any of your transactions, you shall notify our customer service center via email: service@pxtlending.com or immediately write to the corresponding department with the following information:

• Your name and account name;
• The time and date of such transactions or changes;
• Error description and reference code (if applicable);
• Contact name and address, including email address (if any).

We will immediately investigate any errors or unusual activities reported and will inform you of the results as soon as possible.

The Platform processes personal data strictly in accordance with the permissions granted by the user and the disclosures provided in the Google Play Data Safety section.