Privacy Notice for Mobile Application

TYTO CASH PLATFORM

1. For Website and Mobile Apps
    1.1.This Policy sets out the commitment of TYTO NETWORK TECHNOLOGIES PVT LTD doing business under the name and style of TytoCash regarding the collection, processing, and storage of personal information and sensitive personal information (collectively “Personal Data”) in accordance with the Data Privacy Act of 2012 (“DPA”), its implementing rules and regulations (“DPA IRR”), and other issuances by the National Privacy Commission (“NPC”).
    1.2.We recognize the importance of protecting your personal information as well as the importance of transparency in the way that we collect, use, store, transfer/disclose, and dispose information derived from your use of our products, services, online portals, and mobile applications.

2. Personally Identifiable Information
    2.1. “Personally identifiable information” is information that can be used to uniquely identify an individual such as name, password, age, civil status, gender, mailing address, email address, telephone number, mobile number, and other personal details. We also consider personal    information and sensitive personal information as defined under the Data Privacy Act of 2012 as    personally identifiable information.

3. Collection of Information
    3.1.We collect personally identifiable information when you apply for our services, and when you register an account on our mobile applications and online platforms. You may be asked to provide us with personally identifiable information through our website, our mobile apps, through our Point of Sale devices or through paper application forms.
    3.2.With your consent, TYTO NETWORK TECHNOLOGIES PVT LTD may collect your name, mobile number and email address connected to Facebook and Gmail. External websites and companies with hyperlinks to and from TYTO NETWORK TECHNOLOGIES PVT LTD online platforms may collect personally identifiable information about you when you visit their websites. This privacy notice does not extend to those external websites and companies. Please refer directly to their privacy notice regarding their handling of your personally identifiable information.
    3.3.We collect information about you in a number of ways:
    • Information you provide to us through our websites and applications;
    • Information you provide through communications with us;
    • Information you have authorized us to collect through our applications such as your photograph obtained via access to your smartphone camera or photo gallery and your phone, email, or social media contact lists and metadata for the purpose of KYC and preventing fraud;
    • Information you have authorized us to collect from various services and networks, including financial institutions, financing companies, lenders, your employer (for auto-debit or other autodeduction mechanisms) whether private or public, telecommunication companies (such as Globe Telecom, Inc., Smart Communications, Inc., PLDT, Inc., Sun Cellular/Digitel Mobile Philippines, Inc.), utility companies (such as Meralco/Manila Electric Company, Maynilad Water Services, Inc., Manila Water Company, Inc.), government agencies (such as SSS, GSIS, NSO, BIR), credit bureaus (such as the CIC, NFIS), remittances (such as Palawan Express, Cebuana Lhuillier), insurance providers (such Sun Life Grepa Financial, Inc., Insular Life), financial service providers (such as CC Mobile Financial Services Philippines, GCash/G-Xchange, Inc., PayMaya Philippines,Inc.) and other service providers, online or otherwise; and
    • Information from outside sources such as credit bureaus and customer service providers to help us with customer verification and credit-related decisions.
    3.4.In addition to the personal and financial information you submit (or we collect), we may collect information about your computer and smartphone including, where available, your IP address, operating system and browser type – for the purposes of system and loan administration and product improvement. We may also record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help us combat fraud. To register with us you must be 18 years of age or older. Minors are strictly forbidden from using the service.

4. Use of personally identifiable information
    4.1.The personally identifiable information you share will be used according to the contracts that you execute with us for our services. In relation to those contracts, we use the personally identifiable information for credit verification, credit scoring, automated processing of the loan applications, and loans collection.
    4.2.TYTO NETWORK TECHNOLOGIES PVT LTD may use your personally identifiable information to send you information about TYTO NETWORK TECHNOLOGIES PVT LTD, including news about product updates, events,    and other promotional materials, but only if you agree to receive such communications. TYTO NETWORK TECHNOLOGIES PVT LTD will not share any personally identifiable information with third parties for marketing purposes without your consent.
    4.3.TYTO NETWORK TECHNOLOGIES PVT LTD may use personally identifiable information for data analytics, data profiling and other legitimate interests, which will help us understand your needs and to help us improve our services.
    4.4.We will hold and use the following details about you:
    • Your name, address, phone numbers, email address, date of birth, employment and banking and financial details;
    • Demographic and lifestyle information;
    • Information we receive when making a decision about you, your loan or application (including information collected from credit bureaus or other sources);
    • Details of the loans you have and have had with us and all transactions;
    • Details of when you contact us and when we contact you;
    • Mobile device data (such as SIM, IMEI, or other device identifiers type of device, device operating system, device settings, user account information for your mobile device or Google PlayStore account, information about mobile network provider, device specifications), Location    data (such as mobile device location, time zone setting); phone data (such as contact lists and    metadata, SMS metadata, types and nature of mobile applications found on your mobile device); mobile app usage data (such as traffic volume, mobile app usage) and telecommunications usage data or “telco usage score”; and
    • As well as any other information which we reasonably need to operate your account, make decisions about you or fulfill our regulatory obligations.
    4.5.We may keep details of any phone number(s) that you call us from and use them to contact you. References to personal information include all of the information above whether obtained from you, from a credit bureau, from the internet or from any other source.
    4.6.We may share information about you:
    • With any firm, organization, or person we use to help us operate our lending business for the purpose of conducting KYC, determination of credit worthiness, fraud prevention, and to collect payments and recover debts or to provide a service on our behalf; With any firm, organization, or person who provides us with products or services or who we provide products and services to for the purpose of providing such products and performing such services;
    • With any person who has told us and who we reasonably believe to be your parent, carer or helper, when proof is presented that you are unable to handle your own affairs because of mental incapacity or other similar issues for the purpose of proper handling of said affairs;
    • With any payment system we may use for the purpose of disbursement of loan proceeds and payment of loans;
    • With any Third Party Entities (“Partners”) engaged by the Lender such as the Borrower’s employer (for auto-debit or other auto-deduction mechanisms) whether private or public, telecommunication companies (such as Globe Telecom, Inc., Smart Communications, Inc., PLDT, Inc., Sun Cellular/Digitel Mobile Philippines, Inc.), utility companies (such as Meralco/Manila Electric Company, Maynilad Water Services, Inc., Manila Water Company, Inc.), government agencies (such as SSS, GSIS, NSO, BIR), credit bureaus (such as the CIC, NFIS), remittance companies (such as Palawan Express, Cebuana Lhuillier), insurance providers (such Sun Life Grepa Financial, Inc., Insular Life), financial service providers (such as CC Mobile Financial Services Philippines, GCash/G-Xchange, Inc., PayMaya Philippines, Inc.) for the purpose of (i) determination of creditworthiness, conducting all the necessary background checks that may include credit scoring and investigation, and data analytics; (ii) data analytics, statistical analysis and demographics, business development purposes (such as improvement of the websites, mobile applications, and the Lender’s credit scoring algorithm/s, the creation of effective service delivery and payment collection strategies, improving customer experience and customer assistance), and the direct marketing of the Lender’s existing and prospective financial services as well as the products and services of its Partners; (iii) for fraud detection, investigation, and prevention; (iv) for all phases of provisioning the products and services that the Borrower may apply for including evaluation of loan applications, its automated processing, complying with eKYC (Know Your Customer) regulations required by the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, and the Anti-Money Laundering Council, credit verification, credit scoring, and payment collection.
    • With certain authorities in order to detect and prevent terrorism (including to authorities outside the Philippines);
    • With any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transferee or purchaser may use your personal information in the same way as us;
    • With regulatory agencies and government authorities (including but not limited to, the Bangko Sentral ng Pilipinas, the Bureau of Internal Revenue, the National Bureau of Investigation, the Office of the Ombudsman), including those overseas, where we are requested by them to do so;
    • With credit bureaus or any similar organization which provides a centralized application matching service that collects information from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud. We may also provide information to third parties to help them to make decisions about whether to lend to you, allow you extended payment terms or otherwise do business with you.
    4.7.We may share your information to:
    • Search credit bureaus’ records (including information from overseas);
    • Make, or assist in making, credit decisions about you, assess lending (and insurance risks and to check the details that you have let us and others have;
    • Operate and manage your account and manage any application, agreement or correspondence you may have with us;
    • Carry out, monitor and analyze our business;
    • Contact you by email, SMS, letter, telephone or in any other way about our products and services, unless you tell us that you prefer not to receive marketing;
    • Identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
    • Form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
    • Carry out market research, business and statistical analysis;
    • Provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
    • Carry out audits;
    • Perform other administrative and operational purposes including the testing of systems;
    • Trace your whereabouts;
    • Recover any debt you owe us;
    • And comply with our regulatory obligations.
     4.8. Your data may also be used for other purposes for which you give your permission or where we are permitted to do so by law or it is in the public interest to disclose the information or is otherwise permitted under india Law.

5. Credit Bureaus
    5.1.When you apply to us for a loan, we will check the following records about you (and others where applicable):
    • Our own, including information and records you supplied to us or authorized us to collect; and
    • Those at credit bureaus.
    • Whether or not your application is successful, when credit bureaus receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit. This is applicable whether you have been accepted or declined.
    • The credit bureaus supply us with both public information and shared credit and fraud prevention information including information about previous applications and the conduct of
    your accounts.
    • We may also make periodic searches at credit bureaus to manage our relationship with you.
    • Information provided by you on our applications will be sent to credit bureaus and will be recorded by them.
    5.2.We and other organizations may access and use this information to prevent fraud and money laundering and credit bureaus may use your information for statistical analysis. Information held    by credit bureaus will be disclosed to us and to other organizations in order to (for example):
    • Prevent fraud and money laundering and to check and assess applications for credit, credit related or other facilities;
    • Recover debts that you owe and trace your whereabouts;
    • Manage credit accounts and other facilities and decide appropriate credit limits;
    • Verify your identity;
    • Make decisions on credit and other facilities for you, your financial associate (s), members of your household or your business;
    • Check details on proposals and claims for all types of insurance;
    • Check details of job applicants and employees.
    5.3.When you borrow from us, we will give details of your loan and how you manage it to the credit bureaus. If you borrow and do not repay in full and on time, the credit bureaus will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding; other organizations may see these updates and this may affect your ability to obtain credit in the future.
    5.4.If you fall behind with your payments and a full payment or satisfactory proposal is not received,then a default notice may be recorded with the credit bureaus. Any records shared with credit bureaus will remain on file for a retention period after your account is closed, whether any outstanding sums have been settled by you or as following a default.
    5.5.If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud, we may record this and may also pass this information to organizations involved in crime and fraud prevention including law enforcement agencies who may then access this information.
    5.6.We and other organizations may access and use the information recorded by fraud prevention agencies from other countries.

6. Persons under the Age of 18
    6.1.TYTO NETWORK TECHNOLOGIES PVT LTD will not knowingly collect personally identifiable information from any person under the age of 18 TYTO NETWORK TECHNOLOGIES PVT LTD encourages parents to instruct their children to never give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us.
7. Cookies and Other Information on a User’s Machine
    7.1.TYTO NETWORK TECHNOLOGIES PVT LTD’ products, services, sites and mobile apps may employ cookies and other similar and applicable technologies. We may use third party website analytic tools that employ cookies to collect certain non-personally identifiable information concerning use of our websites, such as referring web site addresses, page views and browser types.
8. Mobile App Permissions
    8.1.TYTO NETWORK TECHNOLOGIES PVT LTD mobile application may request that you activate permissions including but not limited to location, emails, messages, phone calls, calendar and contacts. The general description of the mobile app’s behavior can be referenced through the permissions module of your mobile phone. The processing of personal information and meta-data by the mobile application is consistent with what we explained in this privacy notice.
9. Data Subject Rights
    9.1.Under the Data Privacy Act, you have the right to be informed, the right to object, the right to access, the right to rectification, the right to erasure or blocking, the right to damages and the right to file a complaint. If you wish to exercise any of these rights, you may contact us at  customercare@ty2.in  We may decline requests that are excessively repetitive, require disproportionate technical effort, jeopardize the privacy of others, or are extremely impractical or unreasonable.

10.Refund Policy

     At TytoCash we value our customers and are committed to providing best services. Refund process will only be initiated by TytoCash in following conditions:

      We will not pass your details on to any third party.

     (i) If repayment of the loan has been done by the borrower twice by any means.
      (ii) Any extra payment has been received by TytoCash over and above the repayment value in any case.
      (iii) Repayment has been done mistakenly by the borrower unintentionally before his/her the due date of loan repayment.

      If for some unforeseen reason, the client is not satisfied with our services, they may call us to seek direction on future calls. We will give our best effort to increase the satisfaction levels in such cases. We strongly recommend that before making a payment, our visitors and potential clients should read the refund policy. If the customer is eligible for the refund then the refund amount would be credited in the respective bank account within 7 working days.
11. Contact TYTO NETWORK TECHNOLOGIES PVT LTD Data Protection Officer (DPO)
TYTO NETWORK TECHNOLOGIES PVT LTD Data Protection Officer provides support for any data privacy related inquiries or complaints. You may contact TYTO NETWORK TECHNOLOGIES PVT LTD DPO through the following: 
Customer Service NO:  01140844838
Email address:  customercare@ty2.in