PRIVACY POLICY

YINSHAN LENDING INC. (SEC Registration No. CS201900108, Certificate of Authority No. 2860), operating under the name "Happycash" in the Philippines, prioritizes the protection of your personal data. We urge you to carefully review this Privacy Notice to understand how we handle your personal information. This notice is designed to ensure that your personal data is processed in compliance with the Republic Act No. 10173 (Data Privacy Act of 2012, or the “DPA”) and its Implementing Rules and Regulations (IRR).

By proceeding, you acknowledge and agree that you have read, understood, and consent to the terms of this Privacy Policy, effective as of [Date] at [Time]. Your continued use of our services constitutes ongoing consent to the terms outlined herein.

Detailed Explanation of the Clause

The clause explicitly captures the date and time when the user provides consent to the Privacy Policy, creating a clear record of when the agreement became effective. The phrase "read, understood, and consent" underscores that the user has actively engaged with the document and comprehends its contents.

Confirmation of Consent and Continued Use

The statement also highlights that the user's continued use of the services implies ongoing consent, reinforcing the agreement's validity as long as the user remains active. This provides a mechanism for maintaining consent over time while reminding users of their agreement to the Privacy Policy's terms.

1. Information Collection

When you create a Happycash account through our mobile application, website, or access our services via platforms like Google Play or Apple’s App Store, we may collect the following categories of personal information:

Personal Information:

· Full name, biometric information (e.g., facial recognition), date of birth, gender, profession, current and previous addresses, photographs (with permission), SMS data, contact numbers, email addresses, IP addresses, operating systems, browser types, financial data (including bank account details), creditworthiness information, and details of character references (names, emails, contact numbers).

Sensitive Personal Information:

· Nationality, marital status, age, educational attainment, and government-issued identification numbers (e.g., SSS, TIN, Driver’s License).

Device and Usage Data:

· Device model, operating system, unique device identifiers (IMEI, Android ID), IP address, location data (with consent), and usage information (e.g., telecommunications data, app interaction). We may also collect microphone/audio recordings with explicit consent, such as for identity verification.

Trust Decision SDK Information:

· Information for fraud prevention and risk management, including device details, geographic location, login IP, application list, and sensors data (e.g., accelerometer, gyroscope).

We gather this information through:

· Direct submissions from you via our app or website.

· Automated tracking during your interactions with our platform.

· Publicly available sources, government agencies, and third-party partners (with your consent).

2. Purpose of Data Collection

We process your personal data for the following purposes:

· Account Management: To create, maintain, and manage your Happycash account.

· Loan Application & Processing: To evaluate eligibility and process loan applications.

· Fraud Prevention & Risk Management: To prevent fraud, assess risk, and ensure platform security.

· Debt Collection: To recover outstanding debts.

· Marketing & Promotions: To inform you about offers and promotions (with your consent).

· Customer Support: To handle inquiries, concerns, and resolve issues.

· Legal Compliance: To adhere to laws, including anti-money laundering and counter-terrorism financing.

· Research & Development: To enhance our products through statistical analysis and user feedback.

· Voiceprint Biometric Data Analysis: For identity verification via voiceprint analysis.

3. Usage of Personal Data (Permitted Processing)

We may use, process, and/or disclose your personal data within Happycash and to third-party affiliates for the following purposes:

· Authentication: Verifying your identity for security purposes.

· Loan Application Processing: To assess and process loan requests.

· Risk Management: Fraud detection, investigation, and prevention.

· Customer Communication: To send updates, reminders, and respond to inquiries.

· Credit Evaluation: To conduct credit checks and financial assessments.

· Debt Collection: To recover amounts owed under loan agreements.

· Compliance: To comply with legal and regulatory obligations (e.g., anti-money laundering laws).

Additionally, data may be shared with third-party service providers, partners, regulatory authorities, and business partners under specific conditions, as required by law.

4. Disclosure of Personal Data

While we maintain the confidentiality of your personal data, we may disclose it to the following parties, both within and outside the Philippines, for legitimate business purposes:

· Affiliates & Subsidiaries: Other entities within the Happycash group.

· Service Providers: Contractors, payment processors, debt collection agencies, and other third-party service providers.

· Credit Bureaus: National and local credit reporting agencies.

· Legal Authorities: Government, regulatory agencies, or courts, as required by law.

· Strategic Partners: For joint marketing or business operations.

We do not sell or trade your personal data to third parties but may share it with trusted partners to operate our services efficiently.

4.1 Disclosure to Affiliates and Subsidiaries. Happycash discloses personal data only when necessary and in accordance with the Data Privacy Act of 2012. Affiliates and subsidiaries within the Happycash Group may receive personal data for operational, business, and service enhancement purposes, provided they uphold the same standards of data protection as Happycash. Service providers, including contractors, payment processors, and debt collection agencies, may receive data to perform specific functions on Happycash's behalf, under contractual obligations ensuring data security and confidentiality.

4.2 Disclosure to Third-Party Service Providers. Happycash engages third-party service providers to assist in delivering its services, improving user experience, and ensuring the security of its platform. These providers may include, but are not limited to, entities offering services such as data analytics, payment processing, customer support, and risk management. When the Company engages these third parties, it ensures they are contractually bound to protect personal information in accordance with the Data Privacy Act of the Philippines and other applicable laws.

Data Sharing and Purpose

In the course of utilizing these services, the Company may share necessary personal information with these third-party providers. The data shared will be limited to what is required for them to perform their specific functions. The Company ensures that these providers use an individual's information only for the purposes described in this privacy agreement. It implements reasonable and appropriate measures to ensure that personal data is protected against unauthorized access, disclosure, or misuse.

Individual Rights and Control

Individuals have the right to request information about the third-party service providers the Company uses and the specific data shared with them. They also have the right to access, correct, and request the deletion of their personal data processed by these third parties, subject to applicable laws and regulations. To exercise these rights or for any inquiries regarding the Company's third-party service providers, individuals may contact the Data Protection Officer at dpo@happycash.ph. The Company is committed to ensuring transparency and protecting privacy when working with third-party service providers.

4.2.1 By agreeing to this Privacy Agreement, you expressly authorize Happycash to utilize services provided by SMILE TECHNOLOGY PTE LTD. (“Smile”), a risk control supplier, for the purposes of phone detection, email digital footprint analysis, and loan query functions. This authorization enables us to verify your contact information, assess your creditworthiness, and prevent fraudulent activities, enhancing the security and efficiency of our lending processes. This consent is effective from the date of your agreement and will remain valid for [duration, e.g., the duration of your loan agreement or a specified period]. You have the right to revoke this consent at any time by contacting us at dpo@happycash.ph.

Scope of Data Sharing with Smile Technology Pte Ltd.

The data shared with Smile will be limited to your [specific data points, e.g., phone number, email address, loan application details] and will be used solely for the purposes outlined above. We ensure that Smile adheres to strict data protection standards compliant with the Data Privacy Act of the Philippines. Smile is contractually obligated to maintain the confidentiality and security of your data and not to use it for any purpose other than those specified in this agreement. We take reasonable and appropriate measures to ensure that your personal data is protected against unauthorized access, disclosure, or misuse.

Your Rights and Data Protection

You have the right to access, correct, and request the deletion of your personal data processed by Happycash and Smile, subject to applicable laws and regulations. For any concerns or inquiries regarding the processing of your personal data, or to exercise your rights under the Data Privacy Act of the Philippines, please contact our Data Protection Officer at dpo@happycash.ph. We are committed to protecting your privacy and ensuring compliance with all applicable data protection laws.

4.3 Disclosure to Credit Bureaus and Legal Authorities. Credit bureaus, both national and local, may receive personal data for credit reporting and assessment purposes, as permitted by law. Legal authorities, including government and regulatory agencies or courts, may be provided with personal data when required by law, legal process, or to protect Happycash's rights and interests.

4.4 Disclosure to Strategic Partners. Strategic partners may receive personal data for joint marketing or business operations, but only with the data subject's consent or as otherwise permitted by law, ensuring that these partners adhere to data privacy principles. Happycash ensures that all data disclosures are subject to appropriate safeguards, including contractual agreements, to protect the privacy and security of personal data, in compliance with the Data Privacy Act of 2012.

5. Changes to Personal Data

You are responsible for ensuring the accuracy of your personal data. You have the right to request corrections or updates to your information. To update your data, please contact our Data Protection Officer at dpo@happycash.ph., providing your registered name, mobile number, government I.D., and supporting documents.

6. Withdrawal of Consent

You may withdraw your consent to the processing of your personal data at any time by contacting us via email. However, please note that withdrawing consent may affect our ability to provide you with certain services, particularly if you have ongoing contractual obligations.

7. Security Measures

We employ physical, technical, and organizational measures to safeguard your personal data from unauthorized access, use, or disclosure. However, no security system is completely invulnerable, and we cannot guarantee absolute security.

8. Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format. We will provide your data to a third party at your request, where technically feasible.

9. Profiling

We may use automated processing, including profiling, to assess your creditworthiness. You may object to such processing, though this may prevent us from providing you with certain services.

10. Account Deletion and Data Retention

10.1 Right to Account Deletion

You have the right to request the deletion of your HappyCash account at any time through the functionality provided within our app and/or via website. Upon receiving your request, we will take steps to close your account and erase personal data that we are not legally required to retain.

We respect your right to delete your account and associated data. You have two options for account deletion:

In-App Account Deletion:

1. Open the app and go to "Account Settings."

2. Select "Delete Account."

3. Confirm your decision as prompted.

Web-Based Account Deletion Request:

Visit https://www.happycash.ph/delete-account to submit a request. Our support team will process your request within 72 hours. While we will remove most data upon deletion, some information (such as name, identification number, and legal or security-related data) may be retained as required by law and due to legitimate reasons, such as but not limited to security, fraud prevention and regulatory compliance.

10.2 Data We Must Retain After Deletion Request

Due to our legal and regulatory obligations as a financial service provider in the Philippines, we are required to retain certain personal data for a specific period even after you have requested account deletion. We do this for very specific reasons, primarily for compliance, security, and fraud prevention.

We have categorized the data we retain, the reasons for retention, and the duration below:

Data That Is Deleted

Any data not subject to the mandatory retention periods described above will be permanently and securely deleted from our systems. This may include data such as:

· App usage analytics not tied to a transaction

· Marketing preferences

· Session cookies and temporary files

Secure Disposal

After the mandatory retention period expires, we will ensure that all your personal data is disposed of in a secure manner that prevents its further use, access, or disclosure.

11. Suspension, Withdrawal, or Deletion of Personal Data:

We reserve the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our systems if we become aware, or reasonably suspect, that the data is:

· Incomplete, outdated, or false;

· Unlawfully obtained or used for unauthorized purposes;

· No longer necessary for the purposes for which it was collected; or

· Once you withdraw your consent or object to the processing, and there is no other legal ground or overriding legitimate interest for the processing.

12. Your Rights Under the Data Privacy Act (DPA)

As a data subject, you have the following rights:

· Right to be Informed: About the collection and use of your data.

· Right to Object: To the processing of your personal data.

· Right to Access: Your personal data.

· Right to Rectification: To correct or update your data.

· Right to Erasure or Blocking: To remove or block your data.

· Right to Damages: Compensation for inaccurate or unlawful processing.

· Right to Data Portability: To obtain your data in a portable format.

· Right to File a Complaint: With the National Privacy Commission (NPC).

13. Your Rights Under the Credit Information System Act (CISA)

You have the following rights related to your credit information:

· Access: To your credit information.

· Dispute Resolution: For errors or inaccuracies in your credit data.

· Indemnity: In case of unjustified denial of credit access.

· Notification: Of any correction in credit data.

14. Inquiries and Complaints

For any concerns, queries, or to exercise your rights regarding your personal data, please contact our Data Protection Officer at dpo@happycash.ph. We will acknowledge your concerns and provide an estimated timeframe for resolution.

15. Changes to the Privacy Notice

We may update this Privacy Notice from time to time by posting the revised version on our website. Your continued use of our services indicates acceptance of any changes made.

16. Consent and Acknowledgement

By providing us with your personal data, you consent to the collection, use, and disclosure of your data as outlined in this Privacy Notice. If you are submitting personal data on behalf of others, you warrant that you have obtained their consent.