PRIVACY POLICY & TERM AND CONDITIONS
Supreme Money Lending Corp. (“Supreme Money Lending Corp.”, “us”, “we”) is a limited liability company registered in Philippines under number CATCEO-247. Our registered office address is Unit 31, 9782 Dita Street, Barangay San Antonio, Makati City. Supreme Money Lending Corp. is authorized and regulated under firm reference number CS202001119. We are committed to protecting and respecting your privacy. We are registered with the Securities and Exchange Commissioner’s Office under registration number CS202001119). We provide a platform (the “Platform”) via www.suprememlc.ph (the “Website”) and (the “Mobile App Supreme MLC” for lending and borrowing transactions conducted between our customers. The Platform, Website and Mobile Application is owned and operated by Supreme Money Lending Corp..
General
Please read this privacy policy carefully as it sets out the basis on which we collect any personal information from you, or that you provide to us and how we use it in the operation of the Platform.
This Privacy Policy Covers:
- Visitors To Our Website (“Guests”); And
- Registered Users Of The Platform.
A Registered User Of The Platform May Be A:
- Lender; or
- Borrower.
Please note that certain parts of this privacy policy only apply to borrowers and other parts only apply to lenders. Where this is the case, we make it clear in the relevant paragraph.
As well as private individuals, lenders may be limited liability companies or limited liability partnerships. Borrowers will always be limited liability companies or limited liability partnerships. In these circumstances, this privacy policy will apply to, and ‘you’ and ‘your’ refer to, the individuals who are you as the lender or you as adirector, partner or authorized person of the lending or borrowing entity.
Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back
frequently to see any updates or changes to our privacy policy.
Contacting us
If you have any complaints or any questions about any aspect of this privacy policy or your information, or to exercise any of your rights as described in this
privacy policy or under data protection laws, you can contact us:
By post: Supreme Money Lending Corp., Unit 31, 9782 Dita Street, Barangay San
Antonio, Makati City; or
By email: support@suprememlc.ph.
What information do we collect from users of the Website, including Guests?
You can browse this Website as a Guest without giving us any information, and
we won’t know who you are. However, even if you are a Guest, please bear in mind
that we may:
- Record, store and use information about the areas of the Website which you visit
and at what times; - Record, store and use information about your activities in using the Website;
We also collect and store data that you submit to us via email, via our optional surveys, and through our contact form and email subscription sign-up form on the Website.
We collect the information above by using cookies. Please click here to access our Cookie Policy https://www.suprememlc.ph/cookies-policy/ which explains what cookies we use on our Website, why we use them and how you can control them.
What information do we collect from or are provided with in relation to borrowers and lenders?
Additional services are available once you register with us and login to the Website. In this case, we will know who you are, your activities on the Website and information about your computer may be linked to you on our systems.
In order to provide you with such services, we may collect, store and use information you upload to the Platform
The types of information we may request from you are:
- Contact Information – including your name, date of birth, address, postcode and other contact information such as email address and telephone/mobile number and (where applicable) the contact details of your first of kin;
- The bank or building society account details to make or receive payments on the Platform;
- Your passwords and security question answers;
- Your financial interests, financial position, or loan repayment performance;
- Answers to questions required by third party credit reference agencies for
Identification Purposes;
- Information about your activities in using the Website; and
- Information from directors/individuals associated with you and/or your business.
We may retain copies of the following information about you:
- Any correspondence you send us, details of your registration history and any materials you post on the Platform;
- Passports or other identification evidence that you provide for anti-money laundering and anti-fraud purposes;
- Records of any surveys that you may be asked to complete for research purposes, although you do not have to respond to them;
- Details of transactions you carry out through the Platform and the receipt and disbursement of repayments;
- Details of your visits to the Website and the resources that you access;
- Where explicit consent has been provided, information about your physical or mental health or condition (where necessary and appropriate); and
- Where explicit consent has been provided, information relating to any criminal proceedings in which you have been involved.
- If you give us false or inaccurate information, either directly or through an agent, and we suspect or identify fraud, we will record this.
- We may also be provided with information about you from third party brokers, introducers or other referrers, who collected that information from you directly.
What information do we collect from brokers, introducers and other referrers?
- If you are a broker, introducer or other referrer, we will collect and may retain the following personal information about you, either as a shareholder or in your capacity as a director of the company providing the broker, introducer or other referral service:
- Any correspondence you send us, your name, address, email address and contact numbers; and
- Passports or other identification evidence that you provide for anti-money laundering and anti fraud purposes.
Information from other sources
In relation to borrowers only, we will also check information about you held on our own records and also obtain information from credit reference agencies about you and your financial associates’ personal credit behavior and personal credit accounts. We will also search at fraud prevention agencies for information on you and your financial associates and business partners.
What do we do with the information we collect from users of the Website?
The main reason we use this information is to provide you with both an improved website experience and details about our products and services. Where it is in our legitimate interest to do so, we (or third party data processors, agents and subcontractors acting on our behalf) may also use the information:
- To enrich your experience and interaction with the Website by allowing you to store your details so that your preferences are retained when you revisit the Website
- To analyse site usage and improve our services;
- To deliver to you any administrative notices, alerts and communications relevant to your use of the services; and
- To contact you from time to time to inform you about new features, to troubleshoot sproblems, and to protect you against fraud or other criminal activity.
What do we do with the information we collect or are provided with in relation to borrowers and lenders?
Where it is in our legitimate interest to do so, we (or third party data processors, agents and subcontractors acting on our behalf) may use this information to:
- Provide you with details about our products and services;
- Carry out financial and identity checks, fraud prevention checks, regulatory
Checks and credit checks, including by using scoring methods;
- (In respect of borrowers) carry out credit checks;
- (In respect of borrowers) check details on applications for credit and credit related and other facilities;
- (In respect of lenders) check details on applications for lending and other related facilities;
- (In respect of borrowers) if you do not repay money you have borrowed, to trace your whereabouts and recover debts or enforce a loan agreement;
- (In respect of borrowers) to provide you with information about goods or services offered by other companies that we feel may interest you. You will be contacted by electronic means (email or SMS) only if you have consented to this;
- To carry out product development, statistical analysis and market research;
- To develop and improve our services and products;
- To update our records;
- To advise you about the products and services that we are providing to you in response to a request from you about this;
- To carry out checks required by applicable regulation or regulatory guidance;
- To keep you informed about your loan agreements or security documents, as the case may be;
- To allow you to participate in interactive features of the Website, when you choose to do so;
- To make the Website available to you and to identify the products and services which you may be interested in;
- For customer service, including answering questions and responding to feedback and complaints; and
- For any other specific purposes in relation to your activities via the Platform.
In order to provide services and products to you, enter into a contract with you and to fulfill our contractual obligations, it may be necessary for us to manage your borrower or lender account with us and update the records we hold about you from time to time
Where you have given us consent, we shall provide you with information about any new products, services, events, promotions and other information which we think will be of interest to you. You can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences at any time by contacting us via the details as given in the “Contacting Us” section above.
What do we do with the information we collect from brokers, introducers and other referrers?
Where it is in our legitimate interest to do so, we (or third party data processors, agents and subcontractors acting on our behalf) may use this information to:
- Provide you with details about our products and services;
- Carry out financial and identity checks, fraud prevention checks, regulatory checks and credit checks, including by using scoring methods and guidance.
- Choose to do to carry out product development, statistical analysis and market research;
- To develop and improve our services and products;
- To update our records;
- To carry out checks required by applicable regulation or regulatory to allow you to participate in interactive features of the Website, when you so;
- To make the Website available to you and to identify the products and services which you may be interested in;
- For customer service, including answering questions and responding to feedback and complaints; and
- For any other specific purposes in relation to your activities via the Platform.
Who do we share your information with?
We won’t provide your personal information to other companies for their marketing purposes unless you have given us your consent. However, we may aggregate anonymised information based on your personal information and disclose this to advertisers and other third parties.
We may disclose your personal information to third parties where it is in our legitimate interest to do so including for the following reasons:
- We may share your information with analytics and search engine providers that
assist us in the improvement and optimisation of our site; - We may share your personal information with companies and other third parties performing services on our behalf (for example KYC service providers, credit reference agencies, customer relationship management providers or other service providers) who will only use the information to provide that service. We may also share your personal information with other members of our corporate group, or a purchaser or potential purchaser of our business;
- EWe may share alerts and information derived from identity verification checks with third parties for the purpose of anti-money laundering and fraud prevention;
- We may share your email address and our internally generated customer ID number with Trustpilot, who will contact you to invite you to review us on the Trustpilot website, and for no other purpose. This information offers us important feedback to improve our service. If you do not respond to the invitation from Trustpilot within 30 days, Trustpilot will delete your data. If customers decide to review us using Trustpilot, the data they provide to Trustpilot will be processed and stored by Trustpilot in accordance with their privacy policy which can be found on their website. A copy of the data processing agreement between Supreme Money Lending Corp. and Trustpilot can be found at https://legal.trustpilot.com/dataprocessing-agreement; and
- We may disclose your personal information on request to the FCA, Financial Ombudsman Service, the police or any other regulator or government authority in order to fulfill our regulatory responsibilities, to help prevent or detect fraud or any other type of crime or for any other reasonable purpose identified by the relevant authority.
- Where it is necessary for us in order to carry out our obligations arising from any contract entered into with you and to provide services and products to you, we may share your data with staff operating outside the EEA who work for us or for one of our subcontractors. Your data may be processed by such staff for the fulfillment of your order, the processing of your payment details and the provision of support services.
Save as set out in this privacy policy, we will not sell or disclose your data to any third party.
Borrowers
- In addition, where it is in our legitimate interest to do so, we may disclose a borrower’s personal information to:
- Credit reference and fraud prevention agencies to perform similar checks, trace your whereabouts and recover debts you owe. This may include details of your loans on the Platform, how you manage them and any amounts outstanding; and
- Debt collection agencies, security trustees and other legal representatives if required to enforce the terms of any loan agreement.
Where we store your personal data and international transfers
We are committed to ensuring that your information is safe and take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.Supreme Money Lending Corp. has a small operational office in the Philippines for processing lender and borrower applications and providing customer support. Your personal data may therefore be both collected and processed in the Philippines.
Some information you provide to us is stored on either our secure servers (which may be in the United States or the Philippines), stored with our third party Platform provider in the Philippines, or is stored with a third party secure data storage provider, which encrypts the data and keeps it in secure storage servers, which are located in data centers across the United States.
How long we keep your information
We will keep your data for as long as necessary to fulfill the purposes described in this privacy policy.
If you are a borrower or a lender who has entered into a loan agreement via the Platform, we will hold your data for 6 years after the end of our relationship with you. This may be, but is not limited to being once the loan is terminated, or once your application is declined, or at any point we have contact with you regarding your application or agreement. Your data is held for this long for statistical and modeling purposes including stress testing and fraud modeling.
If you provide us with your personal data but do not enter into a loan agreement either as a borrower or a lender then we will only hold your data for a maximum of 12 months from the date such data was received.
- Your application proceeds. If the search was for a credit application the record of that search (but not the name of the organization that carried it out) may be seen by other organizations when you apply for credit in the future; and
- Link together the previous and subsequent names advised by you, of anyone that is a party to the account.
Credit reference agencies supply the following information to us:
- Information about you, such as previous applications for credit and similar personal credit information in your name or in relation to your financial associates and business partners;
- Public information such as County Court Judgments (CCJs) and bankruptcies;
- Electoral register information on you and your business partners; and fraud prevention information.
What credit reference and fraud prevention agencies do
When a credit reference agency receives a search from us they will: place a credit search “footprint” on your credit file regardless of whether years after they are closed, whether settled by you or defaulted. Credit reference agencies will keep records of outstanding debt on file for six The information which we and other organizations provide to the credit. reference agencies and fraud prevention agencies about you, your financial associates, your business partners and details about your business may be supplied by credit reference agencies and fraud prevention agencies to other organizations
and used by them to:
- Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities;
- Check the operation of credit and credit-related accounts;
- Verify your identity if you, your financial associates or your business partner(s) apply for other facilities;
- Make decisions on credit and credit related services about you, your financial associates and/or your business partners, or your business;
- Manage your personal, your financial associates, your business partner’s and/or business credit or credit related account(s);
- Trace your whereabouts and recover debts that you owe;
- Conduct other checks to prevent or detect fraud; and
- Undertake statistical analysis and system testing.
If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organizations may also access and use this information to prevent fraud and money laundering, for example, when:
- Facilities; checking details on applications for credit and credit related or other
- Managing credit and credit related accounts or facilities;
- Recovering debt;
- Checking details on proposals and claims for all types of insurance; and checking
details of job applicants and employees.
Please contact us if you want to receive details of the relevant fraud prevention agencies.
We and other organizations may access and use from other countries the information recorded by fraud prevention agencies.
Disclosing information about other individuals
If you are a joint applicant, or if you have told us of some other financial association that you have with another person (for example financial associates), you represent to us that you are entitled to:
- Disclose information about your joint applicant and anyone referred to by you; and
- Authorize us to search, link or record information at the credit reference agencies about you and anyone referred to by you.
An association will be created by the credit reference agencies between joint applicants and between you and anyone you tell us is financially connected with you. This will link your financial records with that person and those records will be taken into account in all future applications either by you or both of you. This will continue until one of you successfully files a disassociation at the credit reference agencies, i.e. informing them that you are no longer connected financially with a particular individual.
Marketing and Communications
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
If you have registered with us as a lender or a borrower or have previously asked us for information on our products or services and you have not opted out of
receiving that marketing information, we may seznd you information on our range of products, services, promotions, special offers and other information which we think you may find interesting by phone, email and/or SMS.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us by email at support@suprememlc.ph or in writing to us at Supreme Money Lending Corp., Unit 31, 9782 Dita Street, Barangay San Antonio, Makati City.
Google Map for google map – Non-continuous geolocation (This Application) This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the
position automatically.
Personal Data processed: geographic position.
Your Rights
Access to your information and updating your information
You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing. For any further copies which you may request, we may charge a reasonable fee based on administrative costs.
You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (‘data
portability’).
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
Right to object
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims
Your other rights
You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete. If you think any information we have about you is incorrect or incomplete, please contact us by email at support@suprememlc.ph or in writing to us at Supreme Money Lending Corp., Unit 31, 9782 Dita Street, Barangay San Antonio, Makati City to let us know and we will delete or update any information as soon as possible.
In certain circumstances, you have the right to:
- Request the erasure of your personal information erasure (‘right to be forgotten’); and
- Restrict the processing of your personal information to processing to which you have given your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of others.
Exercising your rights
You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as given in “Contacting us” above.
Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your
identity.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot
guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
This privacy policy was last updated: June 2023