Effective Date: March 1, 2022
Last Updated: June 15, 2022
Tala Financing Philippines Inc., a corporation organized and existing in the Philippines (“Tala”, “we”, “us” or “our”) takes your privacy very seriously.
This privacy policy (this “Privacy Policy”) describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You should read and understand this Privacy Policy in its entirety.
This Privacy Policy applies in connection with your use of the Tala Android mobile application found here (the “Tala App”) and your use of our services through the Tala App or otherwise. It does not apply to your use of the Company’s website, found at www.tala.ph (the “Website”). Please see here for the privacy policy applicable to your use of our website.
1. What personal data does Tala collect and process? From where does Tala collect your personal data?
Tala collects the following personal data (as defined under applicable law), including personally identifiable information:
Identification data (e.g., first name, surname, date and place of birth, image capture);
Contact details (e.g., address, phone number, alternate phone number, email address);
Government-issued identification data and documents (e.g., SSS ID, UMID, Voter’s ID, Passport, Driver’s License, Postal ID, PhilSys ID);
Information provided by you through your responses (e.g., details and documents about your income or employment, your proposed use of proceeds, your educational attainment, customer-provided information about your mobile device);
Mobile device specifications (e.g., SIM, IMEI, IP address, or other device identifiers, type of device, device operating system, device settings, user account information for your mobile device or Google PlayStore account, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, CPU capacity, etc.), information about network proximity);
Location data (e.g., mobile device location, time zone setting);
Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information);
Device behavioral data (e.g., contact lists, SMS records, types and nature of mobile applications found on your mobile device);
Telecommunications usage data (e.g., call data records, SMS logs, subscription data, payment details, applications and usage data, telco score);
Tala App usage (e.g., traffic (volume) data, information about your usage or non-usage of the Tala App);
Information related to your communications with Tala (e.g., your communications with Tala via in-app chat, email, telephone or other channels);
Information provided by you in relation to participation in special offers and promotional activities conducted by Tala (e.g., waivers, promo codes, games, contests, discounts, and participation in by-invitation-only groups); and
Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies, mobile network providers).
Tala collects your personal data from:
You, when download the Tala App and/or indicate that you want to apply for credit;
Your other interactions with us, including Information you may voluntarily share with our customer support team or other Tala employees or agents;
Your mobile device (through the device permissions more fully described below);
Credit reference agencies (who may check your personal data against other databases – public and private – to which they have access) or fraud prevention agencies; and/or
Third parties and other publicly available sources, with your consent, when necessary (e.g. we may receive Information from financial rails (or other disbursement channel vendors) or other business partners (such as telecommunications companies and credit scoring service providers) that may assist us in providing services to you).
Third parties who communicate with us through the contact information that you provided to us.
Collection and processing of your personal data by Tala is necessary for the provision of Tala’s products and services and to comply with applicable legal and regulatory requirements to which you and/or Tala is subject. Apart from such cases, we do not collect Information without your specific prior consent.
2. What are the purposes for which your personal data is processed? How does Tala use your personal data?
To assess your eligibility to use our products or services (including, but not limited to, credit scoring and assessing your creditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product);
To service your account with Tala (including, but not limited to, processing disbursement of your funds and collecting repayment of your outstanding balance);
To verify your identity and/or other information you provided to us;
To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;
To analyze customer behavior;
To administer our systems, maintain service quality and compile general usage statistics;
To analyze and improve our services;
To troubleshoot any problems you or other customers encounter with Tala’s services;
To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” (KYC), customer verification, transaction monitoring, and/or anti-money laundering;
To send you marketing or advertising notices or other promotional offers, to the extent you have not objected to the use of your personal data for direct marketing purposes;
To provide service updates;
To provide staff training (where we may monitor or record customer interactions);
To interface with credit reference or fraud prevention agencies;
To provide customer service or support and to resolve disputes and complaints;
To contact you by telephone using autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.
We process your personal data for the purposes set out above on the following grounds:
To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you);
To carry out our legal obligations under applicable law;
In connection with our legitimate interest in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date;
With your prior consent.
3. Who do we share your personal data with?
General
Tala will not disclose any Information containing personal data (as defined under applicable law) to any third parties unless it is necessary and/or appropriate in order to provide Tala’s products or services (provided, that, we may share limited personal data with select partners for research and development). Whenever practically feasible, Tala will only share your personal data with third parties in an anonymized or de-identified format.
You understand and agree that we may, as necessary and/or appropriate for the purposes provided above, transfer and disclose your personal data to:
a subsidiary, affiliate or parent company of Tala (collectively, the “Tala Group”) located outside the Philippines;
employees, subcontractors, agents, service providers, or associates of the Tala Group (including directors and officers);
bank partners (e.g., Union Bank of the Philippines, EON);
intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, remittance and transfer companies, credit reference agencies or credit bureaus;
service providers with contractual or fiduciary relationships with Tala (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer), which may be located outside the Philippines;
telecommunication companies (e.g., Globe, TM, GOMO, Smart, Talk&Text, PLDT, Sun Cellular);
external collection agencies (to assist in the collection of any unpaid obligations to us);
external counsel, external auditors, and consultants, when necessary to resolve disputes or complaints;
a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Tala and/or any company within the Tala Group;
a party in connection with any assignment of credit or the creation of a security interest involving outstanding balances owed to Tala;
to other public or private third parties to the extent (1) we have a duty to disclose or share your personal data in order to comply with any legal obligation (e.g., the Credit Information Corporation, the Bureau of Internal Revenue), (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Tala, the Tala Group and/or our customers.
The above parties may also process or disclose your personal data for the purposes set forth above, so long as such processing or disclosure is in compliance with this Privacy Policy.
Further, Tala may also share your personal data with law enforcement or other government agencies in connection with a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you.
Referrals
To promote its products and services, Tala administers and services a referral program (the “Tala Referral Program”) for its current and future customers. If you choose to accept a referral from another Tala customer and accept a Tala loan in connection with that referral, Tala will provide a bonus to the customer who refers you upon your successful repayment of your Tala loan.
If you choose to participate in the Tala Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the embedded referral link and subsequently applying for and accepting a Tala loan through such referral.
Sharing of information in connection with the Tala Referral Program will always be limited to the information described above and will always be anonymized – Tala will never share personal data about your repayment status with any other customer or user or Tala. More information on the Tala Referral Program is available within the Tala App.
4. For how long will we retain your personal data?
Your personal data will be stored or retained by Tala and its transferees only for so long as necessary for the purposes listed in this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We are required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion. We may also retain your personal data (i) for as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Information that is no longer needed for the purpose(s) for which it was collected shall be deleted or anonymized except as necessary to comply with legal obligations.
5. Where do we process, store or transfer your personal data?
We may transfer your personal data outside of the Philippines, either to the United States, or Singapore, and/or to the extent we provide prior notice to you, to jurisdictions that may have data protection laws that are less stringent than those of the Philippines. When we do so, we will ensure that adequate safeguards are in place in accordance with applicable law and/or the Philippines’ data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your personal data. Your personal data may be processed by any of the parties described above. Tala will use all reasonable and appropriate efforts as required by applicable law to protect your personal data.
6. Automated decisions and profiling
We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.
Credit decisions
When you apply for credit, we’ll use automated processing to decide whether to lend to you and/or make other decisions about your eligibility for our products and services, based on the personal data collected. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data, or income from formal sources.
Our credit and underwriting models utilize data science and machine learning technology to process your personal data and assess your creditworthiness. The associated processing of your personal data is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for our services or ineligible for credit of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Detecting fraud
Tala also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.
Your rights in relation to automated decision-making
If you apply for a credit and your request is declined (or you are informed that you are ineligible for other or associated products or services) as a result of an automated credit, underwriting or fraud decision, you may request that one of our underwriters review this decision. You may do so by contacting us at: support@tala.ph. You may also object to the automated processing of your personal data, but doing so will prevent us from providing you with our services.
7. Your rights as a data subject
You may contact us to exercise your rights as a data subject at dpo@tala.ph or support@tala.ph. Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your personal data or because we need to retain your personal data to comply with a legal obligation).
Right to be informed
We must provide you with certain information related to how we collect your personal data, how we use your personal data (and our legal basis for doing so), who we share your personal data with, where we obtained your personal data and your rights as a data subject. This information is provided within the Tala App and in this Privacy Policy in clear language.
Right to access
You may ask for a copy of the personal data we hold concerning you, as well as information on how such personal data has been processed, unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request. The right to access does not apply to analyses made by the Company with respect to your personal data, such as inferred, derived, modeled, or business-generated data.
Right to rectification
You may ask us to correct any personal data which you believe to be inaccurate. We will promptly update any such personal data. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the request.
Right to erasure or blocking
You may ask us to erase your personal data:
If you believe it’s no longer necessary for us to retain such personal data;
If you do not believe we have legitimate ground for processing it;
If you think we are using such personal data unlawfully; and/or
If you think applicable law requires that we do so.
Right to restrict or object to processing
Where the processing of your personal data is based on your consent or our legitimate interest, you may ask us to stop using your personal data (as defined under applicable law):
if you think such personal data is inaccurate;
if you think it’s illegal for us to use such personal data;
if you don’t want us to destroy such personal data because you need it for legal proceedings;
if you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.
Right to data portability
If we’re using your personal data on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller. The right to data portability is limited to data that you provided actively and knowingly, or that you provided by virtue of the use of our services.
Right to damages
You have a right to be indemnified if you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, considering any violation of your rights and freedoms as data subject.
Right to file a complaint
You have the right to file a complaint with the relevant government agencies for any violation of your rights as a data subject, including the National Privacy Commission of the Philippines.
8. Advertising and Marketing
If you no longer with to receive advertising, marketing or promotional messaging, please contact us at dpo@tala.ph or support@tala.ph and we will remove you from such communication lists.
9. Consequences of not providing us with your personal data
You are not required to provide us with your personal data and you may withdraw your consent from the use or processing of such personal data. However, if you do so, we will be unable to provide our current or future products and services to you and we reserve the right to terminate our relationship with you, as permitted under applicable law. Further, to the extent we have a legitimate interest in retaining your personal data, we may do so. For example, if you have requested that we erase your personal data, but you have an outstanding balance with Tala, we may retain your personal data in order to continue collection efforts. We are also required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion.
10. Consent and Authorization
By downloading the Tala App and clicking “Accept” on the permissions overview screen, you:
accept the terms of this Privacy Policy;
allow Tala to access the device permissions more fully described below;
give Tala consent to collect, use, share, or otherwise process your personal data, which may include personally identifiable information, personal information, sensitive personal information or privileged information (in each case, as defined under applicable law), as outlined in this Privacy Policy;
certify that all personal data you have provided and will provide to Tala is true and correct to the best of your knowledge;
authorize Tala to verify/investigate the accuracy of your personal data; and
acknowledge that Tala may be required to disclose your personal data to the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, Bureau of Internal Revenue, Credit Information Corporation, credit bureaus and/or any other governmental body, in compliance with its legal obligations and in accordance with the principle of proportionality.
11. What device permissions does the Tala App access?
Depending on your Android Operating System and the version of the Tala app installed on your device, the following device permissions may be accessed by the Tala App. Keep your Tala App updated to make sure you can experience the latest and most secure features.
Camera – Tala will request you to upload photos of your ID and to take a selfie with your ID. Tala may also request you to upload copies of documents as proof of income.
Read your contacts – Tala will retrieve information about your contact lists (such as contact names and numbers, contact frequency, and date of last contact). Tala uses this information in its credit and underwriting models to determine whether you are eligible for Tala’s services. We use automated processing to understand your network relationships, and this also helps our fraud models verify your identity. Tala will never reach out to any of your contacts or provide any of your personal data to your contacts unless you separately and expressly direct us to do so.
Find accounts on your device – Tala checks the list of user accounts created on your device and checks the email address used to create each account. This helps our fraud models verify your identity. Tala also uses this information in its credit and underwriting models to determine whether you are eligible for Tala’s services.
Location – This helps our fraud models verify your identity. Tala also uses this information in its credit and underwriting models to determine whether you are eligible for Tala’s services. We also use location data for research purposes.
Read phone status and identity – When you sign up for a Tala account, Tala will retrieve your phone number from your device automatically. This ensures that the mobile number is active and accurate, and that it is linked to the device you are using to open the account.
Read your text messages – Tala will retrieve information about the SMS stored in your device (such as message ID, direction, timestamp, phone number, and content). Tala uses this information in its credit and underwriting models to determine whether you are eligible for Tala’s services. We use automated processing to understand your financial activity, and this also helps our fraud models verify your identity. Tala will never share the contents of your text messages.
Receive text messages – This is used to automatically confirm the one-time password (OTP) sent to your device via SMS.
Read, modify, or delete the contents of your SD card – Tala will request you to upload photos of your ID and to take a selfie with your ID. Tala may also request you to upload photos of documents as proof of income.
Run foreground service – This permission is needed by the Tala app to upload photos for KYC.
Run at startup – This allows the Tala app to send notifications to your device upon restart of your device.
View and change network connectivity – This is used to notify the Tala app when network connectivity changes so that we can determine whether you are connected to the internet or not.
View Wi-Fi connections – Tala uses the IP address and network type of your device to detect and prevent fraud.
Receive data from the internet – Tala needs this permission in order to send requests through the app and to allow the app to access the internet.
Prevent phone from sleeping – This permission is required by some of the features and services within the Tala App, such as in-app messaging.
Retrieve running apps – Tala will retrieve a list of apps installed on your device. Tala uses this information in its credit and underwriting models to determine whether you are eligible for Tala’s services.
12. General
If you have questions about this Privacy Policy or about your rights as a Data Subject, you can contact our Data Protection Officer at: dpo@tala.ph
To improve and continue our services to you and to comply with data privacy regulations that may be issued from time to time, this Privacy Policy may be updated. We will notify you prior to any updates to this Privacy Policy, either within the Tala App, by SMS, or by email.