CASHNYO Financing Corp ("Cashnyo", "We", "Us", or "Our", for brevity) hereby adopts this Privacy Policy in compliance with the provisions of Republic Act No. 10173, entitled: An Act Protecting Individual Personal Information In Information And Communications Systems In The Government And The Private Sector, Creating For This Purpose A National Privacy Commission, And For Other Purposes, otherwise known as the "Data Privacy Act of 2012".
For this purpose, this Privacy Policy ensures that the personal data gathered from our clients in the course of transactions, and in accordance with the nature of our business, shall remain secured and protected.
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 must read this Privacy Policy in its entirety.
(the "Cashnyo App") and your use of our services through the Cashnyo App or otherwise. It does not apply to your use of the Company's website, found at https://www.cashnyo.com/ (the "Website"). Please see here for the privacy policy applicable to your use of our website. This Privacy Policy applies in connection with your use of the Cashnyo Android mobile application found ("Cashnyo App", for brevity) and your use of our services through the same or otherwise. It does not apply to your use of the Company's website, found at https://www.cashnyo.com/ ("Website", for brevity). Please see here for the privacy policy applicable to your use of our website.(collectively, your "Information")
Cashnyo may collect your Information from:
Collection and processing of your Information by Cashnyo is necessary for the provision of Cashnyo's products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Cashnyo is subject. Aside from such cases, we do not collect Information without your specific prior consent.
We process your Information for the purposes set out above on the following grounds:
Cashnyo shall 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 Cashnyo's products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Cashnyo will only share your Information with third parties in an anonymized format.
You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to:
The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy.
Further, Cashnyo may also share your information with law enforcement or other government agencies pursuant to 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.
To promote its products and services, Cashnyo administers and services a referral program ("Cashnyo Referral Program", for brevity) for its current and future customers. If you choose to accept a referral from another Cashnyo customer and accept a Cashnyo loan in connection with that referral, Cashnyo will provide a bonus to the customer who refers you upon your successful repayment of your Cashnyo loan.
If you choose to participate in the Cashnyo 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 imbedded referral link and subsequently applying for and accepting a Cashnyo loan through such referral.
Sharing of your Information in connection with the Cashnyo Referral Program shall be limited to the information described above and shall remain anonymized – Cashnyo will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Cashnyo. More information on the Cashnyo Referral Program is available within the Cashnyo App.
Your Information will be stored or retained by Cashnyo and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We may also retain your Information (i) 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.
We may transfer your Information 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 Information. Your Information may be processed by any of the parties described in Section 3. Cashnyo will use all reasonable and appropriate efforts as required by applicable law to protect your Information.
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.
When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. 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 machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information 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 a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.
Cashnyo 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.
In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through cs@cashnyo.com.
You may contact us to exercise your rights at cs@cashnyo.com.
We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Cashnyo App and in this Privacy Policy.
You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), 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.
You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. 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 thereof.
You may ask us to delete your personal data (as defined under applicable law) from our system:
You may ask us to stop using your personal data (as defined under applicable law):
If we're using your information 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.
You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data).
You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject, including the National Privacy Commission of the Philippines.
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 information or because we need to retain your information to comply with a legal obligation).
You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through cs@cashnyo.com and we will remove you from such communication lists.
You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Cashnyo, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts.
By downloading the Cashnyo App, you:
If you need to contact us, please do so at: cs@cashnyo.com
To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Cashnyo App or by email.
The provisions of this policy shall have full force and effect beginning 27 March 2020.