2.1 Generally, we may collect Personal Information in the following ways:

1. when you apply for a loan through emails, telephone calls or via our website or loan application or management system;
2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
3. when you submit any form or application to us;
4. when you interact with our staff, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, and emails;
5. when you interact with our staff, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
6. when you use our electronic services, or interact with us via our websites, and apps or use services on our websites;
7. when you request that we contact you or request that you be included in an email or other mailing list;
8. when you respond to our initiatives or to any request for additional Personal Information;
9. during CCTV recordings when you visit our premises, or photo taking or video recording at our premises or during n90’s events;
10. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
11. when we receive references from business partners and third parties, for example, where you have been referred by them with your consent;
12. when we seek information from third parties about you and receive your Personal Information in connection with your relationship with us, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
13. when you submit your Personal Information to us for any other reasons.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.

2.3 If you provide us with any Personal Information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes.

2.4 You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to fulfill your requests, or delays in processing your requests.

3.1 Generally, n90 collects, uses, processes and discloses your Personal Information for the following specific purposes on basis of the consent given (where applicable) for:

1. transacting with you and providing our loan services and products;
2. responding to your queries, feedback and requests;
3. managing the administrative operations of n90 and complying with internal policies, reporting requirements and procedures;
4. managing the safety and security of our premises and systems;
5. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of our entities;
6. conducting marketing and communication activities, including posting on our websites or social media platforms or inclusion into videos and marketing collaterals;
7. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our services and products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our services and products;
8. monitoring or recording phone calls for quality assurance, employee training and performance evaluation and identity verification purposes;
9. matching any Personal Information held which relates to you for any of the purposes listed herein;
10. hosting, storing or backing-up your Personal Information, which may be on third party servers or data clouds;
11. legal purposes in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
12. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal, statutory or regulatory bodies which are binding on n90 (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, disclosures required in the public interest or emergencies and conducting audit checks, due diligence and investigations which may be carried out by statutory authorities); and/or
13. purposes which are reasonably related to the aforesaid.

3.2 In addition, n90 collects, uses and discloses your Personal Information for the following purposes:

1. if you are a borrower of n90:
   1. evaluating your financial capacity and ability to repay the loan based on income, expenses, and assets.
      
   2. determining your creditworthiness and  risk profile.
   3. verifying your identity
   4. streamlining loan approvals
   5. detect and mitigate fraudulent activities
   6. complying with legal and regulatory requirements
   7. monitoring loan repayment behavior to ensure compliance with loan terms.
   8. enhancing customer experience
2. if you are a vendor of n90:
   1. assessing your suitability as vendor (i.e. external service provider, consultant, contractor etc.);
   2. managing requests for proposals or quotations, processing orders or managing supply of goods and/or services;
   3. processing and payment of invoices; and/or
   4. purposes which are reasonably related to the aforesaid.
3. if you submit an application to us as a candidate for an employment or other post:
   1. evaluation and assessment of your suitability;
   2. conducting interviews;
   3. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
   4. providing or obtaining references and for background screening;
   5. assessing your suitability for the position applied for;
   6. onboarding successful candidates and facilitating human resource planning and management; and/or
   7. purposes which are reasonably related to the aforesaid.
4. if you are an employee of n90:
   1. staff orientation and entry processing;
   2. determining, processing and reviewing salaries, bonuses and other benefits;
   3. assessing your performance;
   4. considering and processing applications for continuing skills development and training, including organizing training and staff development programmes or events;
   5. administrative and support processes relating to your employment, including its management and termination, staff benefits, including travel, manpower, business continuity and logistics management or support, processing claims, training, learning and talent development, and planning or organizing corporate events;
   6. business continuity purposes;
   7. conducting analytics and research for human resource planning and management and developing, optimizing and improving work-related practices and environment;
   8. conducting internal investigations and proceedings, whistleblowing, internal monitoring and audits; and/or
   9. purposes which are reasonably related to the aforesaid.

4.1 n90 will take commercially reasonable steps to protect your Personal Information against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Information may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

1. n90’s related corporations and employee(s); to address your questions and requests in relation to your interactions with us, to maintain and operate our systems and/or services;
2. agents, contractors or third-party service providers who provide services to n90, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, security, or other services to n90;
3. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of our entities;
4. external banks and their respective service providers;
5. share registrars;
6. companies which provide corporate secretarial services;
7. our professional advisers such as consultants, auditors and lawyers;
8. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
9. any other party to whom you authorize us to disclose your Personal Information to.

4.2 Please note that the disclosures referred above may be subject to additional legal requirements under applicable law, if we do disclose your Personal Information, we will only do so to the extent necessary, proportionate and legally permitted.

5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s clickstream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
‍
5.2 Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
‍
5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to use certain services or enter certain part(s) of our website.

6.1 The Borrower has the following rights under the DPA, which may be exercised by contacting the Lender in writing:

1. Right to Be Informed: To know how your data is collected, used, and shared.
2. Right to Access: To request a copy of your personal data.
3. Right to Correction: To correct inaccurate or outdated data.
4. Right to Object: To refuse the processing of your data for certain purposes.
5. Right to Erasure: To request deletion of your data, subject to legal or contractual obligations.
6. Right to Data Portability: To request your data in a commonly used electronic format.
7. Right to File a Complaint: To lodge a complaint with the National Privacy Commission.

7.1 n90 will take reasonable efforts to protect Personal Information in our possession or our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We implement appropriate organizational, technical, and physical measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include but are not limited to:

• Encryption: Ensuring that sensitive data is encrypted during transmission and storage to prevent unauthorized access.
• Access Controls: Restricting access to personal data to authorized personnel only, based on the principle of least privilege.
• Regular Security Audits: Conducting regular audits and assessments to identify and address vulnerabilities in our systems.
• Secure Software Development: Employing secure coding practices to minimize risks associated with software vulnerabilities.
• Incident Response Plan: Maintaining a comprehensive incident response plan to address potential data breaches promptly and effectively.
• Data Minimization: Collecting only the personal data necessary for the purposes outlined in this policy and retaining it only for as long as needed.
• Physical Security: Securing physical locations where personal data is stored to prevent unauthorized access or theft.

However, we cannot completely guarantee the security of any Personal Information we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the various associated risks with using websites.

‍

7.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or otherwise and we urge you to take every precaution to protect your Personal Data when you are on the internet or use such platforms.
‍
7.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.

‍

8.1 If the transfer of your Personal Information within our affiliates or subsidiaries is necessary, we will take reasonable steps to ensure that your Personal Information transmitted outside of your country of residence remains adequately protected to a standard similar to that afforded by the DPA. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.
‍
8.2 All Personal Information is retained for as long as it is necessary for the purposes it has been collected for in accordance with our data retention policy. Any third party who manages our Personal Information is also required to ensure that the Personal Data is disposed of in accordance with the retention period as may be agreed in their respective engagement contract(s).

‍

9.1 If you:

1. have any questions or feedback relating to your Personal Information or our Data Privacy Policy;
2. would like to exercise your rights under Section 6 of this Policy;
3. would like to withdraw your consent to any use of your Personal Information as set out in this Data Privacy Policy;
4. would like to obtain access and make corrections to your Personal Data records, you can approach us via hello@n90.asia

9.2 Please note that if your Personal Information has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organization or individual to make such queries, complaints, and access and correction requests to n90 on your behalf.
‍
9.3 If you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, n90 may not be in a position to continue to provide its products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with n90, and your being in breach of your contractual obligations or undertakings. n90’s legal rights and remedies in such an event are expressly reserved.

10.1 Our website or application system may contain links to other third-party operated websites over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our website or application system. Once you have left our website by clicking a relevant link, your use of that third-party website will be governed by the privacy or data protection policy of that website.

11.1 This Data Privacy Policy and your use of this website shall be governed and construed in all respects by the laws of the Republic of the Philippines.