TALA APP PRIVACY NOTICE

Who will process my data?

• Tala Financing Philippines Inc. (“Tala”) controls the processing of your data. We are a trusted global company that offers financial services through our mobile app (the “Tala App”). We are licensed by the SEC to serve customers in the Philippines (SEC Reg. No. CS201710582, CA No. 1132).
• In some cases, there may be another company that controls the processing of your personal data. Such as:
  • If your Tala App loan is being funded by our loan channeling partner bank (in this case, the partner bank will also control your data, together with Tala)
  • If you have an e-wallet in the Tala App (in this case, the e-wallet partner will also control your data).

Will Tala share my data with anyone?

• Tala keeps your data safe and we will only share data with authorized persons.
• Some of Tala’s teams are in other parts of the world. Your data will also be processed by other members of the Tala Group, like our parent or sister companies, which are outside the Philippines.
• Our partners help us provide services to you. They include:
  • Financial service companies like payment and remittance platforms, e-wallets, and banks, which allow transfers of funds and payments
  • Partners like Maya Bank, which help us fund your loans
  • Messaging services like telcos for text messages, online messengers for chat, or email platforms, which allow us to communicate with you
  • Third party services like customer support, collections, and marketing agencies, which allow us to address your concerns, collect your payments, and invite you to join promos
  • Fraud prevention platforms that allow us to review your information and keep the Tala App safe
• If you join Tala’s Referral program, Tala may provide a bonus to the customer who refers you when you repay your loan. We will not share details about who made the payment.
• Tala may be required by law to share your data with government agencies such as the Credit Information Corporation (CIC) for credit reporting and the Bureau of Internal Revenue (BIR) for tax purposes.
• We may share your data to other public or private third parties to exercise our rights or to protect other customers, such as law enforcement, legal counsel, auditors, and advisors.
• We may also transfer or assign your balance to another company in cases like a merger or acquisition of Tala. You will be notified if this happens.

Where does Tala get my data?

• Tala App - We collect your data when you install and use the Tala App on your phone. This includes data that you type, upload, or submit in the Tala App, data about your use of the app, and data from your phone where the app is installed.
• Payment and fund transfer channels - We collect data about your Tala payments and fund transfers from the channels that you use.
• Tala agents - We collect data from your interactions with our agents, including your account service requests through calls, chat, email, message, or web form, and your participation at Tala surveys and events.
• Credit reference agencies - We may collect data about you from CIC or credit score providers.
• Partners - We may enter into partnerships to allow Tala to offer services to the partner’s clients or users.

What data does Tala collect and process?

• ID Data. We need data to confirm your identity: copy of your valid ID, your ID number, full name, date of birth, birthplace, and photo
• Contact Details. We need data to get in touch with you: phone number, alternate number, SIM number, email address, home address
• Transaction and Session Data. We need data to process your Tala transactions: Tala App logins, usage, requests, transfers, payments, account numbers
• Interaction Data. We collect and process data from your interactions with us and our agents, including text, chat, email, call, web form, and your participation in surveys, promos, raffles, games, and contests
• Background Data. Tala will ask about your income, employment, loan purpose, education, device ownership. We may also collect data about your financial history from CIC or credit score providers
• Device Data. Tala will collect information about your phone where the Tala App is installed: SIM and and number, IMEI, IP address, device type, operating system, network, settings, SMS keywords, contacts, device or account identifiers, apps installed, location

Why does Tala collect and process my data? What’s the basis?

• There are legal obligations that apply to Tala as a financing company.
  • We confirm your identity and contact details. We conduct KYC (know-your-customer) screening and monitoring to comply with anti-money laundering laws.
    • For this, we need: ID Data; Contact Details; Transaction and Session Data; Background Data
  • We submit basic credit data to the CIC.
    • For this, we need: ID Data; Transaction and Session Data; Background Data
  • We remit taxes to the BIR.
    • For this, we need: Transaction and Session Data
• Tala must also process your data to start, fulfill, or enforce our contract with you.
  • We check if you are eligible for Tala’s services.
    • For this, we need: ID Data; Contact Details; Transaction and Session Data; Background Data, Device Data
  • We maintain your account and process your requests such as loans, payments, cash in, cash out, transfers, and tickets.
    • For this, we need: Transaction and Session Data, Interaction Data
  • We operate the Tala app, fix errors, install updates, and secure it against fraud and illegal uses.
    • For this, we need: Transaction and Session Data; Device Data
  • We train our agents to contact you, remind you about repayment, and resolve your concerns
    • For this, we need: Contact Details, Transaction and Session Data; Interaction Data; Device Data
• We also process your data based on our legitimate interest.
  • We study your use of the Tala App to help improve our services.
    • For this, we need: Transaction and Session Data; Interaction Data; Device Data
  • We send you offers, updates, and promos
    • For this, we need: Contact Details; Transaction and Session Data; Interaction Data

How does Tala process my data? To what extent?

• Scoring. Tala is a tech company and we use automated processing, including machine learning and data science, in our operations. When you open a Tala App account and apply for a loan, our automated system will determine the amount that you can borrow, based on your profile and the data that we collect from you. We conduct thorough research and testing to keep our systems as fair and accurate as possible.
• Fraud. Our systems are also used to detect and prevent fraud or other illegal uses of the Tala App. We may conduct further investigations on fraud patterns and potential unlawful activity. We may exercise all remedies available to us, including filing cases with courts or agencies.
• Account Services. We may also use automated tools to manage your account, such as scheduled messages, auto dialers, pre-recorded calls, robocalls, chatbots, and self-service menus. We constantly work to improve these tools.

How does Tala protect my data?

• Tala implements an information security management system that meets global standards. This includes policies, procedures, and practices that protect personal data.
• We enforce strong security measures across our company and our teams. We make sure that the tools and platforms that we use are secure and respectful of privacy.
• Our staff is trained and required to follow privacy principles in every data processing activity.

Until when will Tala keep my data?

• Tala will retain your personal data as long as your Tala App account remains open. If you close your Tala App account, we must continue to store your account data for five (5) years from the date that your Tala App account is closed. This is a requirement under anti-money laundering laws.
• When the period expires, we will delete personal data. Tala may continue to store data in an anonymized form.
• We may keep your personal data for a longer period if we need to comply with a legal obligation or if we need to defend the rights of Tala or a third party.

Where does Tala process my data?

Tala will process your data in electronic form and we use cloud or online storage with servers in Singapore and in the United States. We conduct processing online in different countries where members and staff of the Tala Group are present, including locations outside of the Philippines. We make sure that wherever the processing is done, your data will be protected with adequate safeguards, including encryption in transit and at rest.

What are my rights as a data subject?

• Right to be informed. You must be given details, in clear and plain language, about how your data is collected and used (plus the legal basis for this), where your data may be transferred or shared, if automated processing will be done, and what your data subject rights are.
• Right to access. You may ask for a copy of the personal data that we hold about you, as well as details on how it has been processed and who may have received copies of it.
• Right to correction. You may ask us to correct any personal data about you that is not accurate. We may ask you to provide supporting evidence for the request.
• Right to object. You may ask us to stop processing your data if our basis for doing so is your consent or our legitimate interest, and no other basis can apply.
• Right to erasure or blocking. You may ask us to erase your personal data if it is inaccurate, or the collection or processing was unlawful, or your rights were violated, or if we no longer need it for the purpose for which it was collected, and no other basis can apply. You may request the deletion of your Tala App account here.
• Right to data portability. If we are processing your data based on your consent or to fulfill a contract with you, you may ask us to give you a copy of your data in a structured, common, and machine-readable format, or to have it transmitted to another data controller.
• Right to damages. You have a right to receive damages if your privacy rights were violated or you were injured by inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
• Right to file a complaint. You have a right to file a complaint with the National Privacy Commission. If you feel that your personal data has been misused, maliciously disclosed, or improperly disposed of, or that any of your data privacy rights have been violated.

How do I exercise my data subject rights? What is the effect of exercising them?

• You can send your request to dpo@tala.ph. We will need to review each request, and in some cases we may ask for supporting documents.
• If you wish to withdraw your consent from processing or object to the automated processing of your data, Tala will not be able to provide you with our services. We may also close your Tala App account, with notice to you.
• We may deny your request if we have valid grounds, such as: if we need to comply with a legal obligation; if you have unpaid loans; or if we need to protect the rights of Tala or a third party.

What does Tala access on my device?

Depending on the operating system of your device, Tala will need access to certain permissions to allow us to collect Device Data. Keep your Tala App updated to make sure you have the most secure features. For Android devices, you can refer to our Data Safety page.