Effective Date: March 1, 2022
Tala Financing Philippines Inc., a corporation organized and existing in the Philippines (“Tala”, “we”, “us” or “our”) takes your privacy very seriously.
1. What personal data does Tala collect and process? From where does Tala collect your personal information?
Tala collects the following personal data (as defined under applicable law), including personally identifiable information:
Tala collects your personal data from:
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 information?
We process your personal data for the purposes set out above on the following grounds:
3. Who do we share your personal data with?
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 (as defined under applicable law) 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:
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.
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 your personal data 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 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 Tala. More information on the Tala Referral Program is available within the Tala App.
4. For how long will we retain your personal data?
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.
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.
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.
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: firstname.lastname@example.org. 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 email@example.com or firstname.lastname@example.org. 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 ground for using or processing your personal data or because we we need to retain your personal data to comply with a legal obligation.
You may ask for a copy of the personal data (as defined under applicable law) we hold concerning you (and your Information related to such personal data), 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.
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.
You may ask us to erase your personal data (as defined under applicable law):
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 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.
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.
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.
Please note that there may be occasions when you wish to exercise your rights and we’re 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).
8. Advertising and Marketing
If you no longer with to receive advertising, marketing or promotional messaging, please contact us at email@example.com or firstname.lastname@example.org 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 Information or any associated personal data (as defined under applicable law) and you may withdraw your consent from the use or processing of such Information or 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 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 an outstanding balance with Tala, we may retain your Information or associated personal data (as defined under applicable law), 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:
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.