Privacy Policy

TOPBET PESO Privacy Policy

This Privacy Policy (hereinafter referred to as "this Policy") aims to explain how we collect, use, and disclose your information when you use the mobile application "TOPBET PESO" (this App). This App is operated by TOPBET TECH CORP., which has established a strategic cooperation with LOAN STAR LENDING GROUP CORP. to provide you with platform support related to loan services only. We and our partners will collect necessary information only after obtaining your explicit consent, and your registration of an account indicates your agreement to process relevant data in accordance with this Policy.

This App does not participate in core loan decision-making. All matters such as loan approval and disbursement are independently decided and executed by the partner LOAN STAR LENDING GROUP CORP. We will strictly take necessary measures to protect the security of your personal information and share information with affiliated parties or third parties to a limited extent only in accordance with legal provisions and the agreements of this Policy.

I. Information We Collect

To provide you with compliant and high-quality loan services, we collect your personal information only within the scope necessary to achieve the service purposes and in accordance with the principles of legality, legitimacy, and necessity.

1.1 Types of Information

• Identity Verification Information: Legal full name, date of birth, gender; government-issued document information and scans such as UMID, TIN, SSS number, and passport; facial biometrics (used solely for KYC identity verification).
• Core Loan Information: Monthly income, income and expenditure status, debt situation; employment information such as workplace, position, and income; loan purpose; bank account and withdrawal information.
• Contact Information: Mobile phone number, email address, residential address; name, relationship, and phone number of emergency contacts.
• Device and Usage Data: Device model, device ID, system version; IP address, operator, network type; page access records, operation logs, usage duration.

1.2 Sources of Information

• Information actively filled in by you during registration and loan application;
• Information submitted by you when consulting customer service or feedbacking issues;
• Verification and anti-fraud information provided by legal channels such as credit reporting agencies;
• Technical data automatically transmitted by your device when using this application;
• Data provided by third parties such as banks and payment institutions authorized by you.

1.3 Collection Principles

We only collect information related to loan services and legal obligations, and do not collect irrelevant content. Except as otherwise specified by laws and regulations or in emergency situations, information collection requires your explicit consent.

II. Rules for Information Use

We will use the information in accordance with the agreements of this Policy and will not use it beyond the scope without your authorization or legal permission. Specific purposes include:

• Loan Service Operation: Processing loan applications, assessing creditworthiness and repayment capacity; completing loan disbursement, transaction processing, repayment reminders, and overdue management.
• Identity Verification and Risk Control: Verifying the authenticity of information, preventing risks such as fraud and money laundering; cooperating with credit institutions to improve service security.
• Service Optimization: Improving product functions and service processes through usage data and resolving issues feedbacked by users.
• Customer Support: Providing you with consultation answers, complaint handling and other services.

III. Information Sharing and Disclosure

We strictly protect your information and only share your information with necessary parties in the following legal scenarios:

3.1 Sharing Recipients

• Third-Party Service Providers: Cooperation partners that provide us with services such as data storage and technical support. Such providers are bound by this Policy and use information only to perform their services.
• Cooperating Loan Providers: Loan institutions, banks, etc. cooperating with us for loan review, fund settlement, and credit verification.
• Regulatory Authorities: Disclosing information in response to legal requirements from institutions such as the Bangko Sentral ng Pilipinas (BSP), Anti-Money Laundering Council (AMLC), Securities and Exchange Commission (SEC), and National Privacy Commission (NPC), or to comply with judicial procedures.
• Protection of Rights and Interests: Disclosing information to relevant parties when necessary to protect your legitimate rights and interests or those of others, maintain service order, or prevent illegal activities such as fraud.

3.2 Sharing Guarantees

Before sharing information with third parties, we will sign data processing agreements with them to clarify information protection obligations. When providing data to research and statistical institutions, we will anonymize the data to ensure that individuals cannot be identified.

3.3 Information of Cooperating Loan Provider

• Loan Provider Name: LOAN STAR LENDING GROUP CORP.
• SEC Registration Number: CS201420759
• Authorization Certificate Number: 1652
• Email Address: legal@loanstarlendingcorp.com
• Contact Phone Number: +63 9543111960
• Office Address: 4th Floor, Carsib Building, Orense Street Corner Del Carmen Street, Guadalupe Nuevo, Makati, Metro Manila, 1200 Philippines

IV. Information Storage and Protection

4.1 Storage Specifications

• Storage Location: Your information is stored on compliant servers within the Philippines. If cross-border transmission is required, it will be filed and encrypted in accordance with the Data Privacy Act.
• Storage Period: Retained only for the time necessary to achieve the service purposes, and deleted or anonymized after expiration. In cases such as legal obligations and potential disputes, the storage period will be extended until the relevant matters are resolved.

4.2 Security Measures

We adopt international standard security measures to protect your information:

• Technical Level: Storing information with AES-256 encryption, transmitting data with SSL/TLS encryption, and deploying firewalls to prevent attacks.
• Emergency Mechanism: Formulating data security plans. In the event of information leakage or other incidents, we will respond immediately and notify you and the NPC within 72 hours.

V. Your Information Rights

In accordance with the Philippine Data Privacy Act, you enjoy the following rights, and we will assist you in exercising them:

• Right of Access: You may request a copy of your information held by us and information about its processing.
• Right to Rectification: You may request correction and supplementation if the information is inaccurate or incomplete.
• Right to Erasure: You may request the deletion of information when the service purpose is achieved, you withdraw consent, or as permitted by law.
• Right to Withdraw Consent: You may withdraw consent to information processing at any time (except as otherwise specified by law), but this may affect the use of services.
• Right to File a Complaint: You may file a complaint with the NPC if you believe our processing activities are illegal.

To exercise the above rights, please contact us through the methods in the "Contact Us" section. We will respond and handle the matter in accordance with the law within 48 hours.

VI. Protection of Special Groups

This application is only intended for users aged 18 and above, and we do not intentionally collect information of minors. If information is collected by mistake, we will immediately stop processing and verify and delete it. Minors who need to use the service shall do so under the accompaniment of their legal guardians.

VII. Description of Third-Party Services

This application may contain third-party links such as bank payment pages and credit inquiry platforms. The privacy policies of third parties are formulated by themselves and have no connection with us. We recommend that you carefully read their privacy terms before use.

7.1 Apple App Tracking Transparency (ATT) Framework Description

To comply with the Apple App Store Review Guidelines (including the App Tracking Transparency Framework) and the requirements of the Philippine National Privacy Commission (NPC) Data Privacy Act of 2012 regarding the principles of transparency and consent, when this application runs on iOS devices and involves cross-app or cross-website tracking behaviors, we will strictly follow the following specifications:

● ATT Authorization Mechanism

Before accessing device information that requires ATT authorization (including but not limited to IDFA, advertising attribution parameters, and cross-app activity data), this application will initiate an authorization request to you through a system pop-up window. We will only access relevant data if you explicitly click "Allow". If you disagree, we will not collect or use such information.

● Data Involved in ATT and Its Purposes

With your authorized consent, this application may use IDFA or related data for:

1. Anti-fraud, risk management, and device security identification;
2. Advertising attribution and statistical analysis;
3. Effectiveness monitoring of application promotion channels;
4. Complying with the regulatory requirements of NPC and BSP for anti-fraud monitoring and risk identification.

We will not sell IDFA or any personally identifiable information to any third party, nor use it for personalized advertising beyond the scope of consent.

3. Impact of Unauthorized Access

If you select "Ask App Not to Track", we will not access IDFA or any data requiring ATT authorization. This will not affect your use of core functions such as loan application, account management, and repayment, but the accuracy of some advertising attribution and anti-fraud measures may be reduced.

4. You Can Modify Authorization at Any Time

You can enter:

Settings > Privacy & Security > Tracking

to enable or disable authorization for this application at any time.

We strictly comply with Apple's platform policies and the principles of legal processing, transparency, and proportionality under the NPC Data Privacy Act, and will not conduct any cross-app tracking without your explicit consent.

VIII. Policy Updates and Notifications

We may update this Policy in accordance with changes in laws and regulations and service upgrades. The updated version will be published on the "Me - Privacy Policy" page.

If the Policy involves the following major changes, we will notify you 7 days in advance through pop-up windows, text messages, or emails:

• Major changes to the scope or purpose of information collection, use, and sharing;
• Changes to your core rights and the methods of exercising them;
• Major adjustments to information security measures;
• Major changes to the responsible entity or cooperating third parties.

Your continued use of this application constitutes acceptance of the updated Policy. We recommend that you review it regularly to stay informed of the latest content.

IX. Contact Us

If you have any questions about this Policy, need to exercise your information rights, or have complaints or feedback, you can contact us through the following methods:

TOPBET PESO Official

• Company Name: TOPBET TECH CORP.
• Office Address: 7th Floor, Aseana One, Bradco Avenue, Aseana City, Paranaque, Metro Manila, 1701 Philippines
• Customer Service Email: contact@topbettech.com

Cooperating Loan Provider

• Email Address: legal@loanstarlendingcorp.com
• Contact Phone Number: +63 9834452033
• Office Address: 101-102, 202 Trina Place, 507 Salas St, Ermita, Manila, 1000 Metro Manila, Philippines

We will respond to your request and resolve the issue within 48 hours.