Sure Money Privacy Policy
Welcome to the Sure Money platform and application. At Sure Money Lending Investors Inc., we prioritize your privacy and are deeply committed to safeguarding the confidentiality, integrity, and security of all personal information you entrust to us. We strictly adhere to the provisions of the Data Privacy Act of 2012 (Republic Act No. 10173), along with all other applicable laws, regulations, and guidelines enforced by the Republic of the Philippines to ensure that your data is handled with the utmost care and responsibility.
This Privacy Policy is designed to transparently inform you about how we collect, process, use, store, disclose, and protect your personal data throughout your interactions with the Sure Money platform and services. Whether you access our services via our mobile application, website, or other digital interfaces, this policy sets forth the types of information we gather, the purposes for which your data is used, the measures we take to protect your information, and your rights as a data subject.
We are committed to maintaining your trust by applying industry-leading data security practices, limiting data access to authorized personnel only, and ensuring compliance with all regulatory standards governing data privacy and protection. By using Sure Money's services, you acknowledge and consent to the practices described in this Privacy Policy, and we encourage you to review this policy regularly as it may be updated to reflect changes in legal requirements or operational practices.
1. Company Information
Company Name: Sure Money Lending Investors Inc.
SEC Registration Number: CS201907919
Certificate of Authority: 2976
App Name: Sure Money
Before registering and using our services, please read this Privacy Policy carefully. By accessing or using the Sure Money app or platform, you confirm that you fully understand and agree to the practices described in this policy.
2. Personal Information We Collect
When you access or use the Sure Money app, we may collect various types of information from you. These may include:
2.1 Identity Information
* Full name
* Identification type and number (e.g., UMID, Driver's License, Passport)
* Date of birth
* Place of birth
* Age
* Gender
* Civil status
* Educational background
* Citizenship
* Home and permanent address
2.2 Contact Information
* Mobile phone number
* Email address
* Emergency contact details
* Relationship to emergency contact
2.3 Financial Information
* Bank or e-wallet account numbers
* Bank name and branch
* Employment details (job title, company name, address, contact)
* Monthly income and income source
* Salary disbursement schedule
* Type and status of employment
2.4 Device and Technical Information
* Device model and manufacturer
* Operating system and version
* Language settings and region
* IP address
* Internet service provider
* Battery level and optimization settings
* App usage behavior
* List of installed applications
* Device fingerprint
* Advertising ID (e.g., Google Advertising ID, IDFA for iOS)
2.5 Usage and Behavioral Information
* Frequency and duration of app use
* Interaction logs and clickstream data
* In-app behavior patterns
* Session identifiers
* Referral sources
3. Purpose of Personal Data Use
We collect and use your data solely for lawful and specific purposes, including but not limited to:
3.1 Identity Verification
To validate your personal details and authenticate your identity for legal and security purposes.
3.2 Credit Evaluation
To assess your creditworthiness using various criteria, including third-party scoring tools, app usage data, and reference checks.
3.3 Loan Application Processing
To process, evaluate, approve, release, and monitor your loan application and related financial transactions.
3.4 Communication and Notifications
To provide timely updates on your account, transaction alerts, payment reminders, and promotional content.
3.5 Customer Support
To address your inquiries, resolve issues, and improve your overall experience through in-app chat, phone, or email support.
3.6 Fraud Prevention and Risk Management
To detect, prevent, and mitigate fraudulent, unauthorized, or illegal activity through tools such as Know Your Customer (KYC), Anti-Money Laundering (AML) checks, and Politically Exposed Person (PEP) screening.
3.7 Legal and Regulatory Compliance
To comply with applicable laws, government regulations, orders, and lawful requests from authorities.
3.8 Debt Collection
If applicable, to pursue collection activities on unpaid loans, which may include sharing data with licensed third-party collectors.
3.9 Service Improvement and Analytics
To enhance product features, conduct surveys, generate reports, and analyze usage trends via analytics tools and SDKs.
4.Permissions We Request
To enable key functionalities and provide secure, seamless loan services tailored to your needs, the Sure Money app may request access to certain device permissions. These permissions are requested only with your explicit prior consent, and we strictly limit the data collected to what is necessary for legitimate financial service purposes. We adhere to Google Play policies and applicable privacy regulations to ensure transparent, secure, and responsible data handling.
4.1 Camera Permission
The app requests access to your device camera to allow you to take real-time photographs of your valid ID and other required documents during the loan application process. This facilitates fast, accurate identity verification and document submission without requiring external hardware.
4.2 Photo Album / Gallery Access
To expedite your application, you may upload existing photos of your IDs or supporting documents from your device's photo gallery. This permission is limited strictly to selecting files you choose to upload and does not grant us access to other media without your action.
4.3 Location Access
Location permission is requested to verify your address and regional eligibility for loan services, and to enhance fraud prevention mechanisms. We collect only coarse location data sufficient for these purposes and do not track or store your precise GPS coordinates. Location data is processed securely and in compliance with data privacy laws.
4.4 Network Access
Network permission is necessary for stable internet connectivity, enabling secure transmission of your application data, document uploads, and real-time updates. We use encrypted communication channels to protect your data during transit.
4.5 App Usage and App List Access
We request limited access to app usage statistics and the list of installed applications strictly for the purpose of evaluating device integrity, detecting rooted or tampered devices, and supporting creditworthiness assessments. This information is collected and processed anonymously where possible and only used to reduce risk and enhance security.
4.6 Advertising ID Access (IDFA/GAID)
Advertising ID access is used solely for fraud detection, analytics, and marketing attribution purposes. We comply fully with Google and Apple platform guidelines regarding user consent, data minimization, and opt-out capabilities. Your advertising ID data is handled with strict confidentiality and never linked with personally identifiable information without your consent.
4.7 SMS Access (Financial-related only)
To streamline loan processing and payment verification, the app may request permission to access SMS messages related strictly to financial transactions, such as bank alerts, loan repayment confirmations, or salary credits. We do not access or store SMS content unrelated to financial activities. All financial SMS data is encrypted, stored securely, and processed only to improve service accuracy and reduce manual entry errors.
We ensure that all data collected through these permissions is stored securely using industry-standard encryption methods, access controls, and regular security audits. Your personal information is isolated and protected against unauthorized access, alteration, or disclosure. We retain data only as long as necessary to fulfill our service obligations and comply with legal requirements.
By granting these permissions, you help us provide you with faster, safer, and more personalized loan services. You may revoke any permission at any time through your device settings, though this may affect some app functionalities.
5. SDKs and Third-party Integrations
We may incorporate third-party SDKs that collect technical and behavioral data for legitimate use:
5.1 Facial Recognition SDK
Used during the identity verification process to validate the authenticity of your uploaded ID against your facial biometrics.
5.2 AppsFlyer
Used for mobile attribution, performance measurement, analytics, and marketing optimization. AppsFlyer may collect device identifiers, IP address, and campaign data.
5.3 Firebase SDK
Used for analytics, crash reporting, and performance monitoring to improve app stability and user experience. Firebase may collect device identifiers, app usage data, crash logs, and performance metrics. Data collected is processed by Google in accordance with its Privacy Policy
All third-party SDKs are bound by contractual agreements to process your data securely and only for authorized purposes.
6. Updating and Correcting Personal Information
You are responsible for ensuring that the information you provide is accurate and current. To request changes, corrections, or updates, you may:
* Use the in-app update feature
* Contact us via email at gwytnethcaasi@suremoneylending.com
7. Disclosure of Personal Information
We may disclose your information only as necessary and permitted by law:
7.1 Internal Sharing
To employees, directors, agents, and affiliated entities who are authorized to handle your information with confidentiality.
7.2 Third-party Service Providers
Including technical providers, cloud storage services, identity verification partners, and debt collection agencies.
7.3 Credit Agencies
To report or inquire about your credit history, including potential defaults or delinquencies.
7.4 Government and Regulatory Bodies
To respond to lawful requests from the National Privacy Commission (NPC), Bangko Sentral ng Pilipinas (BSP), courts, or law enforcement agencies.
8. Data Retention and Disposal
Your personal information is stored in a secure and encrypted environment. We retain your data for as long as required by:
* The purpose for which it was collected
* Applicable regulatory requirements
* Internal audit and accounting needs
When data is no longer needed, we will securely destroy it using appropriate deletion procedures such as anonymization, digital erasure, or shredding for physical records.
9. Your Rights as a Data Subject
Under the Data Privacy Act of 2012, you have the right to:
* Be informed of how your data is collected and processed
* Access and request a copy of your personal data
* Correct or update inaccurate or outdated data
* Object to data processing under certain circumstances
* Withdraw consent at any time
* Request data deletion when no longer necessary
10. Data Security
We implement robust physical, technical, and organizational safeguards, such as:
* End-to-end encryption
* Secure cloud infrastructure
* Multi-factor authentication
* Regular penetration testing and vulnerability scans
* Internal access controls and audit trails
Your data is our responsibility, and we are committed to keeping it safe.
11. Updates to This Privacy Policy
We may revise this Privacy Policy from time to time due to changes in laws, regulations, or company policies. Updates will be published in-app or on our website. Continued use of our services constitutes acceptance of the revised policy.
12. Contact Information
If you have questions, feedback, or concerns about this Privacy Policy or how your data is handled, please contact us:
Sure Money Lending Investors Inc.
Sitio, Kamangahan, Barangay Labogon, Mandaue City, Cebu, 6014 Philippines
Email: gwytnethcaasi@suremoneylending.com
13. Consent Statement
By using the Sure Money app and submitting your information:
* You affirm that all details provided are true and accurate
* You authorize Sure Money to verify and process your data
* You acknowledge that Sure Money may disclose your information as described above
* You confirm that you have obtained the consent of your emergency contacts or references
If you disagree with any portion of this policy, please discontinue use of the app immediately.
14. Children's Privacy
Sure Money is firmly committed to protecting the privacy of minors. Our services are strictly intended for individuals who are 18 years of age or older, and we do not knowingly collect, use, or store any personal information from children under the age of 18.
During the account registration and identity verification process, users are required to confirm their age as part of our compliance measures. If we discover or are informed that we have inadvertently collected personal data from a user under 18, we will take immediate action to:
Suspend access to the associated account
Permanently delete all related personal data from our systems
Notify the user's parent or legal guardian, if contact information isz` available
Inform relevant regulatory authorities if necessary
We also implement technical controls and age-gating mechanisms to prevent underage individuals from accessing or attempting to use our platform.
We strongly encourage parents and guardians to actively supervise their children's online and mobile activities and to educate them about safe internet practices. If you believe that a child under 18 has provided us with personal data or is using our services without authorization, please contact us immediately at:
Email: gwytnethcaasi@suremoneylending.com
We will investigate the matter promptly and delete any associated data in compliance with applicable privacy laws.
15. Account Deletion
You may delete your account at any time via the “Me > Delete Account” feature within the app, or by sending a request to gwytnethcaasi@suremoneylending.com. We will verify your identity before processing the request.
