1. Scope
This Privacy Policy applies to personal information processed by Inclusive Nova Lending Inc. when you visit FlowFund, register an account, apply for credit, complete identity verification, receive disbursement or repayment support, contact customer service, or use related features.
In this Policy, “FlowFund,” “we,” “us,” and “our” refer to the app, its operator, and authorized service partners where applicable. “You” and “your” refer to users, applicants, and customers of our services.
We aim to process personal information in line with Republic Act No. 10173, the Data Privacy Act of 2012, its implementing rules, and other applicable Philippine requirements.
2. Information we collect
To create your account, verify your identity, assess eligibility, provide services, prevent fraud, and comply with legal obligations, FlowFund may collect the following categories of information through our app, website, customer support channels, and authorized platforms.
- Identity and verification information, including full legal name, date and place of birth, age, sex, occupation, government ID details, ID number, KYC status, selfie image, facial verification data, and other proof needed to confirm your identity.
- Contact and account information, including mobile number, email address, residential address, verified SIM or phone information, communication account details, and emergency or reference contacts that you provide or authorize.
- Financial and credit information, including application details, requested amount, eligibility responses, income or employment information, account or card details for disbursement and repayment, transaction history, repayment activity, and records used to assess credit reliability.
- Device, network, and security information, including IP address, device model, operating system, mobile carrier, network status, device identifiers, Android ID where applicable, device fingerprint, VPN usage, app event logs, and other fraud-prevention indicators.
- Optional permission-based data, where allowed by law and only with your consent, such as location information, relevant financial SMS signals, installed app information, image data for verification, and similar data used for security, fraud prevention, eligibility assessment, and service improvement.
- Support and communication records, including customer service messages, complaint details, call notes, uploaded documents, notices, and responses we send to you.
3. Why we collect your information
We use personal information for purposes necessary to operate FlowFund safely and lawfully, including:
- Account creation, authentication, identity verification, KYC review, and account security.
- Credit application review, eligibility assessment, loan processing, disbursement, repayment management, and transaction support.
- Fraud detection, risk monitoring, suspicious activity prevention, platform abuse prevention, and information security.
- Customer support, complaint handling, account notices, software notifications, payment reminders, and other essential communications.
- Product analytics, service improvement, troubleshooting, audit, reporting, and operational quality control.
- Legal and regulatory compliance, including anti-money laundering, credit reporting, consumer protection, tax, court, regulator, and law-enforcement requirements.
- Marketing or promotional communications only where allowed by law and, where required, with your consent.
4. Sharing and disclosure
We may share personal information when required by law, authorized by you, or necessary to provide and protect our services. Recipients may include:
- Credit bureaus, credit reporting agencies, rating agencies, insurers, collection partners, and other financial service participants where permitted.
- Payment, banking, disbursement, repayment, identity verification, cloud hosting, analytics, customer support, and security service providers.
- Professional advisers, auditors, business partners, assignees, transferees, or parties involved in a lawful corporate or financing transaction.
- Regulators, courts, law-enforcement agencies, government authorities, and other parties when disclosure is required or permitted by law.
- Other third parties that you authorize or consent to.
We require service providers and processors to use personal information only for authorized purposes and to apply appropriate confidentiality and security safeguards.
5. Data protection and retention
We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, provide services, complete transactions, prevent fraud, resolve disputes, satisfy audit requirements, and comply with applicable laws and regulations.
Personal information may be stored on secure servers and systems used by FlowFund and its authorized service providers. Where information is no longer required, we will delete, anonymize, or securely archive it according to our retention standards and legal obligations.
6. Security
We apply administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. These safeguards may include encryption during transmission or storage where appropriate, access controls, staff authorization limits, activity monitoring, security reviews, vendor due diligence, and incident response procedures.
7. Your rights
Subject to applicable law, you may have rights to be informed, access your personal information, correct inaccurate or incomplete information, object to certain processing, request deletion or blocking where appropriate, restrict processing in specific circumstances, request data portability where applicable, and file complaints with the proper authority.
To exercise your rights, contact us using the details below. We may need to verify your identity before processing a request and will respond within the legally required timeframe.
8. Minors
FlowFund is intended for individuals who are at least 18 years old. We do not knowingly collect personal information from minors. If we learn that a minor has provided personal information without proper authorization, we will take appropriate steps to remove or restrict the information.
9. Policy updates
We may update this Privacy Policy from time to time to reflect changes in law, business operations, product features, security practices, or user rights. Updated versions will be posted on this page or in the app. If you do not agree with material changes, you may stop using FlowFund and request account deletion where applicable.
10. Inquiries and complaints
For privacy questions, data subject requests, objections, or complaints, contact Inclusive Nova Lending Inc. at privacy@FlowFund.ph. For general support, contact FlowFund.serviceofficial@gmail.com.
Useful reference links: Data Privacy Act of 2012, Implementing Rules and Regulations, and National Privacy Commission guidance on privacy notices.