Privacy Policy Statement

Updated: 31 May 2023

True Money Philippines Inc., including its affiliates and subsidiaries (the “Company”), values your privacy. Our privacy policy values and protects your personal information under the Data Privacy Act of 2012 and the laws of the Philippines. This privacy policy describes our personal information handling practices when you access our services, which include our content on the websites located at truemoney.com.ph, TrueMoney portals or when you use the TrueMoney mobile app and related services (referred to collectively hereinafter as “Services”).

ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.  We may provide additional “data consent” about the data collection and processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

LINKS TO WEBSITES OUTSIDE OF TrueMoney

To provide website visitors with more information that may be helpful to them, some of our websites contain links to other websites that are not affiliated with or maintained by TrueMoney. We do not monitor the privacy practices of these third-party sites, and do not have authority over them. As a result, you fully understand and acknowledge that we do not assume any responsibility for the data collection policies and procedures of these sites.

SPECIAL NOTICE – if you are a minor under the applicable law

Our website and services  are not aimed at children who are regarded minors per the applicable law, and we will not collect, use, provide or process in any other form any personal information of children under such age and in any case of any age younger than 18 years old, deliberately. We therefore also ask you, if you are still considered a minor and younger than the age of 18 , to please do not send us your personal information (for example, your name, address and email address). We will not bear any responsibility for such information provided to us.

If you are under the status of a minor per your applicable law and younger than the age of 18 and you nevertheless wish to ask a question or use this website in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf while specifying such clearly.

CHANGES TO THIS PRIVACY POLICY

True Money reserves the right to modify this Privacy Statement. Updated privacy statements will be posted on this Website when amendments occur. We urge you to review this Privacy Statement when you visit to obtain the most current statement.

I. THE PERSONAL INFORMATION WE COLLECT

Personal Information (PI) is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties such as name, date and place of birth, specimen signature, photo, present and permanent address, source of fund or income, name of employer or the nature or self-employment or business, contact details such as personal telephone number, personal mobile number and personal email address, mother’s maiden name, cookie information, user credentials (i.e. username and password, PIN/MPIN, etc.), contacts list, geolocation, and information about the device you use to interact with us.

We may also collect Sensitive Personal information (SPI) such as an individual’s race, age, marital status, government issued numbers peculiar to an individual which includes (e.g. SSS, GSIS, UMID, Drivers License, etc.)


II. HOW WE  COLLECT PERSONAL INFORMATION 

We collect your Personal Information when you:

• register and get verified to True Money through paper forms, web application forms,  and mobile application 
• use our True Money service through our partner agents and different channels 
• provide us with supporting documents to validate your identity;
• disclose your personal information through customer support, emails, SMS or verbal communication with our authorized representatives, calls may be recorded for coaching and quality purposes
• visit and contact us through our official websites and social media channels; and
• through your interest in TrueMoney advertisements placed on third party sites

III. PURPOSE OF PERSONAL INFORMATION COLLECTION

Our primary purpose in collecting personal information is to provide you with secure, smooth, efficient transaction needs and avail our services. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising.

Additionally we collect personal information for the purpose of the following: 

• Identifying, investigating and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to the submission of reports to the Anti-Money Laundering Council(AMLC);
• Enforcing and/or defending the rights of TrueMoney before any government  agency, court, tribunal, quasi-judicial body;
• Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service to which the data subject is a party;
• When necessary or desirable in the context of an employer-employee relationship between TrueMoney and the data subject; and
• Enabling TrueMoney to exercise governance over its businesses and ensuring that risks arising therefrom are duly identified, measured, managed and mitigated.

We may also collect personal data from other sources (e.g., your employers, credit bureaus, associations/organizations, etc.) as lawfully permitted.

For Partnerships and Corporate entities, you represent and warrant that you have (a) advised your data subjects of the purpose/s of collecting personal data and disclosure thereof to TrueMoney, their rights as data subjects and other relevant information, and (b) obtained the necessary consent and authority to disclose personal data of your directors, officers, employees, members and other representatives to TrueMoney, pursuant to the Data Privacy Act, its Implementing Rules and Regulations and other applicable laws and regulations.

IV. WITH WHOM WE MAY DISCLOSE AND SHARE YOUR PERSONAL DATA

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. TrueMoney will never sell or rent your personal information to third parties without your explicit consent. When there is a need for us to share your personal data to our third party affiliates and partners, we will ensure that personal data will be protected under the terms of Data Sharing Agreement and Contractual obligations.

We may disclose and share your personal data to the following:

• Any member of the TrueMoney Group, its directors, officers, employees, duly authorized representatives, related companies and affiliates;
• Third party service providers and vendors including credit card processors, data analytics, marketing services, customer support providers, and IT service providers who are bound by an obligation of confidentiality. They will have access to your personal data only as necessary to perform their requested function on your behalf, and if they have adequate security and privacy standards acceptable to TrueMoney;
• Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
• Professional advisers including accounting, tax, financial or legal counsel; or
• Anyone we consider necessary for purposes of providing you products and services and other purposes mentioned above.
  
  

V. PROTECTING YOUR PERSONAL DATA

The processing of your personal data exposes you to financial, legal, regulatory or reputational risks that may result from the unauthorized processing or disclosure of personal data. TrueMoney is committed to protecting the privacy of all personal data provided to us. We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. 

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files.

We limit access to those who have a business need to know. We are responsible for all personal data in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices.

VI. RETENTION PERIOD

We store your personal information, registration and transaction records for 5 years after closure of your account in adherence with the requirement of the BSP and other laws and regulations. These data will be destroyed in adherence with our physical and/or technical information security measures when retention is no longer required with respect to existing laws, rules or regulation.

VII. CROSS BORDER TRANSFERS

To facilitate our international operations, TrueMoney may transfer, store, and process your information within our family of companies, partners, and service providers based throughout Asia, including Singapore, Thailand and possibly other countries. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with TrueMoney, you acknowledge and agree to your personal information being processed in this way.

VIII. YOUR RIGHTS AS DATA SUBJECTS

As Data Subjects, you have the following rights:

• Right to be informed. You have the right to be informed whether your personal data is being, or has been processed, including the existence of automated decision-making and profiling, including any personal data breach which is likely to result in a risk for your rights and freedoms.
• Right to object. You have the right to object to the processing of your personal data, including processing for application,  direct marketing, automated processing or profiling. You may also opt NOT to receive marketing information from TrueMoney. Opting and objecting out means that TrueMoney will not proceed processing your personal data.
• Right to Access. You have the right to reasonable access, upon written request, to the contents of your personal data that were processed. You also have the reasonable right to know the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be used as the sole basis for any decision that may significantly affect you.
• Right to rectify erroneous data. You have the right to correct any error in the personal data and if warranted, request immediate rectification.
• Right to Erase or Block (right to be forgotten). You have, based on reasonable grounds and the public interest in the availability of the data, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from TrueMoney’s filing system, without prejudice to TrueMoney continuing to process personal data for commercial, operational, legal and regulatory purposes.
• Right to secure Data Portability. Where personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain from TrueMoney a copy of such data in an electronic or structured format that is commonly used and allows your further use.
• Right to be indemnified for damages. You shall be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as a data subject.
• Right to File a Complaint. You may file a complaint or exercise your rights above by reaching out to us through the contact details provided below. You may also raise privacy concerns to the applicable authority in your jurisdiction.

If you have questions about TrueMoney’s Privacy Statement and Policy, our data processing activities or your dealings with this web site, you can contact the Data Privacy Officer at [email protected], or call TrueMoney Customer Service (Hotline : 02-887-68440) or your account manager, as may be applicable. Our business hours are from 9:00 AM to 6:00 PM, Mondays to Sundays.