First Circle

Privacy Policy

Last updated on Feb. 11, 2020

This Privacy Policy sets out how First Circle Growth Finance Corp., its parent company, affiliates, and subsidiaries (collectively, “First Circle”, “we”, “us”, or “our”) and First Circle’s Related Parties work with you to ensure that your data is protected throughout all your transactions with us.

This document affects your rights, obligations, liabilities, and remedies as a Data Subject under Republic Act No. 10173, otherwise known as the Philippines Data Protection Act of 2012 (“DPA”).

First Circle reserves the right to update this Privacy Policy from time to time, with subsequent notice to Users on our Website, Platform, or through other means. Please carefully read the updates to know how the changes in this Privacy Policy may affect you.

Unless otherwise expressly provided, words with specific definitions in First Circle’s Website Terms of Use and First Circle Account Terms and Conditions shall have the same meanings here.

The words “your data” or “your information” as used here pertains to your personal, sensitive personal, and/or privileged information and documents (as such are defined in the DPA) in relation to your Account or a financing application with First Circle.


This Privacy Policy applies to all persons accessing this Website, users and owners of a First Circle Account, and parties inquiring for financing with us (“User” or “you”). If your relationship with us is governed by a specific and definitive legal agreement(s), that agreement should be read together with this Privacy Policy. Please revisit such other agreement for a more comprehensive understanding of your and our rights, obligations, liabilities, and remedies.

Other Data Subjects (for instance: First Circle job applicants or incumbent employees; Service Providers; and shareholders or investors) are not covered by this Privacy Policy.


This Privacy Policy applies to all information we or our Related Parties or Service Providers collect via:
1. Our Website,
2. Our Platform, and
3. Through offline and online communications with you (e.g. electronic mail, personal hand-delivery, delivery by courier service, messaging applications, survey and feedback forms, phone call, video chat or other means)

We collect the data:
1. Directly from you, your Trading Partner and/or Verifying Party.
2. Automatically through third-party applications as you use, navigate in, interact with our Website and Platform.
3. On an ad-hoc basis from our Service Providers.

Please exercise reasonable caution before providing information or documents to any person or entity claiming to be authorised by or associated with First Circle.

We will never ask for your Account username and password or for financial or personal information not related to your specific financing transaction with us. In case of doubt, please contact or check our application requirements page.


We use a variety of data types and sources to know our Users more. The information we (and our Service Providers) collect includes, but is not limited to:

1. Your full name
2. Your government-issued personal identification numbers
3. Your contact information (e.g. email, mobile phone number, landline number, residential and office address)
4. Any information that, if linked to other information about you, may personally identify you (e.g. your civil status, geographical location, photos, social media handles, professional qualifications or affiliations, etc.)
5. Your Company’s corporate registration documents (issued by the Securities and Exchange Commission, Department of Trade and Industry, Bureau of Internal Revenue, and the appropriate local government unit)
6. Your transaction documents and business history with your Trading Partner
7. Other information as we may need from time to time, which will be collected with your express consent in order to proceed with your financing application


The data we collect primarily helps us verify your identity and know more about your financing needs, so that we can offer the most suitable financing option to you.

1. Verify your personal identity and your authority to act on behalf of your Company, in compliance with know-your-customer (KYC) and anti-money laundering (AMLA) regulations
2. Review and decide on your financing application
3. Improve customer service and engagement
4. Refine our credit policy, operational processes, data analytics, and market research
5. Comply with our contractual obligations with third parties
6. Protect your Account
7. Secure additional funding from investors, lenders, shareholders, or buyers
8. Comply with mandatory regulatory disclosures and legal processes
9. Store your data in accordance with current data retention laws
10. Develop new products and services that may be of interest to you
11. Carry out our rights and obligations
12. Enforce our legal remedies
13. Any other purpose as advised to you, as allowed by law, as may be necessary under contractual agreements, or with your express consent


Your information may be shared across different entities comprising the First Circle group as may be required by the exigencies of business.

Whenever necessary, we also may need to share your information with our Service Providers, relevant government agencies, or potential and present investors, lenders, buyers or shareholders of the business of First Circle.

We reserve the right to use aggregated information from or about our Users, for any purpose and in perpetuity, as long as no individual is directly identified.


To enable us to serve you better, we may need you to execute a limited waiver of your rights (which may also be contained in your specific definitive agreement with us) under the following laws and their respective implementing rules and regulations:

- Republic Act No. 9510 or the Credit Information Systems Act
- Republic Act No. 1405 or the Bank Secrecy Law
- Republic Act No. 6426 or the Foreign Currency Deposit Act
- Republic Act No. 10173 or the Data Privacy Act

This waiver will terminate immediately upon the conclusion of our business relationship with you, unless otherwise provided by law or unless you have any outstanding obligation to First Circle.


You shall indemnify, defend, and hold First Circle and its Related Parties free and harmless against any and all liability, proceeding, inquiry, loss, risk, cost, tax, charge, penalty or damages in connection with your disclosure of information to First Circle, its Representatives, Service Providers, government agencies, and any other party, or in connection with First Circle’s lawful processing of your information.


We implement reasonable and appropriate organizational, technical, and physical measures to protect your data. Any disclosure we make shall be done so on a strictly need-to-know basis only.

We can provide you confirmation on whether and what information about you we process, upon your written request. Please note that data review and reproduction may have associated costs that will be for your sole account.

For queries or concerns on data privacy, please send us an email at
“First Circle is something that will really make a big difference to help SMEs in the Philippines.”
Ramon Lopez
Secretary, Department of Trade and Industry (DTI)