Statement of Policy
We are committed to protecting and respecting your privacy rights under applicable data protection laws, rules, and regulations. This Privacy Policy sets out how First Circle Growth Finance Corp., its parent company, affiliates, and subsidiaries (collectively, as the context may require, “First Circle”, “we”, “us”, “our”) along with their respective shareholders, directors, officers, employees, agents, representatives, consultants, and advisors (collectively, “Related Parties”) work with you to ensure that your data is protected throughout all your transactions with us.
WHO WE COLLECT DATA FROM
This Privacy Policy applies to all persons accessing our website, users and owners of First Circle accounts, products and services, and parties inquiring for financing with us (as the context may require, “user”, “you”, “your”). If your relationship with us is governed by a specific and definitive legal agreement, that agreement should be read together with this Privacy Policy. Please revisit such other definitive agreements for a more comprehensive understanding of your rights, obligations, liabilities, and remedies.
HOW WE COLLECT DATA
In some instances, someone else may provide us with personal information about you, with or without your direct involvement. For instance, we might collect your personal information from your representative, contractor or supplier, business partner, an organization of which you are a member, or other publicly available sources of information.
This Privacy Policy applies to all personal information we or our Related Parties or service providers collect from you whenever you interact or communicate with us, such as when you send us correspondence by e-mail or in writing, deal with us over the telephone or in person, contact us, request us for information on our products and services, provide feedback, or register or provide your information directly through our website or platform.
Given the various channels by which we may collect your personal information, we request that you please exercise reasonable caution before providing information or documents to any person or entity claiming to be authorized 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 us at the details found at
https://www.firstcircle.ph/contact-us, or for financing transactions, please check our
application requirements page.
WHAT DATA WE COLLECT
We use a variety of data types and sources reasonably necessary to provide you with our products and services. The types of personal information we may collect will depend on the nature of your interaction with us and where and how we collect the information, but may include (but are not limited to):
• Your name;
• Your government-issued personal identification numbers;
• Your contact information (e.g. email, mobile phone number, landline number, residential and office address);
• 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.);
• Your transaction documents and business history with your business partners; and
• Other information as we may need from time to time
Please note that if some information we request is not provided, we may not be able to meet its legal obligations or may not be able to provide you with certain products or services. In such cases, we will inform you.
HOW WE USE DATA
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. The purposes for which we use personal information include (but are not limited to):
• Verifying your personal identity and any authority which you may have to act on behalf of your company;
• Complying with applicable laws and regulations, including anti-money laundering regulations;
• Reviewing and deciding on your financing application;
• Improving customer service and engagement or provide ongoing support;
• Billing, collecting, or making payments;
• Refining our credit policy, operational processes, data analytics, and market research;
• Complying with our contractual obligations with third parties;
• Protecting your account/s with us; and
• Developing and marketing new products and services that may be of interest to you
If we collect your personal information to be used for any other purpose, we will let you know that purpose at the time we collect the information.
WHO HAS ACCESS TO DATA WE COLLECT
Your information may be shared across different entities comprising the First Circle group as may be required to fulfill the purposes for which the information was collected or for a related purpose. 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 First Circle, or anyone to whom we are required by law to disclose personal information.
CONSENTS
To the extent required by applicable laws or regulations, we or any service provider engaged by us will aim to obtain your consent to collect and use your personal information at the time of collection. We adopt an “opt-in” policy to obtain your express written consent when collecting your personal information. Thus, you may be asked, for instance, to sign a form or tick a box on a website page or window. In order instances, we may rely on other legal bases for collecting or processing your information, such as our legitimate interests.
To enable us to serve you better, we may also need you to execute a limited waiver of your rights (which may also be contained in your specific definitive agreement with us) under certain laws and their respective implementing rules and regulations. Such 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.
DATA RETENTION
We are required by law to keep some types of information for a certain period of time. If there is no longer any need to retain your personal information, we will destroy or de-identify or anonymize the information. We will only retain your data for as long as necessary to fulfill the purposes for which they have been collected or for as long as may be required or allowed by applicable laws and regulations.
HOW WE PROTECT YOUR DATA
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 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.
OTHER WEBSITES
To the extent that our websites may contain links to sites operated by third parties or organizations, those linked websites are not controlled by us and we are not responsible for the data privacy practices or activities of the site operators. Before disclosing your personal information on any linked website or mobile app, we recommend that you examine the data privacy policies, notices, and terms and conditions of use of the website or mobile app.
CONTACT US
In accordance with applicable laws and regulations, you may request access to, or correct your personal information held by us, or inquire about our data protection policies and practices. For queries or concerns on data privacy, please contact our Data Protection Officer at:
dataprotection@firstcircle.com or at +639670226538.
First Circle reserves the right to update this Privacy Policy from time to time. Please carefully read the updates to know how the changes in this Privacy Policy may affect you.
