PRIVACY NOTICE

Last Updated: 30 March 2025

This Privacy Notice explains how We collect, process, and use the personal data of users (hereinafter referred to as the “Consumer,” “You,” or “Your”) when interacting with the website https://binixo.ph/(hereinafter referred to as the “Site” or “Platform”). We are committed to ensuring the secure and lawful processing of Your data in accordance with applicable regulations.

Before accessing or using Our Platform, please read this Privacy Notice (hereinafter referred to as the “Notice”), which explains what We do with the personal information You provide to Us.

This document has been developed in accordance with the legal and regulatory framework of the Philippines, including the Data Privacy Act of 2012 (DPA), the guidelines of the National Privacy Commission (NPC), and internationally recognized data protection standards as applicable under national law.

1. GENERAL INFORMATION

Your use of the Platform signifies Your agreement with this Notice and with the terms governing the processing of personal data. We recommend that You read it carefully to understand Our principles and practices regarding the handling of Your personal data.

This Notice outlines how We interact with You in relation to the collection of personal information through this Platform. Your access to the Platform and all communications between You and Us are subject to this Notice.

You may browse the Site without disclosing any personal data. However, the full functionality of the Platform requires the provision of personal information. By providing Your personal data, You expressly consent to its collection, use, disclosure, and retention in accordance with this Notice and the DPA.

If You do not agree with the terms of this Privacy Notice, please discontinue the use of the Platform.

This Notice applies solely to the Site and does not govern third-party websites that the Consumer may access via links available on the Platform.

The Company does not verify the accuracy of the personal data provided by the Consumer.

2. DATA CONTROLLER INFORMATION

Infinsacom kft (hereinafter referred to as the “Company,” “We,” or “Us”) is a legal entity registered under the laws of Hungary, with company registration number 14523902 and registered office located at Fehérvári út 126-128, 1116 Budapest, Hungary.

3. PURPOSE OF PERSONAL DATA PROCESSING

The Platform provides a technical solution for comparing loan offers from financial institutions and microfinance organizations, as well as for establishing contact with them. By entering their data, the Consumer gives consent to its transfer to such institutions and organizations for the purpose of evaluating eligibility and assessing the possibility of providing financial services.

The processing of personal data allows the Platform to offer Consumers access to relevant and up-to-date offers that align with their individual requests. This helps optimize the process of searching for financial solutions and enables the delivery of personalized information about financial services that may be provided by financial institutions and microfinance organizations.

We follow the principle of data minimization and process only the information necessary to achieve the purposes stated in this Notice. All data processing is carried out on a lawful basis and in compliance with the Data Privacy Act and the guidelines of the National Privacy Commission (NPC).

Provision of Services on the Platform

The Platform provides a technical solution for searching loan offers from financial institutions and microfinance organizations by automating the selection process based on the data entered. Once the Consumer provides their information, it is transmitted to these institutions and organizations for review and assessment in accordance with their lending criteria.

The subsequent processing of data is carried out by these institutions and organizations in accordance with their own privacy policies and internal data processing procedures. Each financial institution and microfinance organization acts as an independent Personal Information Controller under the DPA and bears responsibility for ensuring compliance with applicable data protection requirements.

All transmitted data is protected using up-to-date technical measures to prevent unauthorized access, and processing is strictly limited to lawful and declared purposes.

Analytics and Platform Improvement

We strive to make the use of the Platform more convenient and efficient, which is why We analyze how Consumers interact with the service. This allows Us to adapt features, improve performance, resolve technical issues, and enhance overall functionality.

The data collected helps Us understand which features are most useful, what needs improvement, and how to optimize navigation and processes across the Platform. Technologies may be used to analyze site visits, behavioral trends, and technical errors.

The Company follows the principle of data minimization: all information used for statistical analysis is processed in an anonymized format and does not include any data that could directly identify the Consumer. Consumers may also manage their privacy preferences by limiting the use of analytical data through their browser settings.

Marketing and Promotional Campaigns

The Company may use the Consumer's contact details to provide information about new service features, special offers, promotions, updates from financial institutions and microfinance organizations, as well as enhancements to the Platform's functionality.

Marketing communications may be delivered in the form of:

emails containing personalized offers and service updates;
push notifications on the Consumer's device, if the appropriate permission has been granted in the browser;
targeted advertisements through third-party platforms such as Google Ads or Facebook Ads, which may be tailored based on the Consumer's preferences and activity on the Platform.

The Company provides Consumers with the ability to control the receipt of marketing communications. You may unsubscribe from promotional emails by clicking the unsubscribe link included in the message.

The Company does not share personal data with advertising platforms without a valid legal basis and always operates in compliance with applicable laws, including the Data Privacy Act.

Compliance with Legal Obligations

The Platform processes personal data in accordance with the applicable laws of the Republic of the Philippines, including the Data Privacy Act, as well as the legal requirements of other jurisdictions in which We operate. This means that personal data may be processed for the following purposes:

to fulfill financial, accounting, and tax obligations, particularly those established by tax and financial regulatory authorities;
to provide information to competent government authorities in response to official requests that are legally valid (e.g., in the context of investigations or court orders);
to protect the legitimate rights and interests of the Company in the event of legal disputes, administrative proceedings, or other legal matters related to the operation of the Platform.

The transfer of personal data to government bodies or third parties shall only take place when required under the DPA and based on a valid legal ground. The Company ensures that any request for disclosure is carefully reviewed for compliance with the legal requirements of the Philippines.

Data Protection and Compliance with International Standards

The Company implements measures to ensure the security of personal data, including activity monitoring, the use of encryption technologies, and safeguards against unauthorized access. All data processed is stored in accordance with the standards of the Data Privacy Act and is accessible only to authorized personnel responsible for the operation of the Platform.

4. LEGAL BASES FOR PROCESSING PERSONAL DATA

The processing of personal data is always carried out in accordance with the principles of transparency, lawfulness, and proportionality, as defined in Section 11 of the Data Privacy Act.

Consent. We may process Your personal data when You have provided clear, voluntary, and informed consent for a specific purpose. Under the DPA, consent must be provided in writing, electronically, or recorded through other means. You have the right to withdraw Your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before such withdrawal.
Contractual Necessity. We may process Your personal data when it is necessary for the performance of our contractual obligations to You, including the provision of our Services, or in order to take steps at Your request prior to entering into a contract.
Legal Obligations. We may process Your personal data when it is necessary for compliance with our legal obligations, including but not limited to:
- providing information to government authorities pursuant to lawful requests;
- fulfilling tax and financial reporting obligations;
- cooperating with law enforcement agencies in accordance with applicable laws;
- providing evidence in judicial or administrative proceedings.
Vital Interests / Legitimate Interests. We may process personal data when it is necessary to protect vital interests or to pursue our legitimate interests or the legitimate interests of a third party, provided that such interests do not override the rights and freedoms of the Consumer. This may include:
- preventing fraud and abuse;
- ensuring the security of the Platform;
- conducting internal analytics and improving our Services.

5. PERSONAL DATA WE COLLECT

This section provides information about the personal data that We may collect from Consumers when they use our Services, as well as personal data that We may obtain from other sources.

The table below outlines the categories of personal data that We collect, use, store, transfer, or otherwise process:

Data Category	Examples of Collected Data	Data Sources
Identifiers	First name, last name, date of birth, age, passport details, tax identification number (TIN), gender, IP address, and other information You provide to Us.	Directly from You or through Your use of the Platform; cookies and other tracking technologies; third parties.
Contact Information	Physical address, email address, phone number, additional contact number, messaging app contacts (Viber, WhatsApp, Signal, Telegram), and any other contact information You provide to Us.	Directly from You or through Your use of the Platform; third parties.
Internet or Other Network Activity / Device Information	Unique device and app identifiers, browsing history or other usage data, browser and operating system used, URL or advertisement that referred You to the Platform, search terms entered into a search engine that led You to the Platform, sections of the Platform You visited, links You clicked, pages or content viewed and time spent, as well as similar information and interaction statistics such as content response times, loading errors, and time spent on specific pages.	Directly from You or through Your use of the Platform; cookies and other tracking technologies.
Approximate Geolocation Information	Your approximate location.	Directly from You or through Your use of the Platform; cookies and other tracking technologies.
Financial Data	Bank account information and other data You provide to Us. This data is not classified as sensitive under the DPA but is processed with enhanced security measures.	Directly from You; third parties.
Usage Data	Information about how You use Our Platform, products, and Services.	Cookies and other tracking technologies.
Marketing and Communication Data	Your preferences regarding receiving marketing communications from Us and third parties, as well as Your communication preferences.	Directly from You or through Your use of the Platform; cookies and other tracking technologies; third parties.

The Consumer may choose not to provide this information; however, this may prevent access to or the use of certain features of the Platform.

You must only submit Your own personal data. It is prohibited to provide information about another individual without their explicit consent. If You do submit data about another person, You must have confirmation that the individual has agreed to the disclosure and processing of their data in accordance with this Notice.

Any information We receive from third parties will be treated in accordance with this Notice. We are not responsible for the accuracy of data provided to Us by third parties, nor are We responsible for the policies or practices of any third party.

We may also process anonymized or aggregated data that does not identify the Consumer, for statistical and analytical purposes. Such data is not considered personal data under the DPA.

6. PROCESSING OF PERSONAL DATA OF MINORS

The Company does not intentionally collect, store, or process personal data of individuals under the age of 18 without a valid legal basis or the consent of their legal representatives.

The Company is not under a legal obligation and does not have the technical means to verify the age of all Consumers. If a minor voluntarily provides personal data without the required consent, the responsibility for the accuracy of such information lies with the individual who submitted it. However, if it becomes known that the personal data of a minor is being processed without the appropriate legal basis, the Company reserves the right to:

take steps to cease the processing of such data;
contact the user to request age verification;
request consent from a parent or legal guardian.

Parents or legal guardians of minors have the right to contact the Company with a request to delete the personal data of the minor Consumer. Such a request will be reviewed in accordance with the applicable laws of the Philippines, particularly the Data Privacy Act, and may be fulfilled provided that there are no conflicting legal obligations requiring the retention of such data.

As of the effective date of this Notice, the Company has no reasonable grounds to believe that it discloses, transfers, or sells personal data of individuals under the age of 18 without a valid legal basis.

Any requests regarding the deletion or restriction of processing of minors' personal data will be reviewed in accordance with the requirements of the National Privacy Commission (NPC) and other applicable data protection regulations in the Philippines.

7. RETENTION PERIOD OF PERSONAL DATA

The Company stores and processes Consumers' personal data for the duration necessary to fulfill contractual obligations, ensure the functionality of the Platform, and comply with applicable legal requirements.

Personal data is retained no longer than is necessary for the purposes for which it was collected, unless its continued retention is required for the fulfillment of legal obligations, resolution of potential disputes, or protection of the Company's legitimate interests.

General Retention Periods for Personal Data

Consumers' personal data is retained for the following periods:

Consumer account data (name, contact details, profile information)- stored throughout the use of the Platform and for up to 12 months following the Consumer's last activity or the end of the interaction, to enable continued service and fulfill legal obligations.
Financial data retained until transferred to financial institutions. In certain cases required by law, some data may be stored for longer periods as mandated by regulations.
Customer support communication data ー retained for up to 24 months from the last interaction to ensure service quality.
Analytical and statistical data may be retained in anonymized form for up to 5 years.
Marketing data stored until the Consumer withdraws consent, but not longer than 24 months from the last activity on the Platform.

Deletion or Anonymization of Personal Data

The Consumer has the right to withdraw consent for the processing of their personal data at any time or request its deletion. In such cases:

Personal data will be deleted or anonymized within 30 days of receiving the relevant request. If necessary, this period may be extended to 90 days.
Financial data required to be retained under applicable law will be stored for the legally mandated period.
Upon the expiration of the applicable retention periods, personal data will be permanently deleted or anonymized, unless further processing is required for the Company's legitimate interests

To submit a request for data deletion or to obtain more information regarding data retention periods, the Consumer may contact the Company using the contact details provided in Section 12 of this Notice.

Exceptions to the General Rules on Personal Data Retention

The Company reserves the right to extend the retention period of personal data in the following cases:

Legal disputes, judicial proceedings, or regulatory audits - until the final resolution of the respective matter.
Compliance with legal and regulatory requirements that oblige the Company to retain specific categories of personal data for a defined period.
The necessity to protect the Company's legitimate rights and interests in accordance with applicable law.

8. CONSUMER RIGHTS REGARDING PERSONAL DATA

All Consumers of the Platform have the following rights:

the right to be informed about what personal data We collect, for what purposes, and on what legal grounds;
the right of access to their personal data and the right to request a copy of such data;
the right to rectification of their personal data;
the right to erasure of their personal data, provided there are no outstanding obligations and no legal requirement for continued retention;
the right to restrict or block the processing of their personal data if the Consumer objects to such processing, contests the accuracy of the data, considers the processing to be unlawful, or if the data is required for the establishment, exercise, or defense of legal claims;
the right to data portability, meaning the right to obtain the personal data the Consumer has provided to Us (in a structured, commonly used, and machine-readable format), and to reuse it elsewhere or request that We transfer it to a third party of their choice;
the right to withdraw consent to processing at any time;
the right to object to the processing of their personal data, and We will cease such processing unless We demonstrate compelling legitimate grounds to continue;
the right to lodge a complaint with Us regarding any processing of personal data, or to contact the National Privacy Commission (NPC) or another competent authority if the Consumer believes that their rights have been violated;
any other rights granted under applicable law.

Please note that some of these rights may be limited if the Company is legally obligated to continue processing data or if legal restrictions under the Data Privacy Act apply.

9. DISCLOSURE OF CONSUMER PERSONAL DATA TO THIRD PARTIES

The Company may disclose Consumers' personal data to third parties only on lawful grounds, as prescribed by applicable Philippine laws, including the Data Privacy Act, particularly when necessary to fulfill contractual obligations, comply with legal requirements, or protect the Company's legitimate interests. Data is transferred only to the extent necessary and in full compliance with confidentiality and security requirements.

Data may be disclosed to partners, as well as financial institutions and microfinance organizations, for the purpose of reviewing submitted applications. Data may also be shared with technical service providers who support the operation of the Platform, or with competent government authorities if required by applicable law or court order.

All third parties with access to personal data are obligated to ensure its protection in accordance with the DPA and other applicable regulations. The data may only be used for the specified purposes and may not be transferred or used for other purposes without a valid legal basis or the Consumer's consent.

Access to personal data may be granted to individuals whose involvement is necessary for support, quality assurance, operation, or improvement of the Platform and our Services. This includes:

Our employees. Our employees process Your personal data to deliver services, provide customer support, offer technical assistance, support marketing efforts, and for other operational purposes. All employees are required to comply with appropriate personal data protection measures. Your data is used strictly within the scope of their responsibilities and with full respect for confidentiality and privacy.
Affiliates. We may share information about You with our current or future subsidiaries or affiliated companies, which may use it in accordance with this Notice.
Service providers, partners, and financial institutions. We may transfer information about You to our partners, contractors, technical service providers, and financial institutions, including microfinance organizations, strictly as required to fulfill the purposes outlined in this Notice.
Government authorities. We will share information with public authorities in accordance with the law, including (but not limited to) responding to lawful requests for national security, law enforcement, or income reporting. We cooperate with regulatory and law enforcement bodies to ensure legal compliance.

By visiting the Site and providing Your personal data, You consent to its processing by the third parties listed above, unless separate consent is explicitly required by law.

All individuals and entities with access to Consumer personal data are required to comply with applicable data protection and confidentiality laws.

With Your consent, the Platform may interact with other third-party websites or services operated independently. We do not control the operations of such third-party websites or services, and this Privacy Notice does not apply to them unless explicitly stated otherwise.

We recommend that Consumers carefully review the privacy and data processing policies of each third-party website or service before submitting any personal data or other information that may be used to identify them.

10. PROTECTION OF PERSONAL DATA

We use generally accepted standards of technological and operational security, including a combination of administrative, technical, personnel, and physical safeguards, to protect the information and personal data We receive from loss, misuse, unauthorized disclosure, alteration, or destruction.

However, no method of transmission or storage is completely secure, and absolute protection against threats beyond our control cannot be guaranteed. If You have reason to believe that Your interaction with Us is no longer secure, please notify our customer support team immediately by following the instructions provided below.

We recommend that Consumers do not use unsecured channels to transmit confidential information to Us.

Security Breach Notification

In the event of unauthorized access to or leakage of personal data that may result in harm to Consumers, We will:

notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, if the incident meets the criteria set by the NPC;
notify affected Consumers, where necessary, using the available contact information;
take appropriate measures to remediate the breach and mitigate any potential negative impact.

11. CONTACT US

If You have any comments or questions about our Platform, or if You have any inquiries, feedback, or complaints regarding this Privacy Notice, You may contact Us by sending an email to: [email protected]

We strive to respond to user inquiries without undue delay and no later than 30 calendar days from the date of receipt. If the request is complex or if We receive a high volume of simultaneous inquiries, this period may be extended to 90 days, in which case the Consumer will be notified along with the reason for the delay.

When You submit an email inquiry, We may request additional information necessary to verify Your identity.