This Privacy Policy describes the information that we gather from you, how we use your information, whom we share your information with, and the steps we take to protect your information. By using the Services, you consent to the privacy practices described in this Policy.

Toploans24 is a trading name of Fininity Ltd., which is registered in Estonia (Company no. 14523902), Registered Office; Tartu mnt 52-166, 10115 Tallinn, Estonia.

We at Toploans24 are aware of how important your privacy is. In order to keep your information confidential, we have implemented measures to ensure that any personal information we obtain from you is processed and maintained in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, other relevant laws and issuances by the National Privacy Commission, any other legislation protecting the fundamental rights and freedoms of individuals, and good data handling practices. In this statement, we detail the type of information that we and Toploans24 may retain about you, our customer. It will also include details about how we obtain, process, and protect any information we may have.

This privacy policy applies only to us and all personal information we may collect and obtain by us. We reserve the right to occasionally amend the content of this privacy policy. If we do so, we will post the revised policy on this website.

We, along with our panel of lenders and credit brokers, will regularly keep you informed about your loan application process. Unless you explicitly state otherwise, we may contact you via telephone, SMS, post, email, and/or automated message.

Our use of your personal data will always have a lawful basis. We will rely upon various lawful bases to process your personal data.

Once you have submitted your loan application on Toploans24, you provide your consent to be contacted by Fininity Ltd along with our panel of Loan Providers, or Credit Brokers in relation to your online loan application. We process your personal data on that basis.

If you wish to withdraw your consent of the processing of your personal data for marketing purposes, you can do so at any time. Simply click the “Unsubscribe” option in any marketing SMS or email we or any associated third party send to you. You can also withdraw your consent by emailing our Data Protection Officer at compliance@toploans24.com. Withdrawing your previous consent to our processing your personal data will not have any effect on the lawfulness of the processing we carried out before your consent was withdrawn.

When you submit your personal data through a loan application, we will process your data in order to fulfill our obligation to provide a loan quote to you. Fininity Ltd and our panel of loan providers and/or credit brokers will contact you with information regarding your loan application quote.

We maintain a legitimate interest in processing your data, which is to share your application with our panel of loan providers and/or credit brokers in order to obtain the loan quote you applied for.

We will contact the customer by telephone, SMS, post, email and/or automated message in order to provide information, loan application alerts, and notices from our associate companies unless otherwise requested by the customer. Third parties may also give us personal information/date, enabling us to offer products to identified potential customers who have expressed interest. We check any information/data obtained by third parties for accuracy. We will also endeavor to confirm your information with you from time to time.

If you choose to allow it, we may send push notifications to your mobile device or web browser. These push notifications may include marketing messages from us or from third-parties. You can change your push notification settings at any time in your browser’s or mobile device’s notification settings.

You are responsible for ensuring that any personal information/data we retain from you is correct and up-to-date. Contact us as soon as possible if you need to update or correct your information.

1. You are free to access and browse through our Website, Toploans24 at your convenience. You are not obligated to provide any personal information/data. (Please review our Cookies Policy for more information.)
2. In order to secure a loan offer for you, we would normally collect the following information from you:
   • Name
   • Address
   • Residential status
   • Birthdate
   • Email address
   • Phone number
   • Income
   • Bank account details
   • IP Address
   • Website activity; the results of which will be used to inform Toploans24 of which aspects of the Website are most frequently and infrequently used. (Please review our Cookies Policy for more information.)

If you ask us a question about our services or choose to send an email to compliance@toploans24.com, we may also collect some of the above personal information from you in order to best respond to your inquiry.

What Information We Collect

When you apply for a loan product online, we collect personal information from you to obtain quotes for the loan. As we provide the services to you, we may also store information about how you use our Website. We may store information about the pages viewed, the website which referred you to our Website, changes you’ve made to personal information provided to us, details of the quotes you request, and the contents of your applications, together with details of your financial information, including bank account or employer details.

We must collect personal information from you in order to provide you with a suitable loan quote. When you request a loan quote, you give your explicit consent to that information being processed by us along with third-party providers, such as Loan Providers and Credit Brokers.

We store the information you provide. We may use that information to pre-populate fields on the Website and make it easier for you to use the Website on future visits.

We will not keep your information for longer than is permitted by law. We will periodically review your information to ensure that.

Keeping your information secure is of utmost importance to us. While no internet data transmission can be perfectly secure, we do our best to protect the information you disclose to us. However, we cannot and will not guarantee or warrant the security of any data you provide to us. You do so at your own risk. By using our Website, you accept the inherent and inevitable risks of providing personal data online. You agree that you will not hold us responsible for any security breach.

We may use your personal information:

1. to allow you to access and use our Services;
2. to improve and customize aspects of our Services;
3. for market research
4. to contact you, including any or all of the following:
   1. sending you information about additional services and products which we think may be of interest to you. This may include new product launches, alternative financial solutions, newsletters, and opportunities to participate in market research;
   2. sending you loan quotes. We may also share the information you provide with our partners (such as our panel of lenders and credit brokers) so that they can calculate personal quotes for you. When they do this, our partners may carry out soft credit checks on you;
   3. sending you a confirmation email of your quote. When you submit a loan application, we will automatically send over the confirmation of the receipt of your application by email or SMS for your records.;
5. to process an application between you and a third party;
6. to track sales. This may involve the sharing of your data with your product provider relating to the product(s) you have purchased;
7. to match our data with data from other sources. We may validate, analyze, and match your information against data that has been collected by a third party in order to ensure that all information we hold about you is consistent, accurate, and well-organized as possible.
8. to send out a customer feedback survey, which we make available to all customers they have completed an application;
9. to pass your data to third parties for marketing purposes;

By using our Website, you agree that we and (with your consent) other third parties we trust will be permitted to contact you via email, SMS, telephone, post, and/or automated message or by other electronic means in relation to services, products and other promotions that may be of interest to you.

At any time when you provide us with personal data/information, when necessary we will seek your consent and/or we will give you an opportunity to tell us you do not consent to the sharing of your information for marketing purposes and other uses. Unless you indicate otherwise, you consent to such use.

Sharing Your Personal Information 

By filling out and submitting a loan application, you hereby consent to the disclosure of your personal information to the following parties:

1. Toploans24 and Fininity Ltd: (i) to contact you, including sending you information about services and products which may interest you; (ii) to quicken form filling, or to customize, or improve your user experience on its website or mobile applications; or (iii) in accordance with its Privacy Policy.
2. Lenders and Credit Brokers.

Where permitted by privacy and data protection law, we may also be compelled to access your account and/or disclose information about you (including electronic identifiers such as IP addresses):

1. if permitted or required to do so by law;
2. if required to do so by any court, or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary in conjunction with legal proceedings or impending legal proceedings; and/or
4. in conjunction with the sale or potential sale of all or a portion of our business.

Some of the providers on our panel may use your personal information in order to assess your situation, (including information about third parties named on your application) and verify the accuracy of any information you provide before giving you a quote. Some providers may perform checks with fraud prevention and credit reference agencies. They may check both your private and public data this way. Some providers may carry out checks against data they already retain on you, such as data from existing financial products, account information, or information from previous transactions in order to decide your loan amount. If providers carry out these searches, your credit report will include a record of the search. Some providers may check education sources to gather information about your previous education as well.

This allows providers to verify any information you provide during the quote process. It also aids in detecting fraudulent loans. These routine checks are common in obtaining loan quotes from other sources as well.

Should you choose to enter into a loan, the data you have given to us, in addition to further information given to the third-party provider, will be held by the provider in accordance with the provider’s privacy policy. We strongly advise that you read your chosen provider’s privacy policy before entering into the loan. We accept no responsibility for how a provider uses your personal information.

You have a number of rights under the DPA including:

Right to be informed − Toploans24 provides all customers with this privacy statement to provide transparent and clear information as to arrangements for the collection, control and processing of personal data.

Right of Access − Copies of personal data held can be requested under an access request and will be met in the 30 day legislative standard ordinarily free of charge. Any extension to these requirements will be advised on the basis of the nature of the request but will be by exception and subject to senior management scrutiny, please see contact us section for further detail.

Right to Rectification − In the event we hold inaccurate data please advise us of the correct information and records will be updated within 72 hours and confirmation provided accordingly (Subject to satisfactory verification of your identity).

Right to Restriction of Processing − Data processing will be restricted whilst any claim of accuracy is being contested by you, or you have challenged the legal basis or legitimate grounds for processing for a specific purpose and to establish, exercise or defend legal claim at your request.

Right to Object − You can object to Toploans24 processing on the basis this is contrary to your rights and freedoms, any objection relating to direct marketing will be acted upon within 48 hours, other objections will be treated as a complaint and assessed against our documented legal basis.

Right to Erasure − Commonly known as the right to be forgotten, Toploans24 will adhere to your request ordinarily within 72 hours where legal basis is solely or partially established as consent, any data required for legal, regulatory or legitimate interests maybe maintained in accordance with documented retention schedules. However our team will confirm and discuss your request to ensure your rights and freedoms are observed at all times.

Right to Data Portability − You have the right to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in a timely manner, generally 72 hours unless evidenced to be unduly excessive or unreasonable.

Rights in relation to Automated Decision Making and Profiling – You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it.

Toploans24 has established robust policy and procedural requirements to enable your rights as a data subject to be adhered with, however where this is not possible for the reasons outlined we confirm the detail.

In relation to all of these rights, please write to or contact us at the address below. Please note that we will need to verify your identity.

Depending on why you provided us your personal data, the amount of time we retain it for will vary:

• Should you choose to opt-out of marketing communications, we will retain your information in order to remember your preferences
• Any information relating to applications you submit on our website will be retained for a minimum period of 6 years (commencing once our relationship has terminated). We keep information for this amount of time in order to assist with potential future complaints.

You are free to opt-out of future contact from Toploans24 whenever you wish. All of our marketing messages include an opt-out or unsubscribe link. Please allow up to 48 hours for us to process your request.

If you wish to assert your right to be forgotten and request the removal or deletion of your personal information, please visit https://unsub.toploans24.com/gdpr?country=PH or email compliance@toploans24.com. We will also ensure that our marketing partners are informed of your request.

Toploans24 reserves the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Services. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms. Immaterial modifications are effective upon posting of the updated Privacy Policy or Terms of Service on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

We strive to ensure that our service to you is always satisfactory. However, should you wish to submit a formal complaint, please email complaints@toploans24.com.