Privacy Policy

Finlo (“Finlo,” “we,” “our,” or “us”) respects the privacy and security of its users. This Privacy Policy describes how information is handled, used, retained, and protected when you use the Finlo mobile application and its related services in the Philippines.

Finlo provides financial scoring, financial activity analysis, and EMI calculation features. Please review this Policy before using the application. By using Finlo, you acknowledge the information practices described below.

This Policy applies to the Finlo mobile application and the related features and services provided through it. We process information only where it is reasonably necessary to operate the application, protect users and the platform, maintain service functionality, and comply with applicable requirements.

2.1 Information You Provide

When you create an account, complete your profile, or use the financial scoring feature, we may process information that you choose to provide, including:

• Full name
• Contact information, such as a mobile number or email address
• Government-issued identification information, where applicable
• Other details entered to complete your profile or financial assessment

This information is used to manage your account, verify submitted details, generate financial scoring reference results, and provide related app services.

2.2 EMI Calculation Information

When you use the EMI calculator, Finlo processes calculation details that you enter, such as:

• Amount
• Interest rate
• Repayment period

These details are used to calculate estimated monthly installments, total repayment amounts, and related reference results.

2.3 Device and Technical Information

To protect accounts, identify abnormal activity, and maintain reliable app performance, we may process limited technical information, including:

• Device brand, model, and manufacturer
• Operating system and version
• Finlo application version
• Device identifiers used for security and misuse prevention
• Technical information relating to app operation, error diagnosis, and security status

This information is used for security verification, abnormal activity detection, fraud and misuse prevention, troubleshooting, and service stability.

2.4 Financial SMS Information

Finlo accesses SMS messages related to financial transactions only after you actively grant SMS permission. This access supports financial activity analysis and the financial scoring feature.

Relevant financial messages may include:

• Income or credit notifications
• Expense or debit notifications
• Payment and transaction alerts
• Notifications relating to changes in account funds

Finlo identifies relevant messages based on commonly used financial transaction indicators and extracts structured information required for analysis, such as transaction amount, transaction time, income or expense category, and transaction count.

• Finlo does not read private messages unrelated to financial analysis
• Finlo does not continuously monitor all SMS activity
• Full SMS message content is not stored or retained by Finlo
• Only summary indicators are generated locally
• Summary indicators support general financial analysis and scoring reference results

SMS permission is optional. You may decline the permission or withdraw it at any time through your device settings. Certain financial SMS analysis and scoring functions may then be unavailable, while features that do not depend on SMS access, including the EMI calculator, will remain available.

2.5 Approximate Location Information

With your permission, Finlo may process approximate location information at the city, region, or similar level for the following purposes:

• Confirming whether relevant services are available in your area of the Philippines
• Supporting regional availability checks
• Meeting applicable regional compliance and security requirements
• Identifying clearly abnormal cross-region usage patterns

Finlo does not collect precise GPS coordinates, continuously track your location, or create a continuous history of your movements.

Depending on the features you use and the permissions you grant, information may be used to:

• Create, manage, and protect your account
• Provide financial scoring and general financial activity analysis
• Perform EMI calculations and display calculation results
• Verify information submitted by users
• Detect abnormal behavior, prevent fraud, and reduce service misuse
• Maintain app functionality, security, and reliability
• Improve product features and user experience
• Respond to user inquiries, account requests, and technical issues
• Comply with applicable laws, regulations, and lawful requirements in the Philippines

Except for full financial SMS content that is processed only on the device, information that must be transmitted is sent through encrypted connections, such as HTTPS, and may be stored on servers associated with finlopro.com.

We apply technical and organizational safeguards appropriate to the type of information and the related processing risk, including:

• Encrypted transmission
• Access controls
• Identity and security verification
• System monitoring and abnormal activity detection
• Restrictions on data access
• Secure deletion or anonymization procedures

Although reasonable safeguards are applied, no electronic storage or network transmission method can be guaranteed to be completely secure.

Finlo does not sell, rent, or trade personal information.

Information may be disclosed only where reasonably necessary in the following circumstances:

• You have provided clear authorization
• Disclosure is required by Philippine law, regulation, court order, or legal process
• A lawful request is received from an authorized government or regulatory body
• Disclosure is necessary to protect the legal rights or safety of users, Finlo, or others
• Disclosure is required to investigate fraud, misuse, security incidents, or unlawful conduct

Any disclosure will be limited to the information reasonably necessary for the relevant lawful purpose.

You may decide whether to grant or withdraw SMS, location, and other app permissions through your device settings. After a permission is withdrawn, features that depend on that permission may no longer operate correctly.

Subject to applicable law, you may request to:

• Be informed whether your personal information is being processed
• Access personal information relating to you
• Correct inaccurate or incomplete information
• Withdraw consent for processing based on your authorization
• Request deletion of information that is no longer required
• Object to certain types of information processing
• Request information about the handling of your account and personal data

You may submit an account deletion request directly within the application through:

After account deletion is completed, personal information associated with the account will be deleted or anonymized, except where retention is required for legal compliance, dispute handling, security investigations, or regulatory obligations.

Personal information is retained only for the period reasonably necessary to fulfill the purposes described in this Policy, maintain service security, or comply with applicable legal obligations.

When information is no longer required, it will be securely deleted, de-identified, or anonymized, depending on the circumstances.

Full financial SMS message content is not uploaded to our servers and is not retained by Finlo on the server side.

Finlo is intended only for users who are at least 18 years old and is not directed to individuals under the age of 18.

We do not knowingly collect personal information from minors. If we become aware that information has been submitted by a minor, we will take reasonable steps to delete it.

We may revise this Privacy Policy when app features, legal requirements, or information practices change.

An updated version will display a revised effective date. Where an update may materially affect your rights, we may provide notice through the application or by another appropriate method.

Your continued use of Finlo after an updated Policy becomes effective indicates that you acknowledge the revised information practices.