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MONEYMAX PRIVACY POLICY

--------------------------------------------------------------------------------

Date of Last Revision: November 8, 2021

MoneyGuru Philippines Corporation. (“MoneyMax”) and MoneyHero Insurance
Brokerage, Inc, (“MoneyHero”, and together “we“, “us” or “our”) are part of the
Hyphen Group, a group of companies that provide price comparison services as
well as financial services, insurance products, communications, and other
products and services and across Asia.

The MoneyMax.ph website (“Website“), including the content, features, tools,
data, software, and functions made available by us through the Website, our
mobile applications, and any other websites or applications we operate (unless
those websites or applications have posted separate or additional terms of
service) (together, the “Services”) have been created to provide information to
our visitors (“you” and “your”) about our products and services.  For the
avoidance of doubt, other than the provision of marketing services, MoneyMax
does not carry on an insurance business and is not regulated by the Insurance
Commission.  All insurance-related activities referred to on the Services are
carried out solely by MoneyHero, a licensed and authorized insurance broker
regulated by the Insurance Commission.

This Privacy Policy explains what information and what Personal Data we collect,
why we collect it, how we use and disclose it, and how we protect Personal Data
in compliance with the Data Privacy Act, 2012.  Please be sure to read this
entire Privacy Policy before using our Services.  When you use, access, or
interact with our Services, you are agreeing to our Terms and Conditions and
consenting to the practices described in this Privacy Policy with respect to the
collection, use, and disclosure of your information.

In this Privacy Policy, the term “Personal Data” means any data relating
directly or indirectly to a living individual which is capable of being used to
identify that individual.


INFORMATION WE COLLECT

We collect information about you in three main ways: when you provide it to us,
with automatic technologies, and when third-party sources provide it to us.

While using our Services (for example, in order to get comparative quotes for
personal loans), your Personal Data may be collected or provided by you to us in
various ways.

The following are examples (without limitation) of the circumstances in which we
collect Personal Data:

 * When you subscribe to receive updates from us, we will ask for your email
   address;
 * When you request quotes for certain products, we may ask for information like
   your age and income, so that we can obtain accurate quotes;
 * When you redeem a reward on our Services, we may ask for your name, email
   address, the product you applied for, your application reference number,
   and/or your application date;
 * When you contact us by telephone, we may ask for your name, email address,
   and/or phone number, so that we can contact you regarding your inquiry; and
 * When you apply for a product or a service using the application forms on our
   Services, we will collect information that includes but is not limited to
   contact details, identification information, and financial information; and
 * If you want to add a child or family member to your application for a product
   or service, we may collect that family member’s name and date of birth, so
   that we can process the application.

The Personal Data we may ask you to provide includes (without limitation):

 * name
 * address
 * email address
 * telephone number
 * date of birth
 * age
 * gender
 * nationality
 * any messages if you write to us using the “contact us” form
 * your saving goals
 * your residency status
 * your income
 * details of the products you are looking for (for example, the size of loan)
 * passport number national identity number or other identity copies and/or
   details (where required for purchasing a product or availing of a service)
 * education history
 * assets
 * employment status
 * employer or company details
 * details of beneficiaries, such as joint policyholders and minor beneficiaries
   (where required for purchasing a product)
 * family members (where required for purchasing a product or availing of a
   service)
 * details of your property (when purchasing home insurance) 
 * financial details about you, including details related to the payment
   method(s) such as credit card and bank account information (when purchasing a
   product); and
 * information related to any of the above.

Most often, the provision of the above data is on a voluntary basis.  However,
if you do not provide sufficient information to us, third-party products and
service providers may not be able to provide the requested information,
products, or services to you.


AUTOMATIC COLLECTION OF COMPUTER DATA

In addition, when you use the Services, we may automatically collect certain
data about how you access and interact with our Services which may, when
combined with other information about you, constitute Personal Data.  Automated
technologies, such as our use of ‘cookies’, help us achieve our goal of
providing you with the best possible service.  When you access our Services, our
servers will record, or track information sent from the browsers.  This can
include the following information (without limitation):

 * attributes of the equipment or device you are using, such as the operating
   system, hardware version, device settings, software, and device identifiers;
 * device locations, including specific geographic locations identified through
   GPS signals or other means;
 * connection information such as the name of your mobile operator, ISP or other
   service providers, browser type, and IP address;
 * the website from which you have reached the Services;
 * the Website pages viewed;
 * details of the products and services on the Services that you look at,
   information, tools, and content available on our Services that you use;
 * time spent on the Services;
 * links from our Services that you click on;
 * quotes you request from our Services;
 * your transactions on our Services and details of any payments made by you
   (including bank account and credit card details and any other account
   identification information); and
 * information related to any of the above.

Our use of cookies enables us to:

 * provide you with a more personalized experience on our Services.  It allows
   us to remember you when you revisit our Services.  You can also access your
   previously saved quotes;
 * study browsing habits on the Services. The more we understand what products
   you are interested in, the greater our ability to offer you customized
   solutions and targeted advertisements, and other marketing materials; and
 * obtain information regarding the number of visitors to the Services and the
   pages viewed.

In most cases, cookies are deleted when you close your browser; these are
referred to as session cookies.  However, persistent cookies stay on your
browsing device either until such time as you delete them, or they expire.  By
using the Services, you consent to us using cookies.  Such use of data does not
disclose any of your Personal Data, and we will not collect, process, or use any
of your Personal Data in this regard.

You can alter your computer browser settings to block or delete cookies. If you
opt to block or delete cookies of the Services, you may not be able to access
certain products or services and this could have an effect on the performance of
the Services on your system (for example, banner ads may not display properly).

In some cases, we also use cookies provided by trusted third parties.  The
Services use a feature of Google Analytics, a widely consumed analytics
solution.  This setup allows for more accurate tracking of our users by
associating that user with the same ID over various sessions and devices. This
approach may combine analytics data with other Personal Data about you that we
have collected by our Services.  Any such combined data will be treated as
Personal Data by us and used in accordance with this Privacy Policy.  

We may use features in Google Analytics and Google Display Network, including
advertising and remarketing, that allow us to target ads to you and report on
demographics and interests.  These tools use cookies and other information to
show ads based on your past actions on our Services.  If you would like to opt
out of these features, please visit https://www.google.com/settings/ads/.


INFORMATION PROVIDED TO US BY THIRD-PARTY SOURCES

Finally, when you use the Services, we may also receive information about you
from other third parties we have partnered with such as Credit Score Providers
(defined under “What do we use your Information for?”) or third parties we have
engaged such as business associates, subcontractors, analytics providers,
platform providers and search information providers or, pursuant to your
request, from third party providers of our Partners (defined under “How do we
Disclose your Information?”).


ACCURACY AND RETENTION OF PERSONAL DATA

By providing us with your Personal Data or that of a family member, you warrant
that such data is true and accurate, and undertake to notify us as soon as
practicable of any change or alteration to the same. Any loss or damage caused
to the Services or to the person responsible for the Services or to any third
person through the provision of erroneous, inexact, or incomplete information
will be your exclusive and absolute responsibility.  When you give us Personal
Data about another person (or persons) such as a family member, you should have
the authority to act on such person’s behalf (whether by appointment or by law
in your capacity as legal guardian).  This includes providing consent to our
processing of their Personal Data.  If for any reason you are concerned as to
whether you are permitted to provide us with another person’s information,
please contact us at the email address listed below before sending us anything.

All Personal Data that has been collected from you will only be stored for a
duration that is relevant to the purpose for which it was processed and for as
long as permissible by applicable law(s).

We will only retain your Personal Data for as long as reasonably necessary to
fulfill the purposes we collected it for (further detailed in the “What do we
use your Information for?” section below), including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements.  We
may retain your Personal Data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.  

You have the right to request access to and correction of your Personal Data as
held by us.  Please contact us at max@moneymax.ph at any time if you wish to
correct, amend or update your Personal Data.   We aim to acknowledge and act
upon your request promptly.  To help us respond in the most timely and
appropriate way, please be as specific as possible in your request or inquiry.


WHAT DO WE USE YOUR INFORMATION FOR?

We use the information we collect about you for our legitimate business
interests to operate the Services, to enhance and customize users’ experiences
with the Services and to improve and grow our business.  Depending on the nature
of your relationship with us, we may use your Personal Data for any or all of
the following purposes:

 * to answer your queries and to communicate with you, for example, providing
   you with alerts, notifications, and recommendations;
 * to allow you to access and use our free comparison services and to provide
   quotes to you;
 * to enable you to access online application forms on third-party external
   sites;
 * to process applications for Partner Products on your behalf (see below and
   the section “Partner Products” for further information);
 * to analyze customer behavior, market trends, and client demographics so that
   we can improve our services and to enable us to provide a more personalized
   service and more relevant communications to you;
 * to enable us to save your Personal Data so that you do not have to re-enter
   it each time you request a quote or apply for a product;
 * to enable us to store data and manage our business operations efficiently;
 * with your consent, for direct marketing purposes (see “Direct Marketing”
   below);
 * to diagnose and prevent service, security, or technical issues affecting the
   Services;
 * to monitor, detect and prevent fraud or abuse of the Services;
 * to protect the safety, integrity, and/or rights of our users or any third
   party; 
 * to comply with our legal and regulatory obligations; and
 * to enable us to provide services and products related to the above and/or
   otherwise related to your use of the Services.

We may transfer your Personal Data to TransUnion Customer Connect Service (or
any other consumer credit reference agency) and/or to FinScore (or any other
provider of alternative credit scoring or predictive modeling) (each a “Credit
Score Provider“), where your Personal Data (including mobile number/s, mobile
phone usage data) will be processed for the purposes of credit investigation,
credit scoring, data analytic, and data profiling.  Your Personal Data will be
used, processed, and stored in accordance with the Credit Score Provider’s
privacy policy (this may include the sharing of your Personal Data by the Credit
Score Provider with their partners in order to generate a credit report and/or
alternate credit score), which is outside of our control. The Credit Score
Provider will share your credit report and/or alternative credit score, as
applicable, with us so that Hyphen Group can personalize your experience on the
Services and showcase those products and services best suited to your
eligibility.  We will also use the information we receive to conduct testing and
analysis of the effectiveness of the underlying scoring methods. 

In some circumstances, we will anonymize your Personal Data (so that it can no
longer be associated with you) for research or statistical purposes, in which
case we may use this information indefinitely without further notice to you.


PARTNER PRODUCTS

We save you time by allowing you to apply on our Services for products and
services provided by third parties (“Partner Products“).  If you apply for a
Partner Product via our Services, your Personal Data provided to us, along with
any other information requested and provided by you will be transferred to the
provider and your application will be processed by that provider. That provider
may contact you directly about your application. Your Personal Data will be
used, processed, and stored in accordance with that provider’s privacy policy,
which is outside our control.


HOW DO WE DISCLOSE YOUR INFORMATION?

We are committed to keeping your Personal Data and other information shared with
us confidential.  There are, however, certain circumstances in which we may
disclose or transfer your Personal Data to certain third parties without further
notice to you, as set forth below:

 * Related Companies: We may share your Personal Data with our affiliates in the
   Hyphen Group (subsidiaries/affiliated companies of CompareAsia Group Limited
   – trading as Hyphen Group) that provide services to or share services with
   us.
 * Business Transfers: As we develop our business, we might sell or buy
   businesses or assets. In the event of, or in preparation for, a change of
   control, merger, acquisition, restructuring, dissolution, or similar event,
   we may disclose or transfer Personal Data to a third party.
 * Partners: We may be required to share information with our partners who are
   banks, brokers, lenders, insurance companies, and other money and financial
   service providers whose products may be displayed on our Services from time
   to time (“Partners“) or when you have requested the products and/or services
   our Partners, which requires us to provide your Personal Data to them in a
   pre-populated form or by API.  In order for you to redeem a reward on our
   Services, we may also need to share those details with the relevant Partner
   in order to authenticate your reward redemption. 
 * Agents, Consultants, and Related Third Parties: We rely on service providers
   to help support our business, for example (without limitation) our IT and
   analytics service providers, back office support, business consultants, legal
   service providers, Credit Score Providers, and marketing service providers. 
   When we engage another entity to perform a function of this nature, we only
   provide them with the information that they need to perform their specific
   function.
 * Legal Requirements: We and/or any of the third parties listed above may also
   be required to disclose your Personal Data to any court, law enforcement
   body, government department, regulator, or industry body of any country where
   required by the laws of the Philippines or any other jurisdiction, or in
   response to a lawful request in the Philippines or elsewhere.  We may also
   need to disclose your Personal Data in order to (i) identify, contact, or
   bring legal action against any person who may be causing damage to or
   interfere with our and/or any third party’s rights or property (whether
   intentionally or otherwise) and/or (ii) help with anti-money laundering and
   counter-terrorist financing requirements of our Partners or other third
   parties.

In connection with the purposes set out in this Privacy Policy, your Personal
Data may be transferred outside the Philippines.  That means your Personal Data
may not be protected to the same or similar level as it would in the
Philippines.  However, we will take all reasonable measures to ensure that your
data is processed and stored securely, regardless of the country in which it is
processed or stored.

By using our Services, you consent to the use and disclosure of your Personal
Data as set out above.


KEEPING YOU UPDATED REGARDING OUR SERVICES & DIRECT MARKETING

Once you use our services, we may use your Personal Data (including your name,
address, email address, and telephone number) to contact you about news, offers,
events, and promotional campaigns in relation to price comparison services
and/or financial services, insurance, communications, online content and other
products and services that we feature on the Services from time to time. 
Whenever you give us your Personal Data, we will give you a chance to inform us
that you do not consent to us or others using and sharing your data for
marketing purposes.  Unless you state otherwise, you are deemed to agree to such
uses.

For example, this may include credit cards, mortgages, personal loans, insurance
products, device protection programs, broadband services, etc.  We may use other
data collected about you, including but not limited to your age, location,
income bracket, employment, browsing history, purchases, and quotes requested in
order to provide materials that are customized and relevant to you.

With your consent, we may also provide your Personal Data (including your name,
address, email address, and telephone number) to our Partners so that they may
contact you with news, offers, events, and promotional campaigns in relation to
price comparison services and/or financial services, insurance, communications,
online content and other products and services that we feature on the Services
from time to time.

We may also share aggregated data, provided your identity will not be disclosed
by such sharing, with third parties for various purposes (including marketing
and advertising), and may use this data in order to better understand your needs
and to improve and adapt our products and services, but please note that, unless
permitted or required by law or as otherwise set out in this Privacy Policy, we
will not disclose your Personal Data to any third parties without your prior
consent.

You can opt out of direct marketing, free of charge, at any time (see “Your
Rights” below).


THIRD-PARTY PROVIDERS

If you opt to enter into a contract with a third party through our Services, the
data you provide to the third party will be transferred to that third party and
controlled by the third party in accordance with that third-party provider’s
privacy policy.  Therefore, you should contact them directly for additional
information in relation to their privacy policies and read all policies, terms,
and conditions before entering a contract. We are not responsible for how
third-party providers use your Personal Data.

If you choose a direct payment gateway to complete your purchase, your payment
will be processed by Paynamics Technologies, Inc. (“Paynamics”), a third-party
payment solutions provider. Paynamics uses Paygate, its payment gateway
solution, to store and encrypt your purchase transaction data in accordance with
the Payment Card Industry Data Security Standard (PCI-DSS).  Your purchase
transaction data is stored only as long as is necessary to complete your
purchase transaction. After that is complete, your purchase transaction
information is deleted.


DATA SECURITY

We are fully committed to safeguarding your privacy, online and otherwise, and
the success of our business depends on our ability to maintain the trust of our
clients and customers.  We apply Defense in Depth approach in securing Personal
Data entrusted to us by our customers and continuously improve those measures to
address security risks. This website employs Amazon’s ‘AWS Certificate Manager’
and thus offers a high level of data protection. However, no information
transmission over the internet is 100% secure. Highly sensitive data such as
your credit card details are encrypted to minimize the danger of interception
throughout transit. However, while we try to safeguard your personal data, we
cannot assure or warrant the safety of any data that you give us, and you do so
at your own risk.


CONSENT

This Privacy Policy supplements but does not supersede nor replace any other
consents you may have previously provided to us in respect of your Personal
Data, and your consents herein are additional to any rights which we may have at
law to collect, use or disclose your Personal Data.


USE OF THE SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and
we request that these individuals do not access or use our Services.


IMPROVING OUR SERVICE

In order to ensure that the services we offer you continue to meet your
requirements; we might ask for your feedback.  Any feedback or other information
you submit to us will, unless otherwise stated, be used in accordance with this
Privacy Policy and our Terms and Conditions.


YOUR RIGHTS

You have the right to check whether we hold Personal Data about you and to
require access or correction of your Personal Data.  You can also opt out of
receiving direct marketing or promotional communications from us, our
affiliates, and any of our Partners, at any time. 

If you wish to exercise any of your above-mentioned rights, or you have any
inquiries or complaints in respect of your Personal Data, please kindly address
your inquiries to:

 * Email: max@moneymax.ph 
 * Tel: 8236-6481 (lines are open Monday to Friday 9:00am to 6:00pm)
 * Address : Salcedo Village, 6th Floor ACT Tower, 135 H.V. Dela Costa, Makati,
   Metro Manila


CHANGES TO THIS PRIVACY POLICY

We may need to revise or update this Privacy Policy from time to time in order
to reflect changes in our Services, our business, or applicable law.  We reserve
the right to modify this Privacy Policy periodically without prior notice.  Your
continued access or use of the Services after any changes or revisions to this
Privacy Policy will be deemed to constitute your agreement with the terms of
such revised Privacy Policy.  We will always include a ‘last revised’ date as
part of our privacy policy. You may check this page periodically to stay
informed of our Privacy Policy.

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address at 6th floor, ACT Tower, H.V. Dela Costa, Salcedo Village, Makati City.
Use of this site constitutes acceptance of our Terms and Conditions and Privacy
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