Privacy Policy
Thanks for using appname. This Privacy Policy is meant to be easy to read: what we collect, why, and what you can do about it.
HOA LOAN SERVICES BK LLC (“appname,” “we,” “us”) operates the appname app and website, which let you browse and compare estimated loan options from participating providers in the Philippines. We are not a lender and we do not make credit decisions.
This policy is written to comply with Republic Act No. 10173 (the Data Privacy Act of 2012), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). Our Terms of Use apply as well.
Who is responsible
Personal Information Controller: HOA LOAN SERVICES BK LLC
Address: 6827 Pershing Ave, Saint Louis, MO, US 63130
Website: zephfinance.com
General contact: [email protected]
Data protection requests: [email protected]
Use this address for any request, question, or complaint under this policy.
What we collect
appname is a comparison tool. You review offers, save options, and run an estimate. We do not take a full loan application on our side. A provider may ask for more in its own application — that happens with the provider, not with us.
When you use appname, we may collect:
- the amount, term, and rate you enter in the calculator;
- offers you choose to save in the app;
- messages you send us (for example your name, email, and the text of the message);
- basic device and usage information, such as device type, app version, browser, IP address, and how the app or site is used.
What we do not collect
- We do not run a credit check. We do not contact credit bureaus and browsing appname does not affect your credit standing.
- We do not ask you to submit a government ID, selfie, OTP, or bank password inside appname to complete a comparison.
- We do not collect your bank account details. If a provider needs them, it asks you in its own flow.
- We do not access your contacts, photos, files, or precise location.
- We do not collect sensitive personal information as defined in Section 3(l) of the Data Privacy Act.
Why we collect it, and on what basis
| Purpose | Lawful basis |
|---|---|
| Show and remember comparison results | Your consent, and performance of the service you requested |
| Respond when you contact us | Your consent |
| Keep the app and site working and secure; prevent fraud and abuse | Our legitimate interests |
| Understand what is broken or unused | Our legitimate interests |
| Meet legal obligations and respond to lawful requests | Legal obligation |
We do not use your data to underwrite a loan. We do not use your personal information to train artificial intelligence models, and we do not share it with third parties for that purpose.
How consent is obtained
Where we rely on consent, you give it by ticking a box that is not pre-ticked, before the relevant processing starts. We keep a record of the consent given, including the date and the version of this policy you accepted. You can withdraw consent at any time — see Your rights.
Who sees it
We may share what is needed with:
- service providers who host or help run appname (hosting, email delivery, analytics, security), under contracts that limit them to our instructions;
- authorities, where the law requires it.
If you tap through to apply with a participating provider, you leave appname and use that provider’s own flow. That provider receives what you submit there and is a separate Personal Information Controller with its own privacy policy. We do not see what you enter on their side.
We do not sell your personal information, and we do not send a loan application from appname to a network of lenders on your behalf.
Participating providers may pay HOA LOAN SERVICES BK LLC if you apply or take a product, and that can affect the order in which options appear. We say so here and in the Terms of Use, not in a hidden note.
Sending information outside the Philippines
HOA LOAN SERVICES BK LLC and some of our service providers are located outside the Philippines, so your personal information may be stored or processed abroad.
Under the Data Privacy Act, we remain responsible for your personal information when it is transferred overseas. We use contractual and technical safeguards so that it receives a comparable level of protection to that required under Philippine law.
Cookies and similar tools
The website may use cookies or similar tools so pages load, settings are remembered, and we can see basic usage. You can block cookies in your browser; some parts of the site may then work less well.
We do not use cookies to decide anything about a loan.
How long we keep it
| Information | Retention |
|---|---|
| Calculator entries | Kept on your device; not retained on our side once the session ends |
| Saved offers | Until you remove them, or until you delete your data |
| Messages you send us | Up to 24 months after the request is closed |
| Device and usage logs | Up to 12 months |
| Record of consent | For as long as we process your data, and 5 years afterwards |
| Anything required by law | For the period the law requires |
After these periods we delete or de-identify the information.
Deleting your information
You can delete your saved offers and any information held about you at any time from inside the app, under More information → Manage my data. You can also write to [email protected].
Keeping it secure
Reasonable organisational, physical, and technical safeguards are in place, including encryption in transit, access controls, and confidentiality agreements with our service providers. No system is flawless, but we take this seriously. You are responsible for keeping your device and any app login details under your control.
If a personal data breach occurs that is likely to give rise to a real risk of serious harm, we will notify the National Privacy Commission and the affected individuals within 72 hours of becoming aware of it, as required by the Data Privacy Act and NPC Circular 16-03.
Your rights
Under the Data Privacy Act you have the right to:
- be informed whether your personal information is being processed, and how;
- access the personal information we hold about you;
- object to processing, including processing for direct marketing or automated decision-making;
- have inaccurate information corrected;
- have your information erased or blocked where it is incomplete, outdated, false, unlawfully obtained, or no longer needed;
- data portability — obtain a copy in a commonly used, structured, electronic format;
- withdraw consent at any time, without affecting processing already carried out;
- damages for inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal information;
- lodge a complaint with the National Privacy Commission.
How to exercise them
Write to [email protected] with your name, a contact detail, and what you are asking for. We may ask for information to confirm your identity.
We respond within 15 business days. If we need longer, we will tell you why and when to expect an answer.
If you are not satisfied, you may complain to the National Privacy Commission at www.privacy.gov.ph. The NPC generally expects you to raise the matter with us first.
If you applied with a provider, use that provider’s own process for the data they collected — we do not hold it.
Children
appname is not for anyone under 18. We do not knowingly collect personal information from children. If we learn that we have, we will delete it.
Changes
If we update this policy, the date at the top changes too. The updated version applies once it is posted on the site or in the app. If the change is significant, we will tell you in the app or on the site before it takes effect.
Contact
HOA LOAN SERVICES BK LLC
6827 Pershing Ave, Saint Louis, MO, US 63130
zephfinance.com
[email protected]