PRIVACY POLICY [as of 11 July 2025]

This Privacy Policy describes how n90 Lending Corp. and its representatives and/or agents (collectively referred to herein as “n90”, “AgadPay”, “us”,“we” or “our”) will manage Personal Information (as defined below) in compliance with the Data Privacy Act of 2012 and its regulation(s) (“the Act”or “DPA”) when you avail or use the AgadPay service.

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By interacting with us and submitting information to us, whether as employer-client or as an employee-user, you agree and consent to n90 collecting, using, disclosing and sharing among themselves your Personal Information, and disclosing such Personal Information to their authorized service providers and relevant third parties in the manner set forth in this Data Privacy Policy.

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This Data Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to n90 in respect of your Personal Information, and your consents herein are additional to any rights which our company may have at law to collect, use or disclose your Personal Information.

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We may from time to time update this Data Privacy Policy to ensure that this Data Privacy Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Privacy Policy as updated from time to time on our website [www.agadpay.ph].

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1. PERSONAL DATA  

1.1 In this Data Privacy Policy, “Personal Information” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

1.2 Examples of such Personal Information you may provide to us include:

1. For Employer-Client: company name, business registration documents, contact person’s names, positions, business email, phone numbers, corporate bank details, credit information, financial information,  and similar information;
2. For Employee-User: name, identification card or other identification number, telephone number(s), mailing address, email address, bank information or statements, salary information, employer information, credit information, financial information,  and any other information relating to any individuals which you have provided us in any methods of interaction with you.

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2. COLLECTION OF PERSONAL DATA

2.1 Generally, we may collect Personal Data in the following ways:

       2.1.1 For Employer-Client:

1. When you register your company for the Agadpay program, submit company details, authorized representative information, and supporting documentation;
2. When you enter into a service agreement, memorandum of understanding, or data-sharing agreement with us;
3. When you or your authorized representative interact with our staff (via calls, email, in-person meetings, or online chat);
4. When you upload or transmit employee payroll information, attendance records, or other workforce-related information to the Agadpay platform;
5. When you respond to due diligence requests or compliance related submissions;
6. When you voluntarily participate in product testing, feedback programs, or provide testimonials or marketing consent;
7. When we receive your business or contact details through referrals or public sources (e.g. your company website, industry events); 
8. When you visit our office or attend AgadPay events where photo or video documentations may be conducted; and
9. When you otherwise submit corporate or representative information to us for service or account administration.

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        2.1.2 For Employee User

1. When your employer shares your employment and payroll-related data (e.g. name, employee ID, job title, timekeeping logs, salary) with us to enable the AgadPay service;
2. When you activate or register your AgadPay account via our website;
3. When you request a wage advance or submit supporting information (e.g. bank/e-wallet details, government-issued ID);
4. When you contact our support channels by phone, email, social media;
5. When you respond to surveys, provide feedback, or participate in promotional activities;
6. When you visit our office or attend AgadPay events where photo or video documentations may be conducted; 
7. When you receive your information from your employer, financial institutions, or authorized third parties, if any, as part of our service delivery; and
8. When you otherwise voluntarily provide your personal information through any interaction with us.

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2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.

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2.3 If you provide us with any Personal Information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes.

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2.4 You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to fulfill your requests, or delays in processing your requests.

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3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, n90 collects, uses, processes and discloses your Personal Information for the following specific purposes on basis of the consent given (where applicable) for:

1. To deliver and operate the AgadPay platform and related financial technology services;
2. To verify identity, employment, and payroll data for platform access and wage eligibility computation;
3. To process, track, and disburse salary advances or wage access requests through integrated banking or e-wallet channels;
4. To administer and support your user account, including user verification, authentication, and account history;
5. To respond to inquiries, feedback or support requests;
6. To generate reports, dashboards, and transaction summaries for employers and users;
7. To improve service functionality, user experience, and platform performance through usage analysis;
8. To conduct market research, surveys, or usage analytics to understand behavior, preferences, and product-market fit; 
9. To ensure security, detect fraud, abuse or suspicious activities on the platform;
10. To host, store, back-up, or transfer data using secure cloud-based solutions;
11. For internal governance, audits, regulatory compliance, and legal documentation;
12. To comply with applicable laws, regulations, issuances, and lawful orders of regulatory authorities, such as the NPC, DOLE, AMLC or BIR;
13. For business continuity purposes, including potential mergers, acquisitions, investments or restructuring activities; and/or
14. For purposes that are reasonably related or ancillary to the above. 

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3.2 In addition, n90 collects, uses and discloses your Personal Information for the following purposes:

      3.2.1 If you are an Employer-Client:

1. To assess your eligibility and onboard your company as an AgadPay partner;
2. To verify your business registration, authorized representatives, and company payroll policies;
3. To receive, reconcile, and process payroll and timekeeping data submitted for employee access;
4. To administer service contracts, billing, and reporting;
5. To coordinate support, training, and communication with your designated administrators;
6. To generate company-level dashboards, usage summaries, or productivity analytics;
7. To support compliance with labor, tax, and financial regulations.

       3.2.2 If you are an Employee-User:

1. To compute your available earned wages based on payroll and attendance data provided by your employer;
2. To process your requests for salary advance or earned wage access;
3. To verify your identity, employment status, and eligibility criteria;
4. To disburse funds to your nominated bank account or e-wallet;
5. To monitor your usage behavior and ensure compliance with platform terms;
6. To notify you about your transaction status, account updates, and system-related alerts;
7. To provide in-app support and resolve service concerns or disputes;
8. To protect against fraud, duplicate access, or misuse of the system;
9. To enhance your user experience and recommend features based on usage.

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4. Disclosure of Personal Information

4.1 n90 will take commercially reasonable steps to protect your Personal Information against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Information may be disclosed, for the purposes listed above (where applicable), to the following entities or parties:

1. n90’s related corporations and employee(s); to address your questions and requests in relation to your interactions with us, to maintain and operate our systems and/or services;
2. agents, contractors or third-party service providers who provide services to n90, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, security, or other services to n90;
3. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of our entities;
4. external banks and their respective service providers;
5. companies which provide corporate secretarial services;
6. our professional advisers such as consultants, auditors and lawyers;
7. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
8. any other party to whom you authorize us to disclose your Personal Information to.

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4.2 Please note that the disclosures referred above may be subject to additional legal requirements under applicable law, if we do disclose your Personal Information, we will only do so to the extent necessary, proportionate and legally permitted.

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5. Use of Cookies

5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s clickstream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

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5.2 Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

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5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to use certain services or enter certain part(s) of our website.

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6. Your Rights as a Data Subject

6.1 Either as Employer-Client or Employee-User, you have the following rights under the DPA, which may be exercised by contacting the n90 in writing:

1. Right to Be Informed: To know how your data is collected, used, and shared.
2. Right to Access: To request a copy of your personal data.
3. Right to Correction: To correct inaccurate or outdated data.
4. Right to Object: To refuse the processing of your data for certain purposes.
5. Right to Erasure: To request deletion of your data, subject to legal or contractual obligations.
6. Right to Data Portability: To request your data in a commonly used electronic format.

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7. Data Security

7.1 n90 will take reasonable efforts to protect Personal Information in our possession or our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

1. Encryption: Ensuring that sensitive data is encrypted during transmission and storage to prevent unauthorized access.
2. Access Controls: Restricting access to personal data to authorized personnel only, based on the principle of least privilege.
3. Regular Security Audits: Conducting regular audits and assessments to identify and address vulnerabilities in our systems.
4. Secure Software Development: Employing secure coding practices to minimize risks associated with software vulnerabilities.
5. Incident Response Plan: Maintaining a comprehensive incident response plan to address potential data breaches promptly and effectively.
6. Data Minimization: Collecting only the personal data necessary for the purposes outlined in this policy and retaining it only for as long as needed.

However, we cannot completely guarantee the security of any Personal Information we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the various associated risks with using websites.

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7.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or otherwise and we urge you to take every precaution to protect your Personal Data when you are on the internet or use such platforms.

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7.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.

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8. Data Transfer and Data Retention

8.1 If the transfer of your Personal Information within our affiliates or subsidiaries is necessary, we will take reasonable steps to ensure that your Personal Information transmitted outside of your country of residence remains adequately protected to a standard similar to that afforded by the DPA. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

8.2 All Personal Information is retained for as long as it is necessary for the purposes it has been collected for in accordance with our data retention policy, and applicable laws and regulations. Any third party who manages our Personal Information is also required to ensure that the Personal Data is disposed of in accordance with the retention period as may be agreed in their respective engagement contract(s).

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9. Contact Us

9.1 If you:

1. have any questions or feedback relating to your Personal Information or our Data Privacy Policy;
2. would like to exercise your rights under Section 6 of this Policy;
3. would like to withdraw your consent to any use of your Personal Information as set out in this Data Privacy Policy;
4. would like to obtain access and make corrections to your Personal Data records, you can approach us via hello@n90.asia

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10. Links to Third-Party Website(s)

10.1 Our website or application system may contain links to other third-party operated websites over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our website or application system. Once you have left our website by clicking a relevant link, your use of that third-party website will be governed by the privacy or data protection policy of that website.

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11. Governing Law

11.1 This Data Privacy Policy and your use of this website shall be governed and construed in all respects by the laws of the Republic of the Philippines.

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