Privacy Policy

Last updated: October 2026. Operator: [COMPANY NAME]. Data Protection Officer / contact: [DPO EMAIL]. Have these reviewed by counsel before production use. Governed by Republic Act No. 10173 (Data Privacy Act of 2012).

1. Data we process

Account data (name, email, mobile, company) for login and billing; payment records (amounts, references, provider references, statuses) for ledger and dispute evidence; Manual Direct claim data (sender reference, receipt photos) for human review; security logs (logins, 2FA events, admin actions) for fraud prevention. We do not collect passwords beyond salted hashes, and we never see provider credentials beyond sealed envelopes.

2. Why and on what basis

Contract (operating your workspace), legal obligation (financial record-keeping, lawful orders), and legitimate interests (security, abuse prevention). Marketing, if any, is opt-in only.

3. Sharing

We share payment data with the payment providers you connect (necessary to move money), and with authorities when legally compelled. We sell no data. Sub-processors (hosting, email delivery) act only on our instructions.

4. Retention

Financial and audit records are kept indefinitely as required by law and for dispute evidence. Receipt photos exist only while a transfer claim is undecided and are deleted on decision (abandoned ones swept after 30 days). Sessions expire on inactivity; expired checkout and idempotency data are purged on schedule.

5. Your rights

Access, correction, portability, and objection as provided by the Data Privacy Act — write to [DPO EMAIL]. Requests that conflict with legal record-keeping duties will be declined with reasons. We respond within statutory timelines.

6. Security and breach

Encryption in transit and at rest for secrets, hashed credentials, throttled auth, and audited admin actions. No system is impenetrable; where a breach creates a real risk of harm we notify affected users and the National Privacy Commission as the law requires.

7. Changes

Material changes are announced in-app at least 30 days ahead; continued use is acceptance. Questions: [DPO EMAIL].