Skyro Lending Inc. Privacy Policy
Effective Date: July 2, 2025
1. Introduction and Scope
Skyro Lending Inc. ("Skyro," "we," "our," or "us") is a duly registered and licensed lending company in the Philippines, operating in full compliance with the country’s legal and regulatory framework, particularly Republic Act No. 10173 or the Data Privacy Act of 2012. We are committed to delivering secure, accessible, and reliable digital lending services that prioritize user privacy and data integrity. Our mission is to make financial services more inclusive, transparent, and personalized for every Filipino borrower.
This Privacy Policy is intended to inform you about how we collect, process, share, and protect your personal and sensitive information when you use our mobile application, website, and other digital platforms or services (collectively, the "Services"). We believe that transparency is key to building trust, and this policy serves as a reflection of that commitment.
By accessing, downloading, registering with, or using our Services, you acknowledge and consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to the terms herein, please refrain from using our Services.
2. Information We Collect
2.1 Personal Identification and Identity Verification Information
To verify your identity and comply with applicable legal and regulatory requirements, we may collect the following data:
Full name as per your government-issued ID
Date of birth
Gender and nationality
Government-issued ID type and number (e.g., UMID, passport, driver’s license)
Clear photographs of your ID (front and back)
Selfie or facial verification images
These details are essential to confirm your identity, prevent fraud, and comply with Anti-Money Laundering (AML) standards and Know Your Customer (KYC) regulations.
2.2 Contact and Residential Information
To communicate with you effectively and send important updates:
Current residential address, including detailed components such as building number, street name, barangay, municipality, and postal code
Valid email address
Mobile phone number registered under your name
This information helps us verify your residence, send loan updates, and reach you for verification and support.
2.3 Employment, Educational, and Marital Status
To assess your creditworthiness and determine eligibility:
Employment status (employed, self-employed, unemployed)
Employer name, address, and contact information
Job title, tenure, and salary frequency
Highest educational attainment
Marital status (single, married, divorced, widowed)
Understanding your employment and educational background allows us to offer loan products tailored to your financial profile.
2.4 Financial and Credit Information
To conduct credit risk assessment and offer suitable loan products:
Monthly income range
Existing loans or financial obligations
Property or vehicle ownership status
Number of credit cards
Banking history or transactional behavior (if applicable)
This data supports our responsible lending practices by evaluating repayment ability and overall financial stability.
2.5 Emergency Contact Information
To reach you or verify information in emergencies:
Name of emergency contact(s)
Relationship to the user
Mobile number and address of emergency contact
This helps us contact someone you trust if we are unable to reach you or if required for identity verification.
3. Permissions Required
To function optimally, our app requests the following device permissions:
3.1 Location Access
Checking general geographic location (e.g., region or city) to prevent potentially fraudulent activity
Enabling area-based service customization (e.g., language or regional compliance)
This permission only accesses approximate location and does not collect precise GPS coordinates. It is used solely to improve service accuracy and comply with regional guidelines.
3.2 Camera and Photo Access
Capturing ID images and selfies for verification
Uploading supporting documents like payslips or utility bills
By using your device’s camera, we ensure swift identity verification and smoother loan processing.
3.4 Device Information
Device model and operating system version
Encrypted unique device identifier
Network carrier and signal strength
We use this data to secure your account, identify suspicious devices, and ensure proper app functionality.
3.5 Network Access Permission
Purpose: To ensure smooth submission of your loan application, receive important notifications, and synchronize data in the background.
Data Collected: Network connection status (WiFi or mobile data), signal strength, and online/offline status.
Usage:
Verify your device’s connectivity to submit forms and validate identity
Optimize upload speeds and notification delivery
Notify you when there is no network connection to prevent submission failures
Restrictions:
We do not collect WiFi passwords or access encrypted content
We do not track your browsing activity or network history
User Control: You may disable this permission at any time via your device settings; however, this may affect the submission of your loan application and the receipt of notifications.
3.6 Battery Optimization Exemption
Ensuring timely notifications and background task execution
Without this permission, you may miss important alerts or updates regarding your loan application.
3.7 Advertising Identifier (Optional)
Purpose: Collecting device-level advertising identifier (IDFA) for personalized ad delivery and marketing optimization, only with your explicit consent.
Data Collected: IDFA (Identifier for Advertisers) on iOS devices, used to deliver relevant loan offers and promotional content based on your in-app behavior.
Usage:
Show you tailored advertisements to improve user experience
Control ad frequency to avoid excessive repetition
User Control: You may opt out of IDFA tracking anytime via your device’s privacy settings or the app’s privacy preferences.
Privacy Commitment: We do not share your personally identifiable information (PII) with advertising partners, and all ad networks must comply with strict data minimization policies.
4.1 Processing Loan Applications
Assessing your credit standing and repayment capacity
Verifying personal and employment details
For example, we may use your payslip to calculate your monthly capacity to repay and determine your loan limit.
4.2 Ensuring Legal and Regulatory Compliance
Meeting Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
Responding to legal inquiries or government requests
This protects both users and the company from fraudulent activities and legal liabilities.
4.3 Improving User Experience
Personalizing product recommendations
Enhancing application interface, performance, and navigation
For instance, based on your past usage, we may recommend a pre-approved loan that matches your income range.
4.4 Risk and Fraud Mitigation
Preventing multiple accounts or applications from a single device
Detecting anomalies in usage or behavioral patterns
We track device fingerprints and login behavior to detect and block fraudulent actors.
4.5 Customer Service
Responding to inquiries, complaints, and disputes
Communicating important updates, reminders, or changes
We store chat transcripts and call logs to monitor service quality and resolve disputes efficiently.
4.6 Marketing and Analytics (with consent)
Sending promotional messages or loan offers
Conducting statistical analysis to improve business strategies
You will receive relevant promotions only if you opt in, and you can manage your preferences anytime.
5. Data Sharing and Disclosure
We do not sell your personal data. However, we may share your information in the following scenarios:
5.1 Authorized Third-Party Providers
Identity verification partners
Cloud and data storage providers
Analytics and customer support platforms
These providers operate under strict data protection agreements to ensure your information is safe and used only as intended.
5.2 Government Authorities
Courts, regulatory bodies, and law enforcement agencies
In response to subpoenas, warrants, or legal obligations
We comply with all applicable laws in good faith and notify you of such disclosures whenever legally permitted.
5.3 Corporate Transactions
Mergers, acquisitions, or asset transfers
Business restructuring or reorganization
In such cases, data transfer will follow existing privacy protections, and you will be notified of changes.
5.4 Credit Bureaus and Financial Institutions
To evaluate your creditworthiness
For loan recovery and repayment tracking
These disclosures are made only when necessary and with data minimization principles in place.
5.5 Anonymized or Aggregated Data
For research, trend analysis, or reporting
This type of data cannot be traced back to you and is used to enhance our services and performance metrics.
6. Data Storage and Security
Skyro implements administrative, technical, and physical safeguards to ensure data integrity:
6.1 Data Encryption
All data transmitted is encrypted using industry standards
Stored data is protected via encryption-at-rest protocols
We use TLS for data in transit and AES-256 for storage encryption to ensure your data is unreadable to unauthorized entities.
6.2 Access Control
Role-based access limitations
Logging and monitoring of all data access
Access to your personal data is restricted to employees who need it to perform their job duties and is regularly audited.
6.3 Local Data Hosting
Data is stored in secure, Philippine-based data centers compliant with legal standards
These data centers are equipped with firewalls, intrusion detection systems, and physical surveillance systems.
6.4 Third-Party SDK Disclosures
AppsFlyer (for marketing attribution)
Advance.AI (for identity verification)
SDKs are reviewed for privacy compliance prior to integration
We ensure third-party SDKs are limited in scope and do not access unnecessary personal data.
6.5 Firebase SDK Disclosure
We use Google Firebase services to support app stability, performance monitoring, and crash analytics. These tools help us understand technical issues and improve app reliability. Firebase collects limited technical data such as:
Device model and OS version
App performance logs
Crash reports (with anonymized session data)
General app usage patterns
Firebase does not access or store any personally identifiable information (PII). All data collected is anonymized or aggregated to ensure user privacy. For more information, please refer to Firebase's Privacy Policy.
7. Data Retention
We retain your personal data only as long as necessary:
Identity and transaction records: minimum of 5 years from last activity (for AML compliance)
Loan-related data: retained during the term of the loan plus 5 years
Support and interaction data: retained for 2 years
Retention periods are defined based on legal, regulatory, and operational needs to prevent fraud and resolve future disputes.
Account deletion requests are honored within 15 business days unless legal obligations require longer retention.
8. User Rights Under the Data Privacy Act
You have the right to:
Access your data and request a copy
Correct inaccuracies in your personal information
Request erasure under certain conditions
Object to data processing or marketing communications
Request data portability
We are committed to upholding your privacy rights and will respond to any request within a reasonable timeframe, typically within 15 business days.
To exercise your rights, contact our Data Protection Officer at: vergelvelasquez@skyrolending.com
9. Account Deletion Process
You may delete your account by:
Using the in-app "Delete Account" feature
Contacting customer service with your name, ID, and registered number
We will confirm your identity and complete deletion within 15 business days. Note that account deletion is permanent and may limit your access to future services.
10. Children’s Privacy
Our Services are not intended for users under the age of 18. We do not knowingly collect data from minors. If discovered, such data will be deleted immediately. Parents or guardians may contact us to assist with removal.
11. Policy Updates
We may update this Privacy Policy from time to time. Material changes will be communicated through the app or email. Continued use of our Services signifies your acceptance of the updated policy. We encourage users to regularly review this page to stay informed about how we protect their information.
12. Contact Information
Skyro Lending Inc.
One Corporate Center, Meralco Avenue corner Julia Vargas Avenue Penthouse 1, Pasig, Metro Manila, 1605 Philippines
Email: vergelvelasquez@skyrolending.com
13. User Consent and Acknowledgment
By using our Services, you acknowledge that you:
Understand and agree to this Privacy Policy
Consent to the collection, use, and sharing of your personal data
Are aware of your rights and how to exercise them
Understand our compliance with the Data Privacy Act of 2012
If you do not agree with any part of this policy, please discontinue your use of the Skyro app.
