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UnionDigital Bank Inc. is an entity regulated by the Bangko Sentral ng Pilipinas (BSP).Bangko Sentral Financial Consumer Protection DepartmentCall: (02) 8708-7087 | Email: <a href="mailto:consumeraffairs@bsp.gov.ph">consumeraffairs@bsp.gov.ph</a>&nbsp;Contact the BSP Online Buddy (BOB) viaBSP website: <a href="https://www.bsp.gov.ph/">www.bsp.gov.ph</a> | SMS: 021582277Facebook: <a href="https://www.facebook.com/BangkoSentralngPilipinas">www.facebook.com/BangkoSentralngPilipinas</a>&nbsp;Deposits are insured by PDIC up to P500,000 per depositor.&nbsp;Copyright © 2023 UnionDigital Bank Inc.

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UNIONDIGITAL BANK PRIVACY NOTICE

Effective from March 1, 2023&nbsp;Your trust is very important to us. This means that UnionDigital Bank Inc. (the “Bank” or “UnionDigital”) is committed to protecting the privacy and security of your personal data (the “Data”). This Privacy Notice (“Notice”) explains our information practices and informs you how we process personal data about you during and after your relationship with us, in accordance with Republic Act No. 10173 (otherwise known as the “Data Privacy Act of 2012” or simply, “DPA”), its Implementing Rules and Regulations (“IRR”), and issuances by the National Privacy Commission (“NPC”).

This Notice is addressed to individuals with whom we interact. This includes:&nbsp;<ol style="list-style-type:decimal;"><li style="text-align:justify;">Customers — current, past and prospective customers as individuals, corporations, or representatives of corporations; and</li><li style="text-align:justify;">Non-Customers — payees or payors of the bank products and services we provide; visitors or inquirers at online channels; ultimate beneficial owners, directors or representatives of corporate clients; and such other persons involved in the application of financial services whether approved or rejected—and transactions with us or with our customers.</li></ol>

Who should read this Notice?

UnionDigital collects Data according to the nature of your relationship with us. This shall include data that is necessary to validate your identity, fulfill our contractual obligations, perform transactions or provide services, customer care and support, etc. We can lawfully process your Data on the basis of at least one of the following reasons:&nbsp;<ul><li style="text-align:justify;">You have given your Consent—if you have given express consent to process your Data for a specific purpose (e.g., to sign-up on exclusive offers, receive promotional materials)</li></ul>&nbsp;<ul><li style="text-align:justify;">By Contract— the processing is necessary for the performance of our contract with you (e.g., account application with the Bank, availment of our products or services)</li></ul>&nbsp;<ul><li style="text-align:justify;">To allow us to comply with Legal Requirements—the processing is necessary for us to comply with the law (e.g., rules and regulations prescribed by the Bangko Sentral ng Pilipinas (“BSP”), Department of Trade and Industry (“DTI”))</li></ul>&nbsp;<ul><li style="text-align:justify;">A Legitimate Interest—the processing is necessary for the purposes of the legitimate interests pursued by UnionDigital. When we use this lawful basis, we ensure that such interests do not override your interests or your fundamental rights and freedoms.</li></ul>

Why we Collect your Data

<ul><li style="text-align:justify;">Know-Your-Customer (KYC) / Identification Data: refers to Data we collect when you sign up or register to our products and services such as full legal name, gender, date of birth, nationality, civil status, permanent address, present address, tax identification number and other government-issued identification numbers, mobile number, home number, office contact details, company name, job position or rank, office address, source of funds, gross annual income, and such other information necessary to conduct due diligence and comply with BSP rules and regulations.</li></ul>&nbsp;<ul><li style="text-align:justify;">Biometric Data: subject to limitations imposed by law, data processed for customer verification using: (1) facial recognition technology; (2) liveliness detection mechanism; and (3) fingerprint recognition applications.</li></ul>&nbsp;<ul><li style="text-align:justify;">Transactional Data: linkable information to your Data such as (1) bank account number, deposits, withdrawals, such other transfers made to or from your account, and details about them such as reference number, and time these were made; (2) information when you contact us through our official channels such as contact centers, web and mobile platforms; and (3) other forms of customer account number, payments, and transactions you have with us.</li></ul>&nbsp;<ul><li style="text-align:justify;">Financial Data: information about the value of your property and assets, your credit history and capacity, and other financial products and services you have with us.</li></ul>&nbsp;<ul><li style="text-align:justify;">Behavioral Data: refers to your online behavior, customer segment, usage of our products and services, internet protocol address of your devices used to access our applications, interests and needs you share with us, and customer behavior we collect as part of due diligence, to prevent fraudulent conduct, and comply with banking rules on anti-money laundering, terrorism financing, and tax fraud.</li></ul>&nbsp;<ul><li style="text-align:justify;">Audio Visual Data: for security and improvement of our services, we process audio and video recordings of your interactions with us, subject to limitations imposed by law.</li></ul>&nbsp;<ul><li style="text-align:justify;">Children’s Data: we may collect information about children if they have opened an account with us with parental consent or if you provide us in relation to a product or service you signed up with us (i.e., when you register children as beneficiary to an insurance product or trust service with us).</li></ul>&nbsp;<ul><li style="text-align:justify;">Relevant Individuals: upon your authorization, we may collect information about family members, beneficiaries, attorneys, attorneys-in-fact, shareholders, beneficial owners whenever applicable, persons under any trust, trustees, partners, committee members, directors, officers or authorized signatories, guarantors, other security and other individuals.</li></ul>

The Types of Data We Process

The Data we collect from you may be used for the following purposes:&nbsp;<ul><li style="text-align:justify;">Data Profiling<ul style="list-style-type:circle;"><li style="text-align:justify;">We may perform automated processing of your Data to evaluate certain aspects, in particular to analyze or predict an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements.</li></ul></li></ul>&nbsp;<ul style="list-style-type:circle;"><li style="text-align:justify;">Customer Engagement<ul style="list-style-type:circle;"><li style="text-align:justify;">We use your contact details with us to communicate with you about your relationship with us. We may ask for feedback, surveys or polls about our products and services.</li><li style="text-align:justify;">We may send you email or mobile notifications, telephone calls, or newsletters about product and services enhancements and account security reminders.</li><li style="text-align:justify;">You have the right to opt out from this form of communications with you or choose another means for which we can contact you.</li></ul></li></ul>&nbsp;<ul style="list-style-type:disc;"><li style="text-align:justify;">Marketing<ul style="list-style-type:circle;"><li style="text-align:justify;">We may use your information for us to send out campaigns of commercial products and services we hope you find interesting, relevant, and useful.</li><li style="text-align:justify;">We want to establish a more personalized relationship with you by providing you offers that would suit your lifestyle and needs.</li><li style="text-align:justify;">We perform data analysis on results of our marketing campaigns to measure their effectiveness and relevance.</li><li style="text-align:justify;">You have the right to withdraw your consent or unsubscribe from receiving personalized offers.</li></ul></li></ul>&nbsp;<ul style="list-style-type:disc;"><li style="text-align:justify;">Due Diligence and Regulatory Compliance<ul style="list-style-type:circle;"><li style="text-align:justify;">We may use your data to evaluate your eligibility for Bank products and services.</li><li style="text-align:justify;">In assessing your ability to repay your loans, we conduct credit risk and investigation and reporting on your credit history and account updates.</li><li style="text-align:justify;">We use your account details when you instruct us to make a payment or fulfill an investment order.</li><li style="text-align:justify;">We use automated processes and data science solutions for faster decision-making in granting loan products.</li><li style="text-align:justify;">We may use the details you provided to contact you to verify the identity or authority of Relevant Individuals or representatives who contact the Bank or may</li><li style="text-align:justify;">We process your data in compliance with legal obligations and statutory requirements by BSP, and other regulatory agencies.</li></ul></li></ul>&nbsp;<ul style="list-style-type:disc;"><li style="text-align:justify;">Business Insights<ul style="list-style-type:circle;"><li style="text-align:justify;">We perform data analysis and reporting based on your data and how we operationalize to aid our management make better decisions.</li><li style="text-align:justify;">We analyze your behavioral data, your interactions with our products and services, and our communications with you to aid us understand the areas for improvement and development.</li><li style="text-align:justify;">We analyze transactional data performed through our third-party service providers and partners in order to determine how we can jointly improve our products and services for you.</li></ul></li></ul>&nbsp;<ul style="list-style-type:disc;"><li style="text-align:justify;">Data Quality<ul style="list-style-type:circle;"><li style="text-align:justify;">We shall process your data in compliance with the data quality standards imposed by BSP. We shall obtain additional information about you from government institutions or credit bureaus to improve the quality of your data with us. We may contact you to ensure accuracy and integrity of your information in our data processing systems.</li></ul></li></ul>&nbsp;<ul style="list-style-type:disc;"><li style="text-align:justify;">Protection and Security<ul style="list-style-type:circle;"><li style="text-align:justify;">We process your data for account protection against cybercrime, identity theft, estafa, fraud, financial crimes such as money laundering, terrorism financing, and tax fraud.</li><li style="text-align:justify;">We use certain Data, including but not limited to name, age, nationality, IP address, home address, and other transactional data to conduct profiling for detection of suspicious activity on your account.</li><li style="text-align:justify;">We may employ artificial intelligence and machine learning in real-time detection of suspected fraudulent activities on your account.</li><li style="text-align:justify;">We may reset your password or temporarily hold your online banking account to protect you from detected suspected fraudulent activities.</li></ul></li></ul>

How we Use your Data

Your Data can only be accessed by authorized personnel in a role-based manner following the principles of proportionality and legitimate “need-to-know”.

Who can Access your Data

When you provide your Data, you also help us comply with our statutory and contractual obligations with other financial institutions. On the basis of legitimate business interests, we may also share your data externally with our partners for value-added services you may find useful and relevant on top of your account with us. For contractual and value-added service data sharing agreements, we employ standardized model clauses as recommended by NPC to ensure protection of your data. Below are the disclosures required by the government entities, other regulatory authorities, and financial institutions:&nbsp;<ul><li style="text-align:justify;">BSP, Anti-Money Laundering Council (AMLC)<ul style="list-style-type:circle;"><li style="text-align:justify;">We are subjected to mandatory disclosures to the AMLC under Republic Act 9160 or the Anti-Money Laundering Act of 2001, as amended, when there is probable cause that the deposits or investments involved are in anyway related to unlawful activities or money laundering offenses.</li><li style="text-align:justify;">BSP mandates disclosures and reporting in compliance with its issuances for the protection of the integrity of the banking sector.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Bureau of Internal Revenue (BIR)<ul style="list-style-type:circle;"><li style="text-align:justify;">We may conduct random verification with the BIR in order to establish authenticity of tax returns submitted to us.</li><li style="text-align:justify;">The BIR may inquire into bank accounts of the following: a) a decedent in order to determine his gross estate; b) a taxpayer who has filed an application to compromise his tax liability on the ground of financial incapacity; and c) a taxpayer, information on whose account is requested by a foreign tax authority.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Credit Information Corporation (CIC)<ul style="list-style-type:circle;"><li style="text-align:justify;">The Credit Information Systems Act (RA 9510) mandates us to submit your credit data to the CIC and share the same with other accessing entities and special accessing entities authorized by the CIC.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Judicial and Investigative Authorities<ul style="list-style-type:circle;"><li style="text-align:justify;">We may be mandated to disclose certain Data upon service of legal court orders (i.e. unexplained wealth under Section 8 of RA 3019) or express legal request from police, public prosecutors, courts, or dispute resolution providers allowed by law.</li><li style="text-align:justify;">In these cases, we will notify you of the disclosure to the requesting government authority, subject to limitations imposed by law.</li><li style="text-align:justify;">Any person or entity to whom the Bank is under an obligation or otherwise required to make disclosure pursuant to legal process or under the requirements of any Philippine Law, regulation, court order or agreement entered into, binding on or applying to the Bank, or agreement entered into by the Bank, whether such legal process, obligation, request, requirement, agreement or guidance may be existing currently or created in the future.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Other Regulatory Authorities<ul style="list-style-type:circle;"><li style="text-align:justify;">Regulatory authorities when such other persons or entities we may deem as having authority or right to such disclosure of information as in the case of regulatory agencies, government or otherwise, which have required such disclosure from us and when the circumstance so warrant.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Financial Institutions<ul style="list-style-type:circle;"><li style="text-align:justify;">To fulfill payments and services, we may have to share your information with correspondent banks, network payment processors (i.e. Visa, Mastercard, American Express, JCB), stockbrokers, fund managers, portfolio service providers, or to any financial institution, processing agent, intermediary, clearing house, issuer, borrower, underwriter, dealer, seller, registrar, registry, paying and collecting agent, custodian, depository, underwriter, fund manager, fund provider, insurer, credit card company, acquiring company, securities and investment services provider, trustee, or any other person who will be involved in the transactions, Services, or any banking/credit or financial activities or with whom the Data Subject has or proposed to or is required to have dealings.</li><li style="text-align:justify;">We disclose your Data with insurers, insurance brokers, or providers of deposit or credit protection for protection against all kinds of risks.</li><li style="text-align:justify;">For purposes of credit investigation, consumer reporting, or for reports of credit history, account updates and fraud prevention, we may share your data with reference agencies such as the Credit Card Association of the Philippines (CCAP), and the Bankers Association of the Philippines (BAP).</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Value Added Services<ul style="list-style-type:circle;"><li style="text-align:justify;">We may disclose your Data to our partners who collaborate with us to provide services to you and provide joint communications that we hope you find of interest.</li><li style="text-align:justify;">Through our digital channels, you may instruct other mobile financial technology applications to retrieve your account information, initiate payments, or cash-in from your account with us via our Application Programming Interface (API) facility.</li><li style="text-align:justify;">In the course of the Bank’s business, we may also disclose your Data to the following authorized personnel, including, but not limited to, an agent, broker, adviser, contractor or third party service provider who provides administrative, mailing, telemarketing, direct sales, telecommunications, call center, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, information security, anti-fraud, payment, debt collection, credit or business information, reference or other background checks, leads and referrals, nominee or securities clearing, consulting service, or other services to the Bank. o We may also share your Data, as set out in the Bank’s corporate data sharing policy, within the Bank’s and among the Bank’s subsidiaries and affiliates including its corporate stockholders and their respective parent companies, affiliates, and subsidiaries (the "Affiliate Entities"), including but not limited to, cross-selling and for other purposes as set out in this Privacy Notice, and to identify and inform You of products and services provided by the Bank and the Affiliate Entities that may be of interest to You.</li><li style="text-align:justify;">We may also share your Data for compliance to any law, regulations, government requirement, treaty, agreement, policy or as required by or for the purpose of any court legal process, examination, inquiry, audit, or investigation of any authority. This applies notwithstanding any non-disclosure agreement.</li></ul></li></ul>&nbsp;<ul><li style="text-align:justify;">Assignees/Relevant Individuals<ul style="list-style-type:circle;"><li style="text-align:justify;">We may also share your Data to enable an actual or proposed assignee of the Bank, or participant or sub-participant or transferee of the Bank's rights in respect of the Data Subject or any other Relevant Individual, of all or any part of the assets or business of the Bank, to evaluate or consummate a transaction intended to be the subject of the assignment, transfer, participation, or sub-participation.</li><li style="text-align:justify;">Your data may be shared to any party giving or proposing to give a guarantee or third-party security to guarantee or secure the Data Subject's obligations or those of any Relevant Individual.</li></ul></li></ul>

How we may Share your Data

In line with our commitment to keep your information secure, we design our services with your safety in mind. All electronic storage and transmission of data is protected with appropriate security tools and technologies. We also have dedicated teams to look after your information security and privacy.&nbsp;To further sustain our security posture, we have implemented appropriate technical and security safeguards and robust policy framework that are kept up-to-date in accordance with the relevant technological developments and regulatory requirements.

How we Protect your Data

The Data we process are stored in secure and encrypted Bank-managed environments, devices, and media. For third party-managed environments, we employ BSP-sanctioned security protocols and procure BSP approval prior to deployment.

How we Store your Data

We will retain your Data in accordance with the BSP Regulations.&nbsp;<ul><li style="text-align:justify;">Retention period for transaction records shall be five (5) years from the date of transaction except where specific laws and/or regulations require a different retention period, in which case, the longer retention period is observed.</li></ul>&nbsp;<ul><li style="text-align:justify;">For financial data and documents which indicate taxable transactions, data shall be preserved for ten (10) years per BIR Regulation.</li></ul>&nbsp;For all other types of records and documents, we shall keep your data as long as it is necessary: a) for the fulfillment of the declared, specified, and legitimate purposes, or when the processing relevant to the purposes has been terminated; b) for the establishment, exercise or defense of legal claims; or c) for legitimate business purposes, which shall be in accordance with the standards of the banking industry.

How long we Retain your Data for

After the expiration of the imposed retention period, we will either:&nbsp;<ul><li>securely and permanently delete or destroy the relevant personal data; or</li></ul>&nbsp;<ul><li>anonymize or de-identify them.</li></ul>

How we Dispose your Data

When we process your personal data, you are afforded certain rights under the DPA. These include:&nbsp;<ol style="list-style-type:decimal;"><li style="text-align:justify;">Right to be Informed. You may demand the details as to how your personal data is being processed or have been processed by the Bank, including the existence of automated decision-making and profiling systems.</li><li style="text-align:justify;">Right to Access. Upon written request, you may demand reasonable access to your personal data, which may include the contents of your processed information, the manner of processing, sources where they were obtained, recipients and reason of disclosure.</li><li style="text-align:justify;">Right to Rectify. You may dispute inaccuracy or error in your personal data in the Bank systems through our contact center representatives.</li><li style="text-align:justify;">Right to Object. For personal data processed based on Consent or on Legitimate Interest of the Bank, you may, upon demand, suspend, withdraw, or remove your personal data for further processing. This includes your right to opt-out to any commercial communication or advertising purposes from the Bank.</li><li style="text-align:justify;">Right to Erasure or Blocking. Based on reasonable grounds, you have the right to suspend, withdraw or order blocking, removal or destruction of your personal data from the Bank's filing system, without prejudice to the Bank continuous processing for commercial, operational, legal, and regulatory purposes.</li><li style="text-align:justify;">Right to Data Portability. You have the right to obtain from the Bank your personal data in an electronic or structured format that is commonly used, subject to the Bank’s internal procedures.</li><li style="text-align:justify;">Right to be Indemnified for Damages. You have the right to be indemnified for any damages sustained due to such violation of your right to privacy through inaccurate, false, unlawfully obtained or unauthorized use of your information.</li><li style="text-align:justify;">Right to File a Complaint. If you feel that your personal data has been misused, maliciously disclosed, or improperly disposed, or that any of your data privacy rights have been violated, you have a right to file a complaint with our Data Protection Officer (“DPO”) and/or with the NPC through <a href="http://www.privacy.gov.ph" target="_blank" rel="noopener noreferrer">www.privacy.gov.ph</a></li></ol>

Your Rights under the DPA

Whenever necessary, UnionDigital may revise or update this Privacy Notice. We shall inform you of any changes or revisions by placing the date of the latest version on top of this page. We encourage you to regularly check this page to ensure you are aware of the latest updates to this Notice.&nbsp;You may view previous versions of this Privacy Notice <a href="https://uniondigitalbank.io/en/privacy-policy-v1-1" target="_blank" rel="noopener noreferrer">here</a>.

Updates to this Privacy Notice

If you have any questions or comments regarding this Privacy Notice or the processing of your personal data, you may contact us by writing to our DPO:&nbsp;Data Protection OfficeUnionDigital Bank Inc.&nbsp;Address: 41/F, Meralco Ave. cor. Onyx &amp; Sapphire Roads, Ortigas Center, UnionBank Plaza, Pasig City, Metro Manila, 1605 PH&nbsp;Email: <a href="mailto: dpo@uniondigitalbank.io" target="_blank" rel="noopener noreferrer">dpo@uniondigitalbank.io</a>

Contact our Data Protection Officer

UnionDigital Bank takes our consumers’ privacy and data security seriously and will share your information only with your consent or as otherwise permitted by law.

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