Wefund Lending Corp., a corporation duly organized and existing in the Philippines (“Juanhand”), protects all the data that are entrusted to us.

Before continuing, please carefully read the contents of this Privacy Policy.

This Privacy Notice outlines how Juanhand, uses, maintains and discloses your personal data in relation to the services JuanHand renders to you. Likewise, it touches upon how Juanhand safeguards your personal data. At Juanhand, we respect and strive to ensure that such is adequately protected. We shall therefor use your name and other information you have disclosed to us, only in the manner and for the purposes set out in this Privacy Policy. We will only collect your personal information where it is necessary for us to do so in and when such is relevant to our transactions with you.

The security of your personal data is important to us and we shall maintain appropriate physical, technical and organizational measures needed to ensure the security and confidentiality of your personal data. We will only keep your information for as long as we are authorized by law or as is relevant for the purposes for which it was collected.

Juanhand is committed to complying with Republic Act No. 10173 or the Data Privacy Act of 2012, and its implementing rules and regulations.

1. Collection of Personal Data

When you create a JuanHand account, or otherwise provide us with your personal information through the JuanHand application or website, or through GooglePlay, Apple’s Appstore or other downloading platforms (the “Platforms”), you may be asked, to supply or provide information, from time to time, including but not limited to, information to establish your identity (ex. name), background, addresses, contact and mobile numbers, email addresses, IP addresses, operating systems, browser types, contact details, financial data, creditworthiness information, audio recordings, and telecommunications usage data (“telco usage score”) and other information and data generated that you provide in relation to using, accessing, or availing of our products and/or services (“ Personal Data”).

We may collect and obtain these Personal Data from yourself or from variety of sources, including but not limited to your submission of your Personal Data; from any analysis of the way you use and manage your account/facility with us; from publicly available sources or registries; from government authorities, regulatory authorities and/or law enforcement agencies; from third parties or other sources; and/or from any information that is supplied and/or collected when you visit our websites which include your mobile device or computer’s IP address or from any information that is collected via cookies on some of our websites. Provided that, the same shall only be collected once you have given your consent to disclose the Personal Data and/or where not otherwise restricted;

Your Personal Data shall be used for risk management, fraud prevention, and other similar purposes as provided under Article 2 of this Privacy Policy which will aid us in providing you with better services. To illustrate, your IP address may be used for anti-fraud purposes.

We shall occasionally request for additional Personal Data, which we shall only collect after you have given your consent through responses to system prompts, which will appear after the creation of your account in relation for such request. Your submission of any information to us, our authorized agents or the Platforms expressly contains your warranty that such information is accurate and not misleading.

We reserve the right to request for additional documentation to verify the information provided by you.

We will only access and collect your personal information if you voluntarily submit the information to us or explicitly provide your consent for our access to the same. If you choose not to submit your Personal Data, or subsequently withdraw your consent to process the same, we shall respect the same. You may request for the removal of your data from our system.

If you sign up for JuanHand using your social media account, link your JuanHand account to any of your social media accounts, or use other certain available JuanHand social media features, we may access information about you which you have voluntarily provided and consented to under your social media provider in accordance with the provider’s policies. However, we undertake to manage and use the information we accessed from your social media account only for the purposes stated in this Privacy Policy and in accordance with JuanHand’s Privacy Policy.

2. Purpose of Collecting Personal Data

During the course of your availment of our service, we may utilize, process and/or disclose your Personal Data to Juanhand’s affiliates, subsidiaries and partner companies for any of the following purposes (“Permitted Purpose”):-

a. to authenticate youridentity;

b. to assess and process your applications for our products and/orservices;

c. to communicate with you including but not limited to sending you updates and reminders, responding to your inquiries and/or complaints and resolvingdisputes;

d. to manage and maintain your accounts/facilities withus;

e. to conduct credit checks to assess or verify your credit/financial worthiness and to assist other financial institutions to conduct creditchecks;

f. to evaluate your financialneeds;

g. to utilize the same for strategic alliances, cross-selling, marketing, andpromotions;

h. to maintain your credit history for present and futurereferences;

i. to detect and investigate crime, fraud or illegal activities, and to utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions, including know your customer (KYC) and regular politically exposed persons (PEP) screening purposes;

j. to respond to the requirements of a civil or criminal legal process and/or for regulatory compliance purpose and/or as required by law orregulation;

k. to collect any debt due or owing and to enforce your obligations tous;

l. to utilize and disclose the same for market research and statistical analysis and surveys with the aim of improving our products and services and productdevelopment;

m. to provide you with the information on our and third-party products and services which may be of interest toyou;

n. to compare information/data for accuracy of our record, and to verify the same with third parties;

o. to utilize the same for research, design and improvement of our products and services, operational and businessprocesses;

p. to support our business, financial and risk monitoring, planning and decisionmaking;

q. to handle complaints andqueries;

r. to utilize and disclose the same for audit, compliance and riskmanagement;

s. to transfer or assign our rights and duties under any governing terms and conditions between us andyourself;

t. to utilize the same for our outsourcing of business and internaloperations;

u. to utilize and disclose the same for securityreasons;

v. to transfer your Personal Data to foreign jurisdictions for the purpose of processing and storage and to enable any cross-border transactions, for the performance of a contract, for the purposes of legal proceedings, upon written request from a foreign regulatory or government authority or body, to protect your vital interest or where it is in the public interest to doso;

w. to process your application and assess your suitability for the program including but not limited to conducting all necessary background checks that may include credit scoring and investigation, data analytics; personal data such as but not limited to financial information from Juanhand’s partners maybe shared back to Juanhand for the purposes mentioned above;

x. to fulfil your instructions and remitpayments;

y. use voice recognition technology to collect and analyze voiceprint biometric data for the purpose of identityverification;

z. to utilize for data analytics and data profiling;and/or

aa. for any other purposes that is required or permitted by any law, regulation, order and/or guidelines.

We also use cookies for number of purposes, including but not limited to, storing your preference for certain types of information or products, for further analysis to provide products and services to you, to improve our products and/or to personalize our services to you. You may adjust the settings on your browser and/or mobile device so that you will be notified when you receive cookie or other similar tracking tools. Please refer to your browser documentation to check if the tracking tools have been enabled on your computer and/or mobile device or to disable cookies.

3. Disclosure of Personal Data

Your Personal Data, held by us, shall be kept confidential at all times. However, in order to provide you with effective and continuous products and services subject to any laws, regulations and guidelines and for the Permitted Purpose, you explicitly consent to us providing, disclosing, or

otherwise processing your Personal Data, in connection with our products and services, to the following parties, in and/or outside the Philippines:

a. Juanhand agents, holding companies, subsidiaries, affiliates andassociates;

b. professional advisers, contractors, service providers, debt collection agencies and our other agents with whom we have contractual agreements for some of our functions andservices;

c. national and local credit bureau, credit reporting agencies, credit reference agencies, rating agencies (such as Credit Information Corporation), insurers and/or insurancebrokers;

d. financial service providers in relation to the products and services that you have withus;

e. any actual or potential participants or assignee or transferee of our rights and/or obligations under any transaction between us andyou;

f. any guarantor or security provider for the products and/or services granted by us toyou;

g. any authorities or regulators, including foreign regulators for the performance of their functions, or any party as required by any law or any government, quasi-government, administrative, court ortribunal;

h. strategic/business partners with whom we have a relationship with for specific products and services;

i. third-party collectionagency;

j. any person connected to the enforcement or preservation of any of our rights under your agreements with us;and/or

k. any party authorized and/or consented by

4. Changes to Personal Data

You must keep the Personal Data provided to JuanHand up to date, and inform us of changes thereto. You are entitled to review the Personal Data that we have collected about you and request for corrections of the same. You have the right to update your Personal Data anytime. If there are any changes to your Personal Data or if you believe that the Personal Data we held about you is inaccurate, incomplete, misleading or not up-to-date, kindly write to us or email your request to our Data Protection Officer (“DPO”), setting out your name and valid I.D. number/Company number, the details of your request, together with the supporting documents. We shall correct or update the information/data as soon as possible. For the avoidance of doubt, the DPO reserves the right to request information or documents from you to verify your identity and the authenticity of the  request made and any other information relating to the corrections requested.

5. Withdrawal of Consent

You may communicate your objection to our continued use, collection, and/or other acts of processing of your Personal Data for any valid purpose and in the manner as stated at any time by contacting us at our e-mail address. This shall be your mechanism to turn off or allow the permissions that were previously granted to us.

Please note that if you communicate your objection to the processing of certain Personal Data, depending on the nature and subject of your objection, the same may affect the timeline of your

applications and/or our analysis of your creditworthiness. Our legal rights and remedies are expressly reserved in such events.

6. Removal of Personal Data

We shall retain your Personal Data, registration and transaction records with a third party data storage providers for the period necessary to fulfill the purposes outlined or up to ten (10) years in adherence with the requirements of the Bangko Sentral ng Pilipinas (BSP) and other laws and regulations; for the establishment, exercise or defense of legal claims; or for legitimate business purposes, which must be consistent with standards followed by the applicable industry.

Your Personal Data will be destroyed in irretrievable and unusable form in adherence with our physical and/or technical information security measures when retention is no longer allowed or required. The same will be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public, or prejudice the interests of the data subjects.

We reserve the right to take necessary actions if we consider that such removal or cessation would hamper our fulfillment of our obligations under applicable laws.

We shall suspend, withdraw, or order the blocking, removal or destruction of your Personal Data from our system if we become aware or reasonably suspect that the Personal Data is incomplete, outdated, false, unlawfully obtained; used for unauthorized purposes; no longer necessary for the purposes for which they were collected; or data subject withdraws consent or objects to the processing, and there is no other legal ground or overriding legitimate interest for the processing.

7. Security

We will take reasonable efforts to protect personal data in our possession or our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Security measures will be implemented and Personal Data will be processed in accordance with current data protection legislation and this Policy.

8. Portability

You have the right to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format and you have a right to request that we transfer such Personal Data to another party.

If you wish for us to transfer the Personal Data to another party, we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or the processing of the same once received by a third party. We reserve our rights to refuse the transfer if such transfer would interfere with another person’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).

9. Profiling

We are permitted to process your Personal Data and other Information for automated processing and automated decision-making upon submission of your Personal Data or upon acquisition of your consent, in connection, with the goal of assessing certain personal aspects as set out, or for compliance with any law, regulation, government requirement, treaty or policy, or as required by or

for purpose of any court, legal process, examination, inquiry, audit or investigation of any Authority. We are permitted to use the profiling for, but not limited to, certain legal and regulatory requirements, combat money laundering, terrorism financing, fraud, assessment of risk and other offenses.

10. Right under the Data Privacy Act

The Data Privacy Act (DPA) establishes that you have the following rights as a data subject:

a. You have the right to indicate your refusal or withdrawal of consent to the collection and processing of your personal data. You also have the right to be informed and to withhold your consent to further processing in case there are any changes or amendments to information given to you. Once you have notified us of the withholding of your consent, further processing of your personal data will no longer be done, unless the processing is required pursuant to a subpoena, lawful order, or as required by

b. You have the right to reasonable access to your personal data. Furthermore, you have the right to limit and prevent disclosure of your personal data and to receive notification of any possible breaches of your personal

c. You may also correct or remove any information that you think is inaccurate. You have the right to dispute any inaccuracy or error in your personal data. You may request for the correction or removal of any inaccuracy or error in your personal data by logging into your account  or making a formal request with our Data Privacy

d. You have the right to the destruction of your personaldata;

e. You have the right to damages;and

f. You have the right to lodge a complaint with the National Privacy Commission(NPC).

The rights herein above listed is not an exclusive list thereof. Please note that the enumerated rights and wording thereof is not an exact copy of those indicated in the DPA. Please check Chapter IV, Section 16 of the DPA for the exact list and rights you may have as a data subject. All the rights mentioned in such law are inherently incorporated into this Privacy Policy and may be freely exercised by the data subject.

Throughout the processing of your Personal Data, your rights under the DPA, such as the (1) right to be informed, (2) right to object, (3) right to access, (4) right to rectification, (5) right to erasure or blocking, and (6) right to damages, shall be upheld. Entities to whom we share your data will also respect the same rights.

If you would like to make any request in relation to your rights, please contact our DPO.

11. Inquiries and Complaints

You have the right to object at any time to the processing of your Personal Data to the extent permitted under the Philippine law, and to the processing of your personal data for the Permitted Purpose. Any queries, requests, concerns, complaints or exercise of your rights regarding the use of your Personal Data may be raised to the respective DPO below:

Email: privacy@juanhand.com

JuanHand commits to acknowledge your complaint in a prompt manner and will give you an estimated timeframe for when the company will respond to your complaint.

12. Changes to the Privacy Notice

Please note that we may update this Privacy Notice from time to time via posting on our website. You are advised to periodically view our website for any updates or the most current version of our Privacy Notice. If the Privacy Policy is updated, the said updated version shall apply to all of your information held and processed by JuanHand henceforth. If you do not consent to the updated terms thereby, you may contact our DPO.

13. Consent and Acknowledgement

By providing us with your Personal Data, you hereby consent to the usage, processing and/or disclosure of your Personal Data in accordance with this Privacy Notice to Juanhand, its affiliates, subsidiaries, and partner institutions such as, but not limited to, Globe Telecom Inc., SMART Communications Inc., DITO Telecommunity, etc.  ,.

If you are a corporation whereby you have provided/disclosed Personal Data of individual third- parties including but not limited to your directors, individual shareholders, employees, authorized signatories, agents, representative or otherwise, you hereby represent and warrant to us that you have the consent of such third parties and are entitled to provide their Personal Data to us to be used, processed and/or disclosed in accordance with this Privacy Notice. You also consent that Juanhand may be required to disclose your Information to the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, credit bureaus and/or any other governmental body, in compliance with its legal obligations

Version Date: March 2022