Your Privacy Matters

1. Introduction

This Privacy Policy describes how Pahiram Technologies, Inc. (“Pahiram,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects personal information obtained through the Pahiram.ph platform, including all subdomains (collectively, the “Platform”), and related mobile applications and services.

This policy is governed by the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and all applicable issuances of the National Privacy Commission (NPC).

By accessing or using the Platform, you consent to the collection and processing of your personal information as described in this policy. If you do not agree, please do not use the Platform.

2. Information We Collect

2.1 Information You Provide

• Account Registration: Full name, email address, mobile phone number, password, profile photo.
• KYC (Know Your Customer) Verification:Government-issued identification documents including but not limited to: Philippine Passport, Driver’s License, Philippine National ID (PhilSys), SSS ID, PhilHealth ID, Unified Multi-Purpose ID (UMID), Voter’s ID, and Postal ID. This includes the document image, document number, and any information extracted from the document.
• Payment Information:GCash account details, Maya account details, bank account information, credit/debit card details (processed and stored by our third-party payment processors — we do not store full card numbers), billing address.
• Listing Information: Item descriptions, photographs, pricing, availability, pickup/delivery location, item specifications and condition.
• Booking and Transaction Information: Rental dates, pickup/return details, communication between users, transaction amounts.
• Communications: Messages sent through the Platform, support requests, feedback, reviews, and ratings.
• Organization Information: For organization/business accounts: business name, business registration documents, business address, authorized representatives.

2.2 Information Collected Automatically

• Usage Data: Pages viewed, features used, search queries, clicks, time spent on pages, referring URLs.
• Device Information: Device type, operating system, browser type and version, screen resolution, unique device identifiers.
• Location Information: Approximate location derived from IP address. Precise location only if you explicitly grant permission through your device settings.
• Log Data: IP address, access times, error logs, request/response data.
• Cookies and Similar Technologies: See Section 7 (Cookies and Tracking) and our separate Cookie Policy for details.

2.3 Information from Third Parties

• Identity Verification Providers: Results of KYC checks performed through our verification partners.
• Payment Processors: Transaction status, payment confirmations, and fraud detection signals.
• Social Login Providers: If you register or log in using a third-party service (e.g., Google), we receive your name, email address, and profile picture as permitted by your settings with that provider.

3. How We Use Your Information

We process your personal information based on the following legal bases under the Data Privacy Act of 2012:

4. Data Sharing and Disclosure

We do not sell your personal information. We share information only in the following circumstances:

4.1 With Other Users

• Lenderssee the renter’s first name, profile photo, verified status, and rental request details.
• Renterssee the lender’s first name, profile photo, verified status, listing details, and approximate pickup location. Full address is shared only upon confirmed booking.
• Reviews and Ratings are visible to all users.

4.2 With Service Providers

• Payment Processors: GCash, Maya, and banking/card payment providers to process transactions.
• Identity Verification Providers: To perform KYC checks on lenders and, when required, on renters.
• Cloud Infrastructure Providers: For hosting, storage, and computing services.
• Communication Providers: For sending emails, SMS, and push notifications.
• Analytics Providers: For anonymized usage analytics.

All service providers are bound by data processing agreements that require them to protect your information and use it only for the purposes we specify.

4.3 For Legal Reasons

We may disclose your information if required to:

• Comply with a legal obligation, court order, or government request.
• Enforce our Terms of Service or other policies.
• Protect the rights, property, or safety of Pahiram, our users, or the public.
• Detect, prevent, or address fraud, security, or technical issues.

4.4 In Dispute Resolution

When a dispute arises between users, relevant transaction information, communications, and evidence submitted by both parties may be shared with the other party and with Pahiram’s dispute resolution team.

4.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you before your information becomes subject to a different privacy policy.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law.

Upon deletion of your account, we will delete or anonymize your personal information within 30 days, except where retention is required by law.

6. Your Rights Under the Data Privacy Act

As a data subject under RA 10173, you have the following rights:

1. Right to Be Informed— You have the right to know how your personal information is being collected and processed. This policy serves as that notice.
2. Right of Access— You may request a copy of your personal information held by Pahiram.
3. Right to Correction— You may request correction of inaccurate or incomplete personal information.
4. Right to Erasure or Blocking— You may request deletion or blocking of your personal information when it is incomplete, outdated, false, unlawfully obtained, or no longer necessary for the purpose for which it was collected. Subject to legal retention requirements.
5. Right to Data Portability— You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
6. Right to Object— You may object to the processing of your personal information, including processing for direct marketing purposes.
7. Right to File a Complaint— You may file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise your rights, contact our Data Protection Officer (see Section 13). We will respond to your request within 30 days.

7. Cookies and Tracking

We use cookies and similar tracking technologies to operate the Platform, remember your preferences, understand how you use the Platform, and improve your experience. For full details, see our Cookie Policy.

You can manage your cookie preferences through your browser settings or through our cookie consent banner. Note that disabling certain cookies may affect the functionality of the Platform.

8. Children’s Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child has provided personal information to Pahiram, please contact our Data Protection Officer.

9. International Data Transfers

Your personal information is primarily stored and processed in the Philippines. In some cases, your information may be transferred to and processed in other countries where our service providers operate (e.g., cloud infrastructure providers).

When we transfer personal information outside the Philippines, we ensure that:

• The receiving country has adequate data protection standards as recognized by the NPC, or
• Appropriate safeguards are in place, such as data processing agreements with standard contractual clauses.

10. Security Measures

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest.
• Secure storage of KYC documents with restricted access.
• Role-based access controls for employees and service providers.
• Regular security assessments and vulnerability testing.
• Secure payment processing through PCI DSS-compliant payment partners.
• Automated monitoring for unauthorized access attempts.
• Incident response procedures for data breaches.

No system is 100% secure. If you become aware of any unauthorized access to your account, notify us immediately.

In the event of a personal data breach, we will notify the NPC and affected data subjects within 72 hours as required by NPC Circular No. 2016-03, where the breach is likely to result in serious harm to the data subject.

11. Third-Party Links

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies before providing them with your personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Post the updated policy on the Platform with a new “Last Updated” date.
• Notify you via email or in-app notification.
• Obtain your renewed consent where required by law.

Your continued use of the Platform after the changes become effective constitutes your acceptance of the updated policy.

13. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Data Protection Officer
Pahiram Technologies, Inc.
Email: privacy@pahiram.ph

You may also file a complaint with the:

National Privacy Commission
3rd Floor, Philippine International Convention Center (PICC)
CCP Complex, Pasay City, Metro Manila
Website: https://www.privacy.gov.ph
Email: info@privacy.gov.ph