Privacy Policy

Datung provides microloans, salary loans, non-collateralized SME loans, collateralized loans, and related financial services to micro-entrepreneurs, salaried individuals, and small and medium enterprises in the Philippines, through our website, offices, loan officers, and field teams. This Privacy Policy explains what personal information we collect, how and why we use it, who we share it with, how long we keep it, and the rights you have over it.

This Policy applies to anyone who visits datung.io or datungapply.com, applies for or holds a loan with Datung, messages or comments on our Facebook Page, or otherwise interacts with our services (each, a "user," "you," or "data subject"). It is written to comply with the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, and, for users we serve from Singapore, the Singapore Personal Data Protection Act 2012.

This Policy is separate from, and does not replace, the privacy policies of platforms we use to reach you — including Meta's Facebook and Messenger Privacy Policy, which governs how Meta itself handles your information on its platforms.

We collect the following categories of information:

2.1 Information you give us directly

• Identity information: full name, date of birth, sex, civil status, nationality, and government-issued identification details you provide for identity verification; and, if you choose to provide them, your place of birth, education level, and religion.
• Government-issued numbers: your Tax Identification Number (TIN) and, if you provide them, your SSS/GSIS, Pag-IBIG, and PhilHealth numbers.
• Contact information: mobile number, email address, home and/or business address, and, if you provide them, alternate numbers and social media or messaging accounts.
• Family and household information you provide in your application, such as your spouse's name, mobile number and occupation, the number of children, and household size.
• Information about other people: the names, relationship to you, mobile numbers and addresses of the personal references and emergency contact you list in your application. Please tell these people that you are sharing their details with us, and for what purpose, before you do so.
• Financial and loan information: income or revenue, employment or business details, supplier details, bank accounts, loan amount requested, loan purpose, existing loans, collateral, monthly expenses, and repayment information.
• Application and underwriting information you choose to provide, including bank or e-wallet statements (such as GCash transaction history) that you upload or share so we can assess your repayment capacity.
• Your application declaration: your typed electronic signature and the date and time you signed.
• Communications you send us, including messages sent through our Facebook Messenger bot, comments on our Facebook posts, emails, and calls with our team.

2.2 Information we collect automatically

• Technical information such as IP address, device and browser type, and pages visited on our website, collected via cookies and similar technologies (see Section 8).
• Your public Facebook profile name and a platform-assigned identifier, when you message our Facebook Page or comment on our posts — provided to us by Meta as described in Section 5.

2.3 Information from third parties

• Credit and repayment information from credit information providers, credit bureaus, and our lending partners, where relevant and permitted by law.
• Information from our payment and disbursement partners confirming that a payment has been made or received.

2.4 Sensitive personal information

Some of the information above is sensitive personal information under RA 10173: your age (derived from your date of birth), civil status, government-issued identification numbers (such as your TIN, SSS/GSIS, Pag-IBIG, and PhilHealth numbers), and your religion if you choose to provide it. We process sensitive personal information only on the basis of the consent you give in the declaration you sign when you apply, or where the processing is required or allowed by law. Religion is optional and is not used to assess your application. Your age is used to apply our eligibility rules: applicants must be at least 18, and loans must be fully repaid before the borrower's 65th birthday. We do not otherwise collect health, political, or similar sensitive information, except where it is unavoidably present in a document you choose to submit.

We use personal information for the following purposes, on the legal bases indicated:

• To assess and process your loan application, including evaluating repayment capacity from information you provide (such as e-wallet transaction history) — necessary to enter into and perform a contract with you, and based on your consent where you choose to submit this information.
• To service an existing loan: sending reminders, processing payments, and managing collections — necessary to perform our contract with you.
• To communicate with you, including responding to messages sent to our Facebook Page and following up with people who comment on our posts to offer information about our products — based on your consent, given by initiating or continuing that conversation, and our legitimate interest in responding to inquiries directed at us.
• To verify your identity and prevent fraud — necessary to comply with our legal and regulatory obligations as a licensed lender.
• To comply with applicable laws and regulations, including reporting obligations to the Securities and Exchange Commission, the Bangko Sentral ng Pilipinas, and anti-money-laundering authorities.
• To improve our products and services, including through aggregated or de-identified analysis of loan performance.

Where we rely on your consent, you may withdraw it at any time as described in Section 11; this will not affect the lawfulness of anything we did with your information before you withdrew consent, and may affect our ability to continue providing you a loan or service.

Datung uses AI-assisted tools to help our underwriting team review loan applications — for example, to help analyze patterns in the financial documents you submit. These tools support, rather than replace, human decision-making: a Datung staff member reviews the assessment before any loan is approved or declined, and you may request a human explanation of a decision affecting your application by contacting us using the details in Section 12. These tools do not receive your sex, civil status, religion, age, or family and household details.

Datung operates an automated chatbot on Facebook Messenger, connected to our Facebook Page, to answer initial questions and pre-screen prospective borrowers before a human team member follows up.

When you send our Facebook Page a message, or comment on one of our posts, Meta shares the following with our chatbot, through Facebook's Messenger Platform: your name as it appears on Facebook, a platform-specific identifier for your account (which is not the same as your public Facebook profile ID), the content of the message or comment you sent, and, where applicable, the specific post or comment you engaged with.

We use this information only to: run you through a short set of qualifying questions about the loan product you're interested in (for example, whether you're asking about a business loan or a salary loan, your general financial situation, and how best to reach you); record your responses as a lead in our internal system so a member of our team can follow up; and, if you comment on one of our posts, send you a single introductory Messenger reply inviting you to continue the conversation, consistent with Meta's Private Reply feature and its 7-day window.

We do not use information collected through Messenger for advertising, and we do not sell it or share it with third parties except as described in Section 6. If you go on to formally apply for a loan, the information you provide through Messenger becomes part of your loan application record and is handled as described throughout this Policy.

5.1 Deleting your Facebook / Messenger data

You can ask us to delete the information we hold about you from a Facebook Messenger conversation or Facebook comment at any time, whether or not you go on to apply for a loan. To do so, email sales@datung.io with the Facebook name you used to contact us and the approximate date you messaged or commented, or send us a message through Messenger saying "delete my data." We will locate and delete the corresponding record from our systems, other than information we are required to keep for legal, regulatory, or fraud-prevention purposes, and will confirm to you once this is done. We aim to complete deletion requests within 30 days.

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

• Payment and disbursement partners, to send or receive loan disbursements and repayments.
• Our credit scoring and underwriting partners, to help assess creditworthiness and repayment capacity as part of the loan approval process.
• Our technology service providers, who host and process data on our behalf under contract — including cloud database and hosting providers and Meta, whose Messenger Platform we use to operate our chatbot. These providers may only use your information to provide services to us, and are contractually required to protect it.
• A third-party debt recovery partner, only for accounts that are severely overdue, and only to the extent necessary to recover the amount owed.
• Government agencies and regulators, where required by law, regulation, court order, or to establish or defend a legal claim.
• A buyer or successor, in the event of a merger, acquisition, or sale of all or part of Datung's business, subject to that party assuming the commitments in this Policy.

We require anyone we share your information with to protect it and use it only for the purpose we shared it for, through data sharing or data processing agreements consistent with NPC requirements.

Some of our service providers process and store data outside the Philippines — for example, our database infrastructure is hosted in Singapore. Where we transfer personal information outside the Philippines, we do so under contractual safeguards consistent with the Data Privacy Act's requirements for cross-border transfers, and only to providers that maintain an adequate standard of protection for your information.

Our website uses cookies and similar technologies to keep it running properly, remember your preferences, and understand how visitors use our site. You can control cookies through your browser settings; disabling them may affect how parts of our website function.

We retain personal information only for as long as necessary for the purposes described in this Policy, including to comply with our legal, regulatory, tax, and accounting obligations as a licensed lending company. Loan application and account records are generally retained for the duration of the loan relationship plus the retention period required under applicable financial regulations. Information collected through Messenger from someone who does not go on to become a borrower is retained only as long as reasonably needed to follow up with that lead, or until you ask us to delete it as described in Section 5.1.

We use appropriate organizational, physical, and technical safeguards to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access — including access controls that restrict who within Datung can view your information, and encryption of data in transit. In the event of a personal data breach that poses a real risk of serious harm, we will notify the National Privacy Commission and affected individuals within the timeframe required by law.

Under the Data Privacy Act of 2012, you have the right to:

• be informed whether, how, and why your personal information is being processed;
• access the personal information we hold about you and obtain a copy of it;
• object to processing, including processing for direct marketing;
• have inaccurate or incomplete information corrected;
• have your information suspended, withdrawn, blocked, removed, or destroyed where it is incomplete, outdated, false, unlawfully obtained, no longer necessary, or processed without a lawful basis;
• obtain your information in a structured, commonly used electronic format (data portability);
• withdraw any consent you have given;
• be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your information; and
• lodge a complaint with the National Privacy Commission.

To exercise any of these rights, contact our Data Protection Officer using the details in Section 12. We may need to verify your identity before acting on a request. Some requests may be limited where we are required by law to keep certain records, for example for regulatory, tax, or anti-money-laundering purposes; if so, we will tell you why.

If you have questions about this Policy, want to exercise any of your rights, or want to raise a concern about how we handle your personal information, you can reach our Data Protection Officer:

• Email: sales@datung.io (attention: Data Protection Officer)
• Philippines address (Dark Knight Lending Inc.): Unit 10-01, One Global Place, 25th St. cor. 5th Ave., Bonifacio Global City, Taguig City 1630, Philippines
• Singapore address (Datung Pte. Ltd.): 32 Pekin St, #05-01, Singapore 048762

If you are not satisfied with our response, you may lodge a complaint with the National Privacy Commission (privacy.gov.ph) or, for Singapore-based users, the Personal Data Protection Commission (pdpc.gov.sg).

Datung's services are intended for adults capable of entering into a binding loan agreement. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from someone under 18, we will delete it.

We may update this Policy from time to time to reflect changes in our practices or in applicable law. We will post the updated Policy on this page with a revised effective date, and, where the changes are material, we will take reasonable steps to notify you directly. See also our Terms and Conditions.