Privacy and Personal Data Protection Policy

for Clickgen Partners Advertising Corp. (Philippines)

 

By registering on the website https://ph.fina.guru/, which references this Privacy Policy, you accept this Privacy Policy and agree to the terms of the User Agreement set forth below.

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User Agreement (Offer) and Privacy and Personal Data Protection Policy

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1. General Provisions and Role of the Company

CLICKGEN PARTNERS ADVERTISING CORP. (CRC2438652051 Shaw Boulevard Wack-Wack Greenhills, City of Mandaluyong, Second District, National Capital Region (NCR), 1550) (hereinafter referred to as "Clickgen") is the administrator of the website https://ph.fina.guru/ acts solely as a provider of marketing and advertising services for third-party financial Partners. The website https://ph.fina.guru/ contains advertisements for financial services provided by Partners with whom CLICKGEN PARTNERS ADVERTISING CORP. has concluded agreements for the provision of advertising services by posting the content of individual Partners in the format of advertising layouts that contain a button for clicking on a hyperlink directly to the website of individual Partners in accordance with the free choice of the User for the purpose of obtaining loans.

1.1 Application on the websites of financial Partners:

• Management of credit websites or platforms
• Evaluation, approval or rejection of loan applications
• Establishment or control of lending terms, interest rates and repayment terms
• Performance of functions data controller in relation to personal information
• Ensuring the legality, reliability and availability of services offered by Partners
• Making credit decisions and providing financial advice

Clickgen only provides advertising of financial services offered by licensed or authorized financial Partners.

 

1.2 Disclaimer for the operation of the Partner's website

Clickgen adheres to reasonable commercial standards in selecting partners, including:

• Checking basic company registration and legal entity status
• Confirming stated regulatory licenses, if publicly available
• Checking the content of the partner's website for obvious misrepresentations
• However, Clickgen does not conduct comprehensive financial, operational or ongoing compliance audits
• Users are responsible for independently assessing the suitability of the partner for their specific needs

1.3 Partner Due Diligence Standards

Clickgen adheres to reasonable commercial standards in selecting partners, including:

• Verification of basic company registration and legal entity status
• Confirmation of stated regulatory licenses, if publicly available
• Review of affiliate website content for obvious misrepresentations
• However, Clickgen does not perform comprehensive financial, operational or ongoing compliance audits
• Users are responsible for independently assessing the suitability of an affiliate for their specific needs

1.4 Marketing Services Boundaries

Clickgen's marketing services are strictly limited to:

• Lead generation and customer acquisition based on the affiliate's claims
• Creation of advertising and promotional content in the format of individual ad layouts using information provided by individual affiliates
• Basic formatting and transmission of lead data
• Clickgen does not provide consulting or recommendation services regarding specific lenders
• Clickgen makes no guarantees regarding loan approval, terms or interest rates

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This Privacy Policy applies to the https://ph.fina.guru/ website, which is owned, operated and controlled solely by Clickgen. Clickgen provides marketing and advertising services by placing on the specified website advertising layouts of financial partners with a button for transition via a hyperlink directly to the website of the financial Partner. The websites of financial Partners contain the Privacy Policy of financial Partners, after reading and fully agreeing with it, Users can use the financial services of the Partner.

Each partner website may contain:

• Offers from partners who have entered into agreements with Clickgen for advertising financial services
• Forms and procedures for registering lead generation
• Bonus programs and promotions offered by partners
• Advertising and information materials (hereinafter referred to as the "Services")

1.5 Functioning of partner websites

Important: partner websites are operated as independent platforms by licensed partner service providers (and not Clickgen). Each partner website:

• Is owned, operated and controlled solely by the relevant financial partner
• Provides financial services directly to users through its own systems and processes
• Acts as a data controller in relation to all personal information collected on its website • Clickgen does not own, operate or control any partner websites

1.6 Clickgen's limited role

Clickgen advertises on its website https://ph.fina.guru/ the financial services of individual Partners with whom it is contractually linked. Clickgen does not operate or administer any partner websites. All websites, financial services, loan offers, terms, approvals or rejections are provided exclusively by the financial Partners, who are the actual operators of the websites and data controllers.

Clickgen does not:

• Provide financial services or loans and does not act as a financial intermediary.

2. Definition of terms

2.1 Clickgen as a provider of marketing and advertising services

A company that performs marketing and advertising functions to promote the services of individual Partners, maintains advertising statistics and acts solely as a data processor on behalf of the Partner.

2.2 Partners/Financial Service Providers

Licensed financial institutions or legal entities that:

• Operate their own websites and lending platforms
• Act as data controllers with respect to all personal information collected about Users
• Provide financial services directly to Users
• Are responsible for all lending decisions, terms and customer relationships
• Have a contractual relationship with Clickgen solely for the purpose of providing marketing services

2.3 User

An individual using the Partner's websites to obtain financial services, whose information may be processed as part of lead generation activities.

 

2.4 Data Controller and Data Processor

• Data Controller: Partners who determine the purposes and means of processing personal data.
• Data Processor: Clickgen processes the personal data of Users who register to access and use the website https://ph.fina.guru/.

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3. Confidentiality and data processing structure

3.1 Data collection and its purpose

Personal data sent through websites operated by Partners via lead forms is collected for the purpose of connecting users with financial service providers.

Data collection:

• Initiated by partners acting as data controllers
• Processed by Clickgen solely in accordance with the terms of Clickgen's Privacy Policy
• Used solely for the purpose of generating leads and providing financial services to users

3.2 Legal basis for processing

The legal basis for processing data includes:

• Legitimate interest: providing users with access to the relevant websites of financial service providers
• Consent: users voluntarily provide information by registering on the Clickgen website and on the relevant websites of individual financial Partners
• Contractual necessity: to ensure communication between users and partners

3.3 Data processing

Clickgen's data processing activities are limited to:

• Obtaining information about potential customers interested in the financial services of Partners
• Formatting and transmitting leads to relevant partners
• Statistical accounting and auditing for the purpose of analyzing marketing effectiveness

3.4 Data transfer and partner liability

Upon transfer of personal data to partners:

• Partners assume full responsibility as data controllers
• Partners must process data in accordance with their Privacy Policy
• Partners are responsible for all subsequent data Processing, storage and deletion
• Clickgen does not control the data and is not responsible for it.

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4. Marketing communications

4.1 Communication preferences

Users may receive marketing communications, including:

• Information about relevant financial services
• Promotional offers from Partners
• Educational content about financial products
• Service updates and improvements

Important: Marketing communications may be sent by Partners directly or by Clickgen only on behalf of Partners in accordance with their specific instructions and as a Data Processor. Clickgen does not initiate marketing campaigns on its own.

4.2 Right to opt out

Users may opt out of marketing communications in the following ways:

• Manage cookie preferences through your browser settings• Use unsubscribe links in emails
• Contact privacy@clickgen.digital
• Update preferences through Partner websites
• Contact Partners directly using their privacy contact information

Note: Users may need to opt out of each Partner separately as Partners maintain independent marketing lists and campaigns.

5. Disclaimer of Full Liability

5.1 Clickgen Limited Liability

Clickgen is not responsible for:

• The accuracy, completeness or legality of information provided by Partners
• Any financial loss, damage or claim arising in connection with the services provided by Partners
• Any misuse or unauthorized processing of personal data by Partners
• The functionality of websites, availability or security of sites operated by Partners
• Credit decisions, terms, interest rates or any results of providing financial services
• Partners' compliance with applicable laws and regulations
• Any violations of regulations or fines incurred by Partners
• Identity theft, fraud or security breaches on Partners' websites
• Partners' business, customer service or debt collection activities
• Technical failures, system downtime or data loss on Partners' systems

5.2 User Confirmation

Users acknowledge and agree to the following:

• All financial transactions and agreements are concluded exclusively with Partners
• Clickgen is not a party to any financial services agreements
• Partners are solely responsible for their own privacy policies
• Website terms of service are controlled by Partners, not Clickgen
• Any disputes must be resolved directly with the relevant Partner

5.3 Disclaimer regarding Partner websites

Clickgen provides links and referrals to Partner websites, but:

• Does not control or operate these websites
• Is not responsible for the content or functionality of Partner websites
• Cannot guarantee the availability or security of Partner websites
• Users visit Partner websites at their own risk

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6. Technical and organizational security measures

6.1 Data protection measures

Clickgen implements appropriate technical and organizational measures, including:

• Encryption of data during transmission and storage
• Access control and authentication procedures
• Regular security assessments and updates
• Security training for staff data
• Incident response and breach notification procedures

6.2 Data Data retention

Clickgen retains personal data only for the minimum period necessary to:

• complete the transfer of leads to partners
• maintain basic records for regulatory compliance
• pursue legitimate business interests (usually no more than 12 months)

6.3 International data transfers

Any international transfer of personal data is subject to appropriate safeguards, including:

• adequacy decisions by relevant authorities
• standard contractual clauses
• certification schemes or codes of conduct (where applicable)

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7. Cookies and tracking technologies

7.1 Use of cookies

The https://ph.fina.guru/ website and Partner Websites may use cookies and similar technologies to:

• basic website functionality
• analytics and performance measurement
• optimize marketing and advertising
• improve user experience

7.2 Managing cookies

Users can:

• disable non-essential cookies
• delete existing cookies at any time
• Please note that blocking essential cookies may impact the functionality of the website

7.3 Third-Party Analytics

Partner websites may use third-party analytics tools. Users should consult the privacy policies of the partners for specific information about analytics providers and opt-out mechanisms.

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8. User Rights and Data Subject Protection

8.1 Right to Information

Users have the right to:

• Know what personal data is being processed
• Understand the purpose of data processing
• Identify the actual data controller (partner/service provider)
• Receive information about the transfer and storage of data

8.2 Right to Correction

Users may request that incorrect or incomplete personal data be corrected. Such requests should be addressed to:

• For lead generation data: privacy@clickgen.digital
• For all other data: the contact details of the relevant Privacy Partner.

8.3 Right to erasure

Users may request that personal data be erased in the following cases:

• The data is no longer needed for the original purpose
• Consent has been withdrawn
• The data has been processed unlawfully
• Erasure is required to comply with legal obligations

8.4 Right to restriction and objection

Users may:

• Request restriction of processing under certain circumstances
• Object to processing on the basis of legitimate interests
• Object to marketing communications at any time

8.5 Right to data portability

If necessary, users may request their personal data in a structured, commonly used format.

8.6 Right to withdraw consent

Users may withdraw their consent at any time by contacting privacy@clickgen.digital or directly to the relevant Partner. ________________________________________

9. Compliance and Governance

9.1 Compliance with Philippine Laws

This Privacy Policy and all data processing activities are subject to:

• Republic Act No. 10173 (Data Privacy Act of 2012)
• Its Implementing Rules and Regulations
• National Privacy Commission Guidelines
• Other applicable Philippine laws and regulations

9.2 Cross-Border Compliance

For partners operating internationally, Clickgen will ensure compliance with:

• Applicable international data protection laws
• Cross-Border Data Transfer Requirements
• Partner-Specific Obligations
• Industry Compliance Requirements

9.3 Cooperation with Regulators

Clickgen will cooperate with regulators as necessary and:

• Respond to lawful requests for information
• Participate in regulatory investigations
• Make necessary changes to ensure ongoing compliance
• Maintain records in accordance with applicable legal requirements

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10. Incident Management and Data Breach Notification

10.1 Response to Data Breach

In the event of a data breach involving personal data processed by Clickgen:

• Clickgen will assess the risk and impact within 24 hours.
• The relevant partner (as data controller) will be notified immediately.
• Partners are solely responsible for notifying regulators and affected users in accordance with legal requirements.
• Clickgen's role is limited to notifying partners and cooperating with their breach response procedures.

10.2 Partner Data Breach Incidents.

In the event of data breaches on websites or systems operated by partners:

• Partners are solely responsible for detecting, assessing and reporting breaches.
• Clickgen is not responsible for, and assumes no liability for, the security of partner systems.
• Users should contact partners directly regarding any suspected data breaches.

10.3 Incident Investigation.

Clickgen maintains procedures for:

• Promptly detecting and assessing incidents
• Forensic analysis and root cause analysis
• Implementing corrective actions
• Preventing similar incidents in the future

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11. Contact Information and Complaints

11.1 Privacy Contact

For all privacy-related questions, inquiries, or complaints:

• Email: privacy@clickgen.digital
• Address: CLICKGEN PARTNERS ADVERTISING CORP., Shaw Boulevard Wack-Wack Greenhills, City of Mandaluyong, Second District, National Capital Region (NCR), 1550

11.2 Complaint Resolution

Users may also file complaints with:

• National Privacy Commission of the Philippines
• Other relevant regulatory authorities
• Partners directly for service-related issues

11.3 Response Time

Clickgen will:

• Acknowledge receipt of inquiries within 48 hours
• Provide meaningful responses within 30 days
• Engage with partners to resolve issues comprehensively

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12. Partner Screening and Relationship Management

12.1 Partner Selection Process

Clickgen follows sound commercial practices when selecting partners:

• Basic verification of company registration and regulatory licenses
• Review of partner websites for obvious compliance issues or misrepresentations
• Confirmation of compliance with partner data security standards and privacy policies
• However, Clickgen does not conduct regular operational audits and does not guarantee the performance of partners
• Users are responsible for reviewing partner credentials and assessing the quality of service

12.2 Partner Performance Monitoring

Clickgen monitors partners for:

• Basic lead delivery and technical integration performance
• Obvious signs of consumer complaints or regulatory issues
• Compliance with basic advertising and privacy standards
• However, detailed monitoring of credit practices, customer service, or business operations is beyond the scope of Clickgen

12.3 Partner Relationship Management partners

Clickgen reserves the right to terminate relationships with partners in the following cases:

• Breach of contractual obligations
• Evidence of fraudulent or illegal practices
• Failure to comply with required licenses or regulatory requirements
• However, termination of the relationship does not create retroactive liability for past actions

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13. Regulatory and Licensing Disclaimer

13.1 Clickgen Regulatory Status

Important Notice: Clickgen Partners Advertising Corp.:

• Is NOT a lender licensed under the laws of the Philippines
• Is NOT registered with the Central Bank of the Philippines (BSP)
• Is NOT subject to lending regulations
• Operates solely under general advertising and marketing regulations
• Does not require financial services licensing for its limited marketing role

13.2 Licensing Responsibilities of Partners

• Partners are solely responsible for obtaining and maintaining all necessary licenses
• Partners must comply with all applicable lending laws and regulations
• Clickgen does not verify or guarantee the licensing of affiliates beyond the basic statements made by affiliates
• Users should independently verify the regulatory status of affiliates
• Clickgen makes no guarantees regarding affiliate compliance or the accuracy of licensing

13.3 Consumer Protection Notice

Users are advised to:

• Check the lender’s license with the relevant Philippine regulatory authorities
• Read carefully and understand all the terms and conditions of the loan before making a decision.
• Familiarize yourself with your rights under Philippine consumer protection laws.
• Report any suspicious or fraudulent lending practices to the authorities.
• Seek independent financial advice if necessary.

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14. Data Minimization and Purpose Limitation

14.1 Data Collection Limitations

Clickgen’s data collection is strictly limited to:

• Basic contact information such as username, mobile number, and/or email address required for lead generation.
• Credit inquiry data provided by users.
• Technical data to ensure the functionality and security of the website.
• Prohibition of collection of sensitive personal data without explicit consent and business justification.

14.2 Restrictions on the use of data.

Personal data processed by Clickgen will NOT be used for:

• direct lending or credit decisions
• credit scoring or financial profiling
• debt collection
• sales to third parties outside the affiliate network
• marketing of non-financial products or services

14.3 Restrictions on data sharing

Clickgen will only share personal data with:

• authorized partners for legitimate lead generation purposes
• service providers operating under strict data processing agreements
• regulators where required by law
• law enforcement in accordance with applicable legal procedures

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15. Audit and transparency rights

15.1 Users’ audit rights

Users may request information about:

• specific partners who have received their personal data
• the date and method of data transfer
• the current status of data storage
• any data breaches affecting their information

15.2 Cooperation with regulators in conducting audits

Clickgen will:

• Fully cooperate with National Privacy Commission audits
• Provide access to data processing records and security documentation
• Implement changes recommended by regulators
• Maintain required records in accordance with Philippine laws.

15.3 Transparency Reporting

Clickgen will publish periodic transparency reports, including:

• Number of partnerships maintained.
• Categories of personal data processed.
• Number of regulatory inquiries received.
• Summary of incidents and breaches.
• Summary of user rights requests fulfilled.

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16. Policy Updates and Communications

16.1 Policy Changes

This Privacy Policy may be updated from time to time to:

• Reflect changes in the law.
• Implement new business practices.
• Increase transparency and clarity.
• Improve user protections.

16.2 Notification of Changes.

Users will be notified of significant changes by:

• Updates on partner websites where this Policy is published.
• Email notifications, where technically feasible.
• Clearly indicating the versions and effective date.

16.3 Continued Use.

Continued use of partner websites after the policy has changed constitutes acceptance of the updated terms. Users are advised to review this Policy regularly.

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Applicable Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of the Philippines.

Important: Clickgen Partners Advertising Corp. does not own, operate or control any websites on which Users register or provide personal information. All such websites are owned and operated exclusively by Partners who provide financial services.

Any disputes arising in connection with this Policy, the functionality of the https://ph.fina.guru/ website shall be resolved exclusively with Clickgen Partners Advertising Corp.

Last updated: August 22, 2025

Contact information: privacy@clickgen.digital