Privacy Policy

Information we collect

SureDeal may collect account information such as your name, email address, authentication identifiers, profile information, and contact information. Provider features may require business information, business URLs, phone numbers, verification information, identification documents, and uploaded images.

We may also process SureDeal transaction details, payment and transaction status, communications submitted through the service, dispute evidence, device and security information, fraud-prevention signals, and records needed to operate and protect the service.

Why we process personal data

We process information for legitimate and disclosed purposes such as authenticating users, creating and managing SureDeals, connecting customers with intended providers, facilitating payment and deposit workflows, sending service communications, preventing fraud and abuse, conducting provider verification and risk assessment, handling disputes, complying with legal obligations, providing support, and improving the service.

Where Philippine law requires consent or another specific lawful basis, SureDeal will rely on the applicable lawful basis and provide required notices.

AI, profiling, and risk assessment

SureDeal may use automated tools to analyze submitted information, public information, transaction signals, and other lawful data sources for fraud prevention, verification, risk assessment, and platform security.

Where required by applicable privacy law, users will be informed about relevant automated processing or profiling and provided applicable rights to object, withdraw consent, or request appropriate review.

Payment and financial-service providers

Payment-related information may be processed by banks, payment service providers, e-money issuers, acquirers, payment gateways, fraud-prevention providers, or other financial-service partners involved in processing, safeguarding, settling, refunding, or investigating a transaction.

SureDeal should avoid storing full payment-card credentials or other sensitive payment credentials when a qualified payment provider can process them directly. Each payment provider may process information under its own legal and privacy obligations.

How information may be shared

Information necessary to carry out a SureDeal may be displayed or shared between the customer and provider. We may also share information with service providers supporting authentication, hosting, storage, communications, payments, security, fraud prevention, verification, analytics, and customer support.

We may disclose information when required by law, court order, lawful government request, regulatory obligation, or when reasonably necessary to investigate fraud, security incidents, abuse, disputes, or threats to users or the platform.

SureDeal does not sell personal information as part of its current product design.

Data minimization, retention, and security

SureDeal should collect only information reasonably necessary for declared and legitimate purposes and use reasonable administrative, organizational, and technical safeguards appropriate to the nature of the information.

Information may be retained for as long as reasonably necessary for transactions, payment reconciliation, fraud prevention, disputes, security, legal claims, regulatory obligations, accounting, and other legitimate purposes. Different categories of information may have different retention periods.

Your privacy rights

Subject to applicable law, you may have rights to be informed, access your personal data, object to certain processing, correct inaccurate information, request erasure or blocking where warranted, obtain data portability where applicable, withdraw consent where processing depends on consent, and lodge a complaint with the National Privacy Commission.

Some information may need to be retained or processed despite a request where required for a contract, legal obligation, fraud prevention, establishment or defense of legal claims, or another lawful basis.

Cross-border processing

SureDeal may use cloud, authentication, communications, payment, analytics, or support providers whose systems or personnel are located outside the Philippines. Where personal data is transferred or accessed across borders, SureDeal should use appropriate contractual, organizational, and technical safeguards required by applicable law.

Children

SureDeal is intended for persons legally capable of entering into the relevant transactions and providing any consent required for use of the service. Age and eligibility requirements may vary depending on the transaction and applicable law.

Changes to this Privacy Policy

SureDeal may update this Privacy Policy from time to time as its services, data practices, providers, technology, or legal obligations change.

The current version may be posted in the app. For substantial or material changes, or where Philippine privacy law requires notice, consent, or an opportunity to object or withdraw consent, SureDeal will provide the required notice or choice before applying the changed processing as required by law.

A change to this Privacy Policy does not by itself authorize SureDeal to process personal data in a manner that would otherwise require a new lawful basis, notice, or consent.

Privacy contact

Before public launch, this Policy should identify SureDeal's legal entity, Personal Information Controller details, business address, Data Protection Officer or privacy contact, privacy email, applicable retention periods, relevant processors and data-sharing arrangements, effective date, and the process for exercising data-subject rights.