BPI Direct BanKo Privacy Policy

Maintaining your privacy is an important part of the products and services that we provide. This Privacy Policy, hereafter referred to as “Policy”, explains how we collect, protect, use, and share information when you access our websites and/or apply for and avail of our products and services. 

This Policy outlines the general practices of BPI Direct BanKo Inc. (“BanKo”) in relation to our processes and content which are made available through our network of websites, our online and mobile applications, and social media pages (collectively referred to as “websites”). This Policy also covers the privacy practices for our customers who apply for and obtain products and services from us, such as, but not limited to, deposits, loans, investments, insurance, and other such products and services that the Bank may offer from time to time.

The privacy practices described in this Policy are primarily intended for individuals in the Philippines and are designed to comply with the Data Privacy Act of 2012 (R.A. 10173) and its implementing rules and regulations. When accessing our websites and/or availing of our services from outside the Philippines, you acknowledge and agree that your information may be transferred to and processed in the Philippines following legal and regulatory standards for data protection that may differ from your current or home jurisdictions.

In designing our products, services and the processes as well as activities that support the delivery of any or all of these, BanKo proactively and appropriately identifies, assesses and addresses data privacy risks and seeks to follow the principle of “Privacy by Design” to ensure that the rights of our clients, stakeholders and the public are upheld.

When you apply for or avail of any product or service that BanKo offers or when you interact with our employees, authorized representatives, agents and service providers, we collect your personal information. This may include, among others:

• your name and personal particulars such as contact details, address, birthdate, education;
• specimen signatures;
• digital photos and biometrics;
• government ID details;
• financial information (such as income, expenses, balances, investments, tax, insurance, financial and transaction history, etc);
• employment details;
• business interests and assets;
• images via CCTV and other similar recording devices and processes which may be observed when visiting our offices and/or using our other facilities;
• voice recordings of our conversations with you

We may, as and when necessary, seek to verify or augment these information with third-party entities including government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction and, in the process, gain additional information about you.

In the course of availing our products and services, we also collect information about your transactions and dealings which include your account activities, movements and interactions with third parties such as merchants and utility companies. 

When you access our websites, we may provide information about us as well as information regarding our products and services. If you have enrolled your account as a condition of use, you may conveniently access your accounts through the website. In the course of using our network of websites and electronic platforms, we may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. We may track your location if you use our location-based content such as branch or ATM locators. We may likewise use web analytics tools, including those of third parties’, that use cookies to collect anonymous information and data generated in connection with your activities when you visit the pages and our network of websites.

We may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives, agents and service providers.

In addition, to continuously improve our digital products and services, BanKo uses trusted third-party analytics tools such as Meta Analytics (Meta SDK), Google Analytics, Firebase, and AppsFlyer. Through these tools, we may collect limited technical and interaction data, which may include:

• App usage behavior (e.g., pages viewed, taps, time spent in-app)
• Session and navigation information (e.g., screen paths, button clicks)
• Device identifiers (e.g., device ID, advertising ID)
• Operating system and device model
• App version and update history
• General location (derived from IP address)
• Crash reports, error logs, and diagnostic information
• App installation and uninstallation events
• Marketing campaign attribution data (e.g., source of app download or engagement)

These data points are collected in an aggregated, anonymized, and non-personally identifiable manner wherever possible, and are used exclusively to enhance app performance, personalize user experience, optimize marketing efforts, and ensure security monitoring of the BanKo mobile app and digital assets.

We use the information collected to deliver and provide the products and services that you have availed to:

• approve, facilitate, administer and process applications and transactions;
• respond to queries, requests and complaints and improve how we interact with you;
• send you statements, billings, notices and other such documents necessary for continued use of our products and services;
• conduct studies and researches for the purpose of reviewing, developing and improving our products and services;
• perform profile analysis, behavioral modeling and analytics to understand needs, preferences and market trends to be able to improve and recommend suitable products and services;
• reach out to you regarding products and services information, including offers, promotions, discounts, rewards; and for personalizing your experience with our various touchpoints such as branches, call center, telemarketing, email, messaging and other channels;
• determine the effectiveness of our marketing efforts and initiatives;
• provide location-based services such as finding the ATM or branch nearest to you;
• perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;
• comply with our operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, the Bangko Sentral ng Pilipinas rules and regulations, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time.
• comply with applicable laws of the Philippines and those of other jurisdictions including the United States Foreign Account Tax Compliance Act (FATCA), the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended (AMLA) and the implementation of know your customer and sanction screening checks
• comply with legal and regulatory requirements such as submission of data to credit bureaus, credit information companies, the Credit Information Corporation (CIC) (pursuant to RA No. 9510 and its implementing rules and regulations) responding to court orders and other instructions and requests from any local or foreign authorities including regulatory, governmental, tax and law enforcement authorities or other similar authorities;
• perform other such activities permitted by law or with your consent.

We may share anonymized or aggregated data with our trusted analytics service providers, namely Meta Analytics, Google Analytics, Firebase, and AppsFlyer, strictly for the purposes of:

• Monitoring app performance and detecting technical issues
• Analyzing user behavior to improve features and services
• Conducting attribution reporting for marketing campaigns
• Understanding overall trends in app usage

These service providers are contractually bound to process information in accordance with applicable data privacy laws, and they employ industry-standard security measures to safeguard collected data.

We may share your personal information with our subsidiaries, affiliates and third parties, under an obligation of confidentiality. 

• We may share personal information with various units within BPI Group of Companies in order to better understand the way you use our products and services. This will allow us to improve our services and offer you opportunities to obtain such other useful products and services that may deliver greater value to you.
• We may share information with our parent bank and affiliates to likewise offer you additional products and services that we believe you might find interesting.
• We may share with third parties that we engaged to support us in delivering our services to you. These may involve anonymous or aggregated information to help improve our products, services, and content.
• We may also engage third parties to help us operate our business. These include support in:
  • complying with legal requirements such as court orders;
  • enforcing our terms of use including, among others, our rights as creditor to customers availing of our loan or credit products, or such other applicable policies with respect to the services that we provide;
  • addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property or security of our customers or third parties;
  • to carry out all other purposes set out above.

Further, if you are, become, or apply to become a client of any other entity of the BPI Group of Companies (i.e. the Bank of the Philippines Islands and its subsidiaries and affiliates), BanKo and such other entity/ies of the BPI Group of Companies have the option, but not the obligation to, rely upon, use, and share your relevant personal and/or account information for any of the following purposes:

1. To facilitate your account opening or application with the concerned entity/ies of the BPI Group of Companies;
2. To validate, consolidate or update your customer information records and/or credit history;
3. To provide consolidated billings, deposit or investment summaries or other reports as you may request;
4. To send you reminders, announcements, promotions, offers, invitations and other notifications;
5. To enroll you in loyalty or similar client-oriented programs of the BPI Group of Companies;
6. For research purposes or to design banking, financial, securities and investment or other related products or services for your use;
7. For promotional and/or marketing activities of BPI Group of Companies or of the concerned or affiliate/s; and/or
8. To comply with a legal obligation to which BPI Group of Companies or the concerned parent bank or affiliate/s is subject.

We may transfer, store, and/or process your personal data outside the Philippines. In doing so, we will comply with the Data Privacy Act and its implementing rules and regulations.

We wish to assure you that we do not, and will not, sell personal data to any third parties. All our engagements with third parties shall be fully compliant with our obligation of confidentiality imposed on us under the applicable agreements and/or terms and conditions or any applicable laws that govern our relationship with you.

We fully recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc. Appropriately, we strive to maintain the confidentiality, integrity and availability of your personal information by employing physical, technological and procedural safeguards. We train our employees to properly handle your information. Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards. 

Additionally, we ensure that all third-party analytics tools used, such as Meta Analytics, Google Analytics, Firebase, and AppsFlyer, are integrated in compliance with the Data Privacy Act of 2012 and international best practices, with data collected stored securely and access limited to authorized BanKo personnel and trusted service providers only.

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time, remains in effect and until such time as it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes. Once the purpose for which it was collected shall have been completed, we will securely dispose of your personal information unless we are required to retain them for legal or regulatory purposes.

In respecting your rights to privacy, you may opt to tell us:

1. to inform you of what we do with your personal information;
2. to provide you with information that we currently have about you, subject to restrictions applied to us as a bank and a company operating in the Philippines by certain laws and regulations, in an easy-to-access format and easy-to-understand language; 
3. not to send you marketing materials via email or SMS, not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining, providing and completing the products or services that you have availed from us;
4. not to process your personal information upon withdrawing consent, unless processing is legally required;
5. to remove and dispose your personal information from our records, as allowed by applicable laws and regulations; 
6. to update any personal information upon your advice;
7. to electronically move, copy, or transfer it securely through available means.

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you prior to making the request.

You may lodge a complaint regarding our use of your personal information and be assured that we will address your concerns promptly. Should we fail to do so, you may address any complaint to our regulators, particularly the Bangko Sentral ng Pilipinas and the National Privacy Commission, consistent with the rights granted to you under applicable laws and regulations.

For any queries, clarifications or requests on any aspect of this Policy, the exercise of your rights pertaining to your personal information or to provide any feedback that you may have about our processing of personal information, please send us a message or visit any of our branches.

You may also reach us through these channels:

Email: bankoprivacy@bpi.com.ph

We will respond to you soonest during business hours.

Phone: (+632) 8819-6728 Mondays to Fridays, 8:30am – 5:30pm, or via (632) 889-10000

Address: DATA PROTECTION OFFICER, BPI Direct BanKo Inc., 220 Ortigas Avenue, BanKo Center, North Greenhills, San Juan City, Philippines

We may modify or amend this Privacy Policy from time to time to keep up with any changes in relevant laws and regulations applicable to us or how we collect, use, protect, store, share or dispose of your personal information. Any relevant updates will be posted on the BanKo website.

Definitions:

Personal Information/ Data – refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Sensitive Personal Information/ Data refers to personal information:

1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
2. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
3. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
4. Specifically established by an executive order or an act of Congress to be kept classified.

Parent Bank – Bank of the Philippine Islands

BPI subsidiaries and affiliates - members of the BPI Group of Companies such as, but not limited to, Ayala Plans, Inc., BPI Asset Management and Trust DBA BPI Wealth, A Trust Corporation, BPI Capital Corporation, BPI Europe, PLC, BPI Investments, Inc., BPI Remittance Centre Hong Kong Ltd., BPI Wealth Hong Kong Limited, BPI/MS Insurance Corporation, BPI AIA Life Assurance Corporation, BPI Securities Corporation, BPI Foundation, Inc. and Legazpi Savings Bank.