Effective Date: May 27, 2025

Elite Recovery Solutions ("ERS," "we," "us," or "our") is dedicated to safeguarding the privacy and security of the personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website at www.eliterecovery-solutions.com, interact with our services, or engage with us in financial recovery activities.

By using our website or providing us with your personal information, you agree to the terms of this Privacy Policy.

1. Who We Are

Elite Recovery Solutions is a financial recovery agency committed to facilitating the recovery of outstanding receivables on behalf of our clients. We operate in strict compliance with all applicable laws and regulations, most notably the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

2. Information We Collect

We collect personal information that is necessary to perform our financial recovery services, meet our legal obligations, and operate our website. The types of personal information we may collect include:

a. Information You Provide Directly to Us:

• Contact Information: Your name, address, email address, and phone number(s).

• Payment Information: Details you provide when making payments online (e.g., bank account details, credit card numbers). Please note that we typically use secure third-party payment processors who handle these details directly, and we do not store full payment card information on our servers.

• Correspondence Information: Any information you share when communicating with us via email, phone, web forms, or mail (e.g., inquiries, disputes, payment arrangements).

b. Information We Obtain from Third Parties: As a financial recovery agency, we frequently receive and process information from third parties, primarily our clients (the original creditors) and other legitimate sources. This may include:

• Receivable-Related Information: Original customer's name, account number, outstanding receivable amount, original loan or service agreement details, payment history, and other relevant financial transaction data.

• Identification Information: National ID number, SSS number, TIN, birthdate, or other identifiers provided by the original customer or obtained through legitimate verification processes.

• Contact and Location Information: Updated contact details or residential/business addresses obtained through lawful methods from credit bureaus, public records, or other authorized data sources, primarily for locating individuals.

• Background Information: Information relevant to your ability to pay or your financial circumstances, as legally and legitimately available from third-party sources.

c. Information Collected Automatically (Website Usage Data): When you visit our website, we may automatically collect certain information about your device and Browse activity using cookies and similar technologies. This includes:

• IP Address: Your device's unique internet protocol address.

• Browser Type and Version: Details about the web browser you are using.

• Operating System: The operating system of your device.

• Referring/Exit Pages: The website you came from and the website you navigate to after leaving ours.

• Pages Viewed: The specific pages you visit on our website.

• Time and Date of Visit: The duration of your visit.

3. Purposes for Which We Collect and Process Your Information

We collect and process your personal information for the following legitimate purposes, in line with the principles of transparency, legitimate purpose, and proportionality under the DPA:

• Financial Reconciliation: To identify and locate customers, communicate with you regarding your outstanding receivable, verify your identity, negotiate payment arrangements, process payments, and recover the outstanding receivable on behalf of our clients.

• Account Management: To manage your receivable account with us, maintain accurate records of communications, payments, and disputes.

• Compliance with Legal and Regulatory Obligations: To comply with all applicable laws, regulations, legal processes, and governmental requests, including the Philippine Data Privacy Act, anti-money laundering laws, and consumer protection regulations.

• Fraud Prevention and Security: To detect, prevent, and respond to fraud, unauthorized activities, and other security risks.

• Reporting to Credit Bureaus: To report account status and payment history to credit bureaus, where legally permitted and applicable.

• Website Improvement: To understand how users interact with our website, troubleshoot technical issues, and enhance our website's functionality and user experience.

• Customer Support: To efficiently respond to your inquiries, disputes, and requests.

• Legal Action: To initiate or defend legal claims or actions related to receivables, if necessary.

4. Lawful Basis for Processing (Under the Philippine Data Privacy Act)

We process your personal information based on one or more of the following lawful bases as required by the DPA:

• Performance of a Contract: The processing is necessary for the performance of our contract with our clients (the creditors) to collect receivables, and in some cases, for the original contract between you and the creditor.

• Compliance with Legal Obligation: The processing is necessary for compliance with a legal obligation to which Elite Recovery Solutions is subject (e.g., regulatory reporting, responding to court orders).

• Legitimate Interests: The processing is necessary for the purposes of the legitimate interests pursued by Elite Recovery Solutions or by a third party (e.g., our clients), provided that such interests are not overridden by your fundamental rights and freedoms as a data subject. Our legitimate interests include efficient receivable recovery, fraud prevention, and ensuring the accuracy of records.

• Consent: In limited cases, where required by law or when other lawful bases do not apply, we may obtain your explicit consent for specific processing activities (e.g., for certain optional communications). You have the right to withdraw your consent at any time, subject to legal and contractual limitations.

5. Disclosure and Sharing of Your Information

We may share your personal information with the following parties, only to the extent necessary for the purposes outlined in this Privacy Policy:

• Original Creditors: The clients on whose behalf we are collecting receivables.

• Service Providers: Third-party vendors and service providers who assist us in our operations, such as payment processors, IT support, data storage providers, and analytics providers. These providers are contractually obligated to protect your information and use it only for the purposes for which we disclose it to them.

• Legal and Professional Advisors: Our attorneys, auditors, and other professional advisors.

• Government Authorities and Regulators: When required by law or a valid legal process (e.g., court order, subpoena, regulatory inquiry).

• Successors in Business: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will ensure the new entity adheres to similar privacy standards.

We will not sell, rent, or trade your personal information to third parties for their independent marketing purposes without your explicit consent.

6. Data Security

We implement reasonable and appropriate organizational, physical, and technical security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are in place to uphold the security principle of the DPA and include:

• Secure networks and internal access controls.

• Encryption for sensitive data transmission (e.g., via SSL/TLS).

• Regular security assessments and vulnerability testing.

• Employee training on data privacy and security.

• Strict data retention and disposal policies.

While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period may vary depending on the nature of the information, the specific legal obligations we are subject to, and our legitimate business needs. Generally, we will retain receivable-related information for the duration of the collection process and for a period thereafter as required by law or our clients' instructions.

When your personal information is no longer needed, we will securely dispose of it through anonymization or destruction methods.

8. Your Data Privacy Rights (Under the Philippine Data Privacy Act)

As a data subject under the DPA, you are empowered with significant rights over your personal information. Elite Recovery Solutions is committed to upholding these rights:

• Right to be Informed: You have the right to be informed whether personal information pertaining to you is being or has been processed by us.

• Right to Object: You can object to the processing of your personal information, especially in cases of direct marketing, automated processing, or profiling.

• Right to Access: You have the right to demand reasonable access to your personal information, including the categories of data processed, the purposes of processing, the recipients of your data, and information about automated decision-making that significantly affects you.

• Right to Rectification: You can dispute the inaccuracy or error in your personal information and request us to correct it promptly and accordingly.

• Right to Erasure or Blocking: You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal information from our filing system upon discovery and substantial proof that the personal information is incomplete, outdated, false, unlawfully obtained, or utilized for unauthorized purposes.

• Right to Damages: You have the right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal information.

• Right to Data Portability: You have the right to obtain a copy of your personal information in an electronic or structured format, if processed by electronic means, allowing you to transfer it to another data controller.

• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided below. We may require you to verify your identity before processing your request.

9. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies (e.g., web beacons, pixels) to enhance your Browse experience, analyze website traffic, and understand user behavior.

• Cookies are small text files placed on your device by websites that you visit.

• How We Use Them: We use cookies for essential website functionality, analytics (e.g., Google Analytics to understand traffic patterns), and potentially for security purposes.

• Your Choices: Most web browsers are set to accept cookies by default. You can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed. However, disabling cookies may affect the functionality of our website.

10. Links to Third-Party Websites

Our website may contain links to third-party websites for your convenience (e.g., for online payment processing). We are not responsible for the privacy practices or content of these third-party websites. We encourage you to review the privacy policies of any website you visit before providing them with your personal information.

11. Children's Privacy

Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us, and we will take steps to delete such information from our records.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. We will post the updated Privacy Policy on our website with a new "Effective Date." We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

13. Contact Us / Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data privacy practices, please contact our Data Protection Officer:

Data Protection Officer

Elite Recovery Solutions

Email: dpo@eliterecoverysolutionsph.com

Phone: (02) 83342149 Address: 45B Kabignayan Street, Tatalon, Quezon City

We will endeavor to respond to your inquiries promptly and in accordance with applicable laws.

Privacy Policy