Privacy Policy

Last Updated: November 30, 2025

This Privacy Policy explains how Kredit Hero Pte Ltd (Singapore) and Kredit Hero Inc. (Philippines) (collectively, "Floowed", "we", or "us") collect, use, and disclose information when you use our website and SaaS platform (the "Service"). By using the Service, you consent to the data practices described in this policy.

1. our role: Controller vs. Processor

To clarify our responsibilities regarding the data we process:
For our Direct Clients (Lenders/Banks): We act as a Data Controller. We collect your business contact details and account information to manage our business relationship, billing, and support.
For Borrower Data: We act as a Data Processor. When you (the Lender) upload documents, financial records, or IDs of your borrowers to the Service, we process this data strictly on your behalf and in accordance with your instructions. You are responsible for obtaining the necessary consent from your borrowers to upload their data to Floowed.

2. Information we collect

2.1 Information You Provide to UsAccount Information: When you register, we collect your name, business email, phone number, job title, and company details.
Billing Information: We collect payment details (via our third-party payment processors). We do not store full credit card numbers on our servers.
Borrower Data: As part of the Service, you may upload documents containing Personally Identifiable Information (PII) of your loan applicants (e.g., ID cards, bank statements, tax returns).

2.2 Information Collected AutomaticallyUsage Logs: We collect information about how you interact with our platform, including IP addresses, browser types, access times, and pages viewed.
Cookies: We use cookies to maintain your session, authenticated state, and site preferences.

3. How we use Information

We use the information we collect for the following purposes:
To Provide the Service: To digitize documents, run workflows, and facilitate your lending operations.
Billing & Administration: To process payments and send administrative alerts (e.g., invoices, system updates).
Security: To detect and prevent fraud, abuse, or security incidents.
Product Improvement (Aggregation): We may use anonymized and aggregated data (data that is stripped of all personal identifiers) to analyze usage patterns, train our algorithms, develop new features, and compile industry benchmarks.

4. Sharing and Disclosure

We do not sell your data. We only share data in the following circumstances:
Service Providers: We engage trusted third-party vendors to assist in providing the Service. This includes:Cloud Hosting: Reputable infrastructure providers (e.g., Google Cloud, AWS) for secure data storage.
Payment Processors: (e.g., Stripe) for billing.
Legal Compliance: We may disclose information if required by law, subpoena, or regulation (e.g., complying with a request from the Bangko Sentral ng Pilipinas, MAS, or other competent authorities).
Business Transfers: If Floowed is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. International data transfers

Floowed is a global SaaS platform with headquarters in Singapore.
Global Processing: By using the Service, you acknowledge that your data may be transferred to and processed in countries outside of your country of residence, including Singapore, the United States, and the Philippines.
Transfer Mechanisms: For data transferred out of the European Economic Area (EEA), the United Kingdom, or Switzerland, Floowed ensures adequate protection by relying on Standard Contractual Clauses (SCCs) approved by the European Commission or other relevant legal frameworks to ensure your data remains protected to a standard comparable to GDPR.

6. Data Security

We take the security of your data seriously, especially given the nature of financial documents.
Infrastructure: Customer Data is hosted using reputable, industry-standard third-party cloud infrastructure providers (such as Google Cloud Platform, AWS, or Azure) that maintain industry-standard security certifications (e.g., SOC 2 or ISO 27001).
Encryption: Data is encrypted in transit (using TLS/SSL) and at rest (using industry-standard encryption protocols).
Access Controls: Access to Borrower Data is restricted to authorized personnel and is logged.

7. Data Retention

Account Data: We retain your account information for as long as your account is active and for a period thereafter to comply with tax/legal obligations.
Borrower Data: We retain Borrower Data only for as long as instructed by you (the Client). Upon termination of your subscription, we provide a 30-day export window, after which data is securely deleted in accordance with our data disposal policies.

8. Your Global Privacy Rights

Depending on your location (e.g., the European Economic Area (EEA), California, or APAC), you may have specific rights regarding your personal data, including:
Right to Access & Portability: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate data.
Right to Deletion ("Right to be Forgotten"): Request deletion of your personal data, subject to our legal obligations to retain records.
Right to Restrict Processing: Ask us to limit how we use your data.

Notice to Borrowers: If you are a borrower whose data was uploaded to Floowed by a Lender, please contact the Lender directly. We act as a Data Processor and can only process data rights requests under the instructions of the Lender (the Data Controller).

9. Contact Us (Data Protection Officer)

If you have questions about this Privacy Policy or our data practices, please contact our Data Protection Officer (DPO):

Kredit Hero Pte. Ltd.
trading under floowed

14 Robinson Road 08-01A
Far East Finance Building
Singapore 048545

Email: hello@floowed.com

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