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Impact Banking Platform — Terms of Service (Trial)

By creating an account, you agree to the following terms:

1. Trial Period: Your 30-day trial provides full access to the Impact Banking platform. No payment information is collected during the trial.
2. Acceptable Use: The trial environment is for evaluation purposes. You agree not to process real financial transactions or store real customer data during the trial period.
3. Data Handling: Demo/test data created during the trial may be migrated to your production environment upon subscription. We do not share your data with third parties.
4. Regulatory Compliance: The platform is designed to support BSP, AMLA, and RA 10173 compliance. However, regulatory responsibility remains with the subscribing institution.
5. Termination: Either party may terminate the trial at any time. Upon expiry, your environment will be suspended (not deleted) for 30 additional days to allow subscription or data export.

Full terms available upon request. Contact legal@pocketpass.app.

Data Privacy Notice — Republic Act 10173

In compliance with the Philippine Data Privacy Act (RA 10173), we inform you:

1. Data Collected: Institution name, type, registration number, administrator contact details (name, email, phone), and usage analytics.
2. Purpose: To provision and maintain your platform trial environment, communicate service updates, and provide technical support.
3. Storage: All data is stored in encrypted, access-controlled infrastructure. Personal data is processed in accordance with the National Privacy Commission guidelines.
4. Third Parties: We do not sell or share your personal information. Infrastructure providers (hosting, email) process data under strict data processing agreements.
5. Your Rights: You may request access, correction, or deletion of your personal data at any time by contacting our Data Protection Officer at dpo@pocketpass.app.
6. Retention: Account data is retained for the duration of your subscription plus 1 year, or until you request deletion.

For the full privacy policy, contact dpo@pocketpass.app.

IT Outsourcing Disclosure for BSP-Supervised Institutions

By using Impact Banking as a cloud-based Banking-as-a-Service platform, your institution is entering into a material outsourcing arrangement as defined by BSP Circular 899 (Technology Risk Management Framework) and related BSP Memoranda.

Key obligations your institution must fulfil:

• BSP Notification: BSP-supervised institutions must notify the Bangko Sentral prior to outsourcing critical IT functions. This includes core banking systems, transaction processing, and data storage.
• Due Diligence: Your institution must conduct due diligence on Impact Banking as a service provider, including assessing our security controls, business continuity plans, and compliance with data privacy laws.
• Service Level Agreements: A formal SLA should be established between your institution and Impact Banking. Enterprise subscribers receive a dedicated SLA; other tiers operate under our standard service terms.
• Risk Management: Your institution retains full responsibility for managing risks associated with this outsourcing arrangement, including operational risk, data privacy risk (RA 10173), and regulatory compliance risk.
• BSP Examination Access: The BSP retains the right to examine and audit outsourced functions. Impact Banking will cooperate with BSP examinations as required.

Note: Impact Banking provides the technology platform only. All regulatory responsibilities — including BSP licensing, capital adequacy, consumer protection (BSP Circular 808), and AML compliance (RA 9160) — remain with your institution.

Questions? Contact compliance@pocketpass.app