Andale Privacy Policy

1. Information Andale Collects

Andale collects the following categories of information:

(a)Account and contact information: the User's name, email address, mobile number, and the profile information created when the User signs in with Google or Apple.

(b)Identity verification data: the government-issued identification document the User uploads (choosing from the ID types supported in the app), including the front and back images captured during verification.

(c)Biometric data: a live selfie captured during identity verification, and the biometric template derived from it for the purpose of liveness detection and face-matching against the User's uploaded ID. Section 3 describes how this data is specifically processed, including the optional consent under which a User's selfie may be kept for research.

(d)Booking and transaction data: the User's Listings, Bookings, messages with other Users, payment confirmation photos, and Footprint posts.

(e)Location data: the location the User sets or searches to find gear nearby, and the pickup location set for a Listing, where applicable.

(f)Condition photographs: photos taken at hand-over and return of a rented item.

(g)Device, log, and usage data: the User's IP address, device type, operating system, app version, and how the User interacts with the app, collected automatically.

2. How Andale Uses Information

Andale uses personal data to: operate and provide the Platform, including matching Renters and Providers; verify the User's identity and prevent fraud; process Bookings, payments, and refunds; send the User account notices, Booking updates, and verification codes by email, SMS, or in-app notification; keep the Platform secure, including detecting suspicious logins and misuse; troubleshoot and improve the app; enforce Andale's Terms & Conditions and Key Policies; and comply with Andale's legal obligations.

Andale may also use de-identified data, from which personal identifiers have been removed so that it cannot reasonably be used to identify a User, for research and analytics, including to study and improve the detection of fraudulent or tampered identity documents. Andale does not use identifiable identity document information for research. Selfies and biometric data are used for research only with the User's separate, optional consent, as described in Section 3.

3. Biometric Data and Identity Document Processing

Biometric data and government-issued identification numbers are treated as sensitive personal information under the Data Privacy Act. Andale processes them only with the User's separate, explicit consent, given during the identity verification step. This consent is distinct from the User's acceptance of the Terms & Conditions and is given through an affirmative action, such as ticking a box that is not pre-selected.

The User's selfie and the biometric template derived from it are processed by a third-party biometric verification provider, Face++ (operated by Megvii), acting on Andale's behalf, solely for liveness detection (confirming the User is a real person, not a photo or mask) and face-matching (confirming the selfie matches the uploaded ID). Unless the User gives the optional research consent described below, Andale does not keep the selfie or biometric template after verification is completed. Based on the provider's published privacy policy, the provider processes images only to return a result and deletes or anonymizes them afterward, and does not retain them.

Optional research consent. Separately from the consent above, the User may choose to allow Andale to keep their selfie and the biometric template derived from it to study and improve the detection of AI-generated or fake faces. This consent is optional and is given through a separate checkbox that is not pre-selected. Declining it, or withdrawing it later, does not affect the User's identity verification or access to the Platform. If the User consents, Andale stores this data separately from the User's account, under a pseudonymous identifier, with encryption and restricted, logged access. It is used only for this purpose, is not shared with third parties, and is not used to train the models of Andale's verification provider. The User may withdraw this consent at any time by contacting Andale using the details in Section 12, and Andale will delete the data within 30 days of the withdrawal.

The User may withdraw consent to biometric processing for identity verification at any time by contacting Andale. Withdrawing that consent prevents the User from completing identity verification, and therefore from booking or listing on the Platform.

4. Legal Basis for Processing

Andale processes personal data on the following legal bases: the User's consent, particularly for biometric data, identity documents, and the optional research use of selfies and biometric data; the necessity of processing to perform Andale's contract with the User under the Terms & Conditions; Andale's legitimate interests in securing the Platform and preventing fraud, including through the use of IP addresses and device data, and in researching and improving fraud detection using de-identified data; and compliance with legal obligations, including under the Internet Transactions Act and tax-related recordkeeping requirements.

5. Data Sharing & Disclosure

Andale shares information with:

(a)Other Users, to the extent necessary to complete a Booking. For example, a Provider sees a Renter's verified name and Passport tier when reviewing a booking request.

(b)Service providers, including Andale's identity verification provider (Section 3), payment gateway provider, and cloud infrastructure and hosting providers, which host Andale's authentication, database, storage, and messaging infrastructure.

(c)Law enforcement or courts, in response to a valid legal process, such as a subpoena, court order, or formal law enforcement request, including in connection with a suspected fraud report as described in Andale's Key Policies. Andale does not disclose a User's personal information directly to another User outside of a valid legal process.

(d)Regulators or government agencies, where required by Philippine law.

Andale does not sell personal data to third parties.

6. Cross-Border Data Transfer

Andale uses third-party cloud infrastructure and hosting providers to host its authentication, database, file storage, and messaging infrastructure. These providers, as well as the biometric verification provider, may store or process personal data on servers located outside the Philippines. Andale's database is hosted in Hong Kong, and uploaded files, such as identification documents and photographs, are stored in the United States. The biometric verification provider processes data on servers in the United States or Canada, and its operator is headquartered in China.

Where personal data is transferred outside the Philippines, Andale remains responsible for it under the Data Privacy Act and uses only providers with contractual and technical safeguards, such as encryption and access controls, that provide a level of protection comparable to that required under Philippine law.

7. Data Retention

Andale retains personal data only for as long as necessary for the purposes described in this Policy, or as required by law:

(a)Selfie and biometric template: not retained by Andale once verification is completed. Andale keeps only the verification result (verified or not, and the date). The selfie and template of a User who has given the optional research consent in Section 3 are kept for up to 12 months, or until the User withdraws consent, whichever is earlier, and are then deleted.

(b)Government ID images: for as long as the account remains active, and for 1 year after the account is closed, to support fraud reports and valid legal requests.

(c)Booking, payment, and transaction records: for 10 years, to comply with tax and bookkeeping requirements of the Bureau of Internal Revenue.

(d)Messages and condition photographs: for 1 year after the Booking is completed, or longer while a dispute or fraud report is open.

(e)IP address and device logs: for 12 months.

(f)Inactive accounts: an account with no login activity for 2 years may be closed and its data deleted or anonymized, after prior notice to the User's registered email.

After these periods, personal data is deleted or anonymized, except where a longer period is required by law or necessary for an ongoing legal claim.

8. Data Security

Andale applies reasonable organizational, physical, and technical measures to protect personal data, including encrypted storage, restricted access to verification data, and image cropping and compression applied to every upload. No method of storage or transmission is completely secure, and Andale cannot guarantee absolute security.

If a personal data breach occurs that is likely to put Users at risk of serious harm, Andale will notify the National Privacy Commission and the affected Users within 72 hours of becoming aware of the breach, and will take steps to contain the breach and reduce its impact.

9. User Rights & Account Deletion

Under the Data Privacy Act, the User has the right to: be informed that their personal data is being processed; access their personal data; correct inaccurate data; object to processing; withdraw consent, where processing is based on consent; request the deletion or blocking of their data, subject to legal retention requirements; obtain a copy of their data in a commonly used electronic format (data portability); and lodge a complaint with the National Privacy Commission. To exercise these rights, the User may contact Andale using the details in Section 12.

Account deletion. The User may delete their account at any time in the app by going to Profile > Settings (gear icon) > Account > Request Account Deletion, or by sending a request to the email address in Section 12. Andale processes deletion requests within 30 days. A deletion request may be put on hold while the User has an active Booking, a pending payout, or an open dispute or fraud report.

Upon deletion, Andale deletes or anonymizes the User's personal data, including any selfie kept under the optional research consent, except data Andale is required to retain under Section 7, such as transaction records required by tax law. Reviews and Footprint posts may remain on the Platform with the User's name replaced by "Deleted User."

10. Children's Privacy

The Platform is not intended for use by anyone under 18 years old, consistent with the eligibility requirement in Andale's Terms & Conditions. Andale does not knowingly collect personal data from anyone under 18. If Andale becomes aware that it has done so, it will take steps to delete that data.

11. Changes to This Policy

Andale may update this Privacy Policy from time to time. Andale will notify Users of material changes by posting notice within the app before the change takes effect. Continued use of the Platform after the effective date constitutes the User's acceptance of the updated Policy.

12. Contact Us

Users with questions about this Privacy Policy, or who wish to exercise their rights under the Data Privacy Act, may contact Andale's Data Protection Officer, at contact@andaleph.com.