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Privacy Policy

Last updated: 2/26/2026

1. Overview

Confirmi is a merchant risk assessment platform designed to help e-commerce sellers reduce Return-to-Sender (RTS) losses, failed deliveries, and fraudulent transactions by analyzing historical order outcomes.

Confirmi processes limited customer data strictly for fraud prevention, delivery reliability analysis, and merchant operational risk management.

Confirmi operates in compliance with the Philippine Data Privacy Act of 2012 (RA 10173) and applies industry-standard security safeguards.

2. Categories of Data Processed

When a merchant connects their Pancake account via OpenAPI, Confirmi may process the following customer-related data:

Identifiers

  • Phone number
  • Customer name

Delivery Information

  • Delivery address

Order Outcome Metrics

  • Order count
  • Successful order count
  • Failed / RTS order count
  • Order timestamps

Confirmi does not collect:

  • Payment card details
  • Banking information
  • Conversation/chat history
  • Product contents beyond what is required for risk context
  • Internal Pancake trust or moderation flags

3. Purpose of Processing

Customer data is processed exclusively to:

  • Generate delivery reliability and RTS risk assessments
  • Detect patterns of repeated failed deliveries across participating merchants
  • Identify high-risk transactions before shipment
  • Support fraud prevention and operational decision-making

Confirmi does not use this data for:

  • Marketing or advertising
  • Behavioral profiling unrelated to fraud prevention
  • Resale to third parties

4. Aggregation and Cross-Merchant Analysis

Confirmi may aggregate customer order outcome data across participating merchants.

To protect privacy:

  • Phone numbers are normalized and cryptographically hashed for cross-merchant matching.
  • Merchant identities are not disclosed to other merchants.
  • Individual merchant performance breakdowns are not shared.

When a risk lookup occurs, merchants receive aggregated statistics only, such as:

"This customer has placed 33 total orders across 2 participating merchants, with a 54% successful delivery rate."

No other merchant-specific data is revealed.

5. Address & Name Processing

Customer names and delivery addresses are processed solely for:

  • Identifying duplicate patterns (e.g., repeated RTS to the same address)
  • Detecting risk clusters (e.g., same address used across multiple failed transactions)
  • Supporting merchant-level fraud detection models

Confirmi does not publicly expose names or full addresses to other merchants.

Where feasible, Confirmi applies:

  • Partial masking
  • Tokenization
  • Hash-based matching for cross-merchant analytics

6. Lawful Basis for Processing

Processing is based on:

  • Legitimate interest of merchants in preventing fraud and reducing financial loss
  • Merchant authorization when integrating Pancake accounts
  • Contractual necessity for providing Confirmi's services

Merchants remain responsible for informing their customers that order data may be processed for fraud prevention purposes.

7. Data Minimisation & Proportionality

Confirmi adheres to data minimisation principles:

  • Only data necessary for risk modeling is processed
  • No excessive personal information is collected
  • Access to personal data is strictly role-restricted

8. Data Security Safeguards

Confirmi implements technical and organisational measures including:

Technical Safeguards

  • HTTPS (TLS 1.2+) encrypted transmission
  • Encryption at rest
  • One-way hashing of phone numbers for cross-merchant matching
  • Restricted database access
  • Role-based access control (RBAC)
  • API key encryption and secure storage

Organisational Safeguards

  • Limited internal access to production data
  • Access logging and monitoring
  • Controlled deployment processes
  • Immediate revocation of access for departing personnel

9. Data Sharing & Third Parties

Confirmi does not:

  • Sell personal data
  • Share raw personal data with third parties
  • Expose full names or addresses across merchants

Data is processed strictly within Confirmi's infrastructure.

10. Data Retention

Customer data is retained only for as long as:

  • The merchant maintains an active Confirmi subscription; or
  • The data remains relevant for fraud prevention and risk modeling

Upon merchant termination, data may be deleted or anonymized subject to legal obligations.

11. Incident Management

Confirmi maintains procedures for:

  • Security incident detection
  • Containment and investigation
  • Notification of affected parties where required by law

12. Compliance Framework

Confirmi aligns with:

  • Philippine Data Privacy Act of 2012 (RA 10173)
  • Secure API integration best practices
  • SaaS security standards for data protection

While Confirmi is not currently ISO-certified, security practices follow commonly accepted SaaS security principles.

13. Contact Information

For privacy inquiries:

Confirmi

Email: info.confirmi.ph@gmail.com

Contact: +63 917 553 4881