Privacy Policy

Last Updated: July 23, 2026

This Privacy Policy explains how Evgeny Zhuravkin, doing business as PinoyLoads.com, an Individual Entrepreneur registered under the laws of Georgia (country), Identification Number 322737384 ("PinoyLoads," "we," "us," or "our"), collects, uses, stores, shares, and protects personal data.

For the purposes of applicable data protection law, Evgeny Zhuravkin is the controller of the personal data described in this Policy. Questions and privacy requests may be sent to support@pinoyloads.com.

This Policy applies to PinoyLoads.com, order processing, customer support, My PinoyLoads, and related services. It applies alongside our Terms and Conditions.

We process personal data in accordance with the Law of Georgia on Personal Data Protection. The EU General Data Protection Regulation (GDPR), UK data protection law, or other local privacy laws may also apply to particular users or processing activities.

1. Personal Data We Collect

We collect personal data directly from senders, from payment and service providers, and automatically when our website and services are used.

1.1 Information provided by a sender

When a sender places an order, uses My PinoyLoads, or contacts support, we may collect:

• the sender's email address;
• the recipient's mobile number, subscriber number, or service account number;
• the selected telecommunications network or service provider;
• the selected top-up, load, promo, or other digital product;
• information included in a customer support message;
• an optional recipient label entered in My PinoyLoads, such as "Mom," "Tita," or a name; and
• any additional information voluntarily provided when resolving an order, refund, security, or support issue.

Users must not enter health information, government identification numbers, financial information, passwords, or other sensitive personal information in recipient labels or ordinary support messages unless we specifically request information that is necessary to resolve a matter.

1.2 Order and service information

We generate and process information associated with an order, which may include:

• order and transaction reference numbers;
• order date and time;
• product, amount, currency, and telecommunications network;
• delivery, cancellation, refund, and processing status;
• order status history and user-facing operational comments;
• support and resolution history;
• chargeback or payment-dispute information; and
• fraud-prevention and security results.

Order information becomes personal data when it is linked or reasonably linkable to a sender, recipient, email address, mobile number, service account number, device, or other identifier.

1.3 Information received from PayPal

Payments are processed by PayPal. We do not directly collect or store a full payment-card number or card security code.

PayPal may provide us with information needed to confirm and service a transaction, including:

• payment status and transaction reference;
• payer name;
• payer email address;
• billing or account address, where provided by PayPal;
• amount, currency, and payment time; and
• information relating to a refund, reversal, dispute, or chargeback.

PayPal processes payment information under its own privacy terms. Information received from PayPal is used only to process and support orders, prevent fraud, respond to payment disputes, and protect legal rights. Our monthly small-business turnover reporting is based on aggregated figures; we do not retain identifiable PinoyLoads order records for that reporting purpose unless a particular record is separately required by law.

1.4 Technical, device, and security information

When the website or My PinoyLoads is used, we may automatically process:

• IP address and approximate IP-based location;
• browser type and version;
• device and operating-system information;
• language, time zone, and date/time information;
• pages, actions, and referral information;
• cookies and similar identifiers;
• authentication and session information; and
• server, access, error, and security logs.

We use this information to operate the website, protect My PinoyLoads, prevent abuse, investigate errors, and detect fraudulent or unauthorised activity.

When a visitor arrives through an external website or a tagged link, we may record campaign parameters, such as utm_source, and the referring domain in a server-side session. We use this information to understand how visitors find PinoyLoads and to attribute an order to its traffic source. Where a full referring URL is not necessary, we retain only the relevant source, domain, and campaign information.

1.5 Information received from other sources

We may receive transaction, delivery, network, error, or status information from PayPal, Smart Communications, Globe Telecom, DITO Telecommunity, MaxMind, and other providers used to complete or secure a transaction.

2. Recipient Information Provided by a Sender

A sender may provide a mobile number or service account number that belongs to another person. The recipient may not be the person purchasing the top-up.

We process recipient information only as reasonably necessary to:

• identify the destination of the requested top-up;
• transmit the request to the selected telecommunications provider;
• confirm or troubleshoot delivery;
• display recent recipient and order information to the sender in My PinoyLoads;
• provide customer support;
• prevent fraud and misuse; and
• establish, exercise, or defend a legal claim.

Our legal basis is the performance of the service requested by the sender and our important legitimate interests in delivering that service accurately, maintaining service integrity, providing support, and preventing fraud.

Because recipient information is normally obtained from the sender rather than directly from the recipient, this Policy also serves as our publicly available notice concerning that processing. A recipient may contact support@pinoyloads.com to ask whether we process information concerning them. We may request information necessary to verify identity and will protect the rights and personal data of both the recipient and the sender when responding.

3. My PinoyLoads and Recipient Labels

My PinoyLoads is an email-based secure-access feature. It may display recent orders and recent recipient identifiers associated with the sender's email address. It is not a public directory.

A sender may add, edit, or remove an optional label for a recipient. Labels are associated with the sender's My PinoyLoads profile and are not made available through My PinoyLoads to other senders. A label does not alter the recipient's telecommunications account.

We process My PinoyLoads information to provide the feature requested by the sender, improve convenience for repeat orders, protect access to order information, and prevent unauthorised access.

Authentication links, tokens, cookies, and sessions are processed only for their technical validity period, until they are used, expire, are revoked, or are replaced, and for any additional period reasonably necessary to investigate security incidents. Users should not forward or publish a My PinoyLoads access link.

4. Purposes and Legal Bases

We process personal data for the following purposes and legal bases:

We do not send promotional marketing emails unless the recipient has separately opted in. Order confirmations, delivery updates, security notices, refund messages, and support replies are transactional messages and are not promotional marketing.

Where we rely on legitimate interests, we consider the necessity of the processing, its effect on the individuals concerned, their reasonable expectations, and the safeguards available to protect them.

5. Automated Fraud Screening and Order Decisions

We use internal systems and third-party fraud-prevention services, including MaxMind, to evaluate transaction and security risk. Depending on the transaction, these systems may consider IP-based location, transaction consistency, payment signals, order frequency, device or browser signals, prior fraud indicators, and similar security information.

A high-risk result may cause an order to be delayed, referred for review, refused, cancelled, voided, or refunded. We do not intentionally use special-category personal data, such as health, religion, ethnicity, political views, or biometric identification data, to make these decisions.

If an automated or substantially automated decision has a legal, financial, or similarly significant effect, the affected person may contact support@pinoyloads.com to request human review, provide relevant information, express their point of view, or contest the result. We may withhold details that would enable fraud, compromise security, expose another person's data, or reveal protected fraud-detection methods, to the extent permitted by law.

6. How We Share Personal Data

We do not sell or rent personal data. We disclose personal data only as reasonably necessary for the purposes described in this Policy.

6.1 Payment processing

• PayPal processes payments, payment confirmations, refunds, reversals, disputes, and chargebacks.

6.2 Telecommunications providers

• Smart Communications, Inc.;
• Globe Telecom, Inc.; and
• DITO Telecommunity Corporation.

We work directly with these providers. We transmit the recipient number or account identifier, selected product, and the limited transaction information necessary for the provider to apply and confirm the top-up.

6.3 Hosting, infrastructure, and backup services

• Vultr, operated by The Constant Company, LLC, provides cloud hosting and infrastructure in the United States.
• Hostinger provides backup and related hosting infrastructure located in the United Kingdom.

These providers process hosted or backed-up data on our behalf under their service terms and applicable data-processing arrangements.

6.4 Email services

• Google Workspace / Gmail is used to send and receive transactional email and customer-support communications. Email content may include the sender's email address, order reference, delivery status, support messages, and other information necessary to respond.

6.5 Fraud prevention

• MaxMind and similar security services may receive an IP address and limited transaction or device information to evaluate fraud and security risk.

6.6 AI-assisted support and automation

We use AI-assisted services to help classify, draft, route, summarise, and respond to customer-support requests and to support internal service automation. These providers may include:

• OpenAI;
• Anthropic; and
• Z.AI, provided by JINGSHENG HENGXING TECHNOLOGY PTE. LTD.

Depending on the support request, limited message content and relevant order context may be processed by one or more of these providers. This may include a support message, order reference, delivery status, sender email address, or recipient number where that information is necessary to investigate or resolve the request.

We seek to minimise the information sent to AI providers and do not intentionally provide full payment-card numbers, card security codes, passwords, or unrelated personal data. AI output may be reviewed, corrected, or rejected by PinoyLoads personnel or systems before action is taken. Users should not include unnecessary sensitive information in support messages.

6.7 Professional advisers, authorities, and legal disclosures

We may disclose limited information to professional advisers, payment-dispute participants, courts, law-enforcement bodies, regulators, tax authorities, or other competent authorities where disclosure is legally required or reasonably necessary to establish, exercise, or defend legal rights, protect safety, investigate fraud, or comply with a lawful request.

If the ownership or operation of PinoyLoads changes, personal data may be disclosed as part of a legitimate business reorganisation or transfer, subject to appropriate confidentiality and data-protection safeguards.

7. International Data Transfers

PinoyLoads is operated from Georgia (country), while some service providers and recipients are located in other countries. Depending on the service and transaction, personal data may be processed in or transferred to:

• Georgia, where PinoyLoads is operated;
• the United States, including for Vultr infrastructure and certain payment, security, Google, OpenAI, and Anthropic services;
• the United Kingdom, where Hostinger backup infrastructure is located;
• the Philippines, where Smart, Globe, and DITO process recipient information to deliver top-ups;
• Singapore, in connection with Z.AI; and
• other locations in which the named providers lawfully operate their infrastructure or subprocessors.

We make international transfers only where necessary for the purposes described in this Policy and use legally recognised safeguards where required. Depending on the applicable law and provider, safeguards may include data-processing agreements, contractual confidentiality and security obligations, adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.

Where consent is legally required for a specific transfer, we will request it separately. Merely visiting the website is not treated as blanket consent to all international transfers.

8. Data Retention

We do not retain identifiable personal data indefinitely or merely because storage is technically possible.

8.1 Orders and My PinoyLoads

We retain identifiable order data for up to 24 months from the order date. This may include the sender's email address, recipient number, order details, timestamps, delivery status, status history, user-facing comments, and associated My PinoyLoads activity.

After this period, the identifiable information is deleted or irreversibly anonymised so that it can no longer reasonably be linked to a sender or recipient.

8.2 Recipient labels

An optional recipient label is retained until:

• the sender removes it; or
• 24 months have passed since the recipient was last used or the label was last updated,

whichever occurs first. Labels are not retained as tax or accounting records.

8.3 Support, fraud, and disputes

Support communications and fraud-prevention information are normally retained for no longer than 24 months after the related order or the closure of the support matter.

Where a particular refund, chargeback, fraud investigation, complaint, court proceeding, regulatory request, or other legal claim is open, we may restrict and retain the minimum information necessary until the matter and any applicable review or appeal period have ended. The additional information is then deleted or anonymised unless another lawful ground requires its continued retention.

8.4 Technical logs, authentication data, and cookies

Technical logs, authentication records, and security information are retained only for their operational validity period and for the period reasonably necessary to maintain service integrity, investigate incidents, prevent repeated abuse, and comply with applicable law. Older operational logs are routinely deleted or overwritten.

8.5 Backups

Encrypted backups are maintained under a rolling disaster-recovery schedule and are automatically overwritten according to that schedule. Personal data deleted from the active service may remain in a protected backup until the relevant backup is overwritten. Backups are isolated from ordinary production use and are used only for disaster recovery, security, and service restoration.

8.6 Aggregated turnover information

We may retain aggregated monthly turnover and statistical information for tax reporting, financial administration, service measurement, and business planning. Information is not personal data under this Policy where it has been irreversibly aggregated or anonymised and cannot reasonably be used to identify a buyer or recipient.

9. Cookies and Similar Technologies

We use cookies and similar technologies for the following purposes:

• Essential and security technologies: to operate the shopping cart, maintain the server-side session, protect forms, provide secure My PinoyLoads access, prevent fraud, remember necessary service choices, and store the user's cookie-consent preference.

Essential technologies are required for the website and services to operate and cannot always be disabled through our systems. A user may configure their browser to block cookies, but parts of the website or My PinoyLoads may then fail to work correctly.

We do not currently use Google Ads advertising or conversion-measurement cookies. If we introduce Google Ads or another optional advertising or measurement technology, we will update this Policy and, where required by applicable law, request consent before that technology is activated.

The cookie-consent notice allows a visitor to accept or reject non-essential technologies. Where a visitor has given consent, the visitor may withdraw or change that choice through the cookie-preference controls made available on the website or through applicable browser controls. Withdrawing consent does not affect the lawfulness of processing that occurred before withdrawal.

If optional third-party technologies are introduced, the relevant provider may process cookie, device, referral, or usage information under its own privacy terms. We do not use cookie consent as the legal basis for collecting information that is strictly necessary to process an order, remember a consent choice, or secure the service.

10. Data Security

We use technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful processing. These measures include, as appropriate:

• encrypted transmission using current TLS/HTTPS technology;
• access controls and limitation of access according to operational need;
• authentication and session-security controls;
• logging of relevant access and security operations;
• separation of production and backup functions;
• provider and processor selection;
• minimisation of data disclosed to service providers; and
• procedures for investigating and responding to suspected security incidents.

No online service can guarantee absolute security. Users are responsible for protecting access to their email account and for not sharing My PinoyLoads access links or other authentication information.

If a personal-data incident is likely to create a significant risk or harm, we will notify the competent authority and affected individuals where and within the time required by applicable law.

11. Your Privacy Rights

Subject to applicable law, a person whose personal data we process may have the right to:

• receive information about our processing of their personal data;
• access personal data and receive a copy;
• correct, update, or complete inaccurate or incomplete data;
• request termination of processing, deletion, or destruction of data;
• request blocking or restriction of processing;
• withdraw consent at any time where processing is based on consent;
• object to direct marketing;
• receive or transmit certain data in a structured, commonly used, machine-readable format where data portability applies;
• request human involvement and contest a significant automated decision;
• receive information about recipients and international transfers; and
• lodge a complaint with the State Audit Office of Georgia, a competent data-protection authority, or a court.

To exercise a right, contact support@pinoyloads.com and describe the request. We may request information reasonably necessary to confirm identity, identify the relevant records, prevent unauthorised disclosure, and protect another person's rights.

For requests governed by Georgian law, we will normally act or provide a reasoned response no later than 10 working days after receiving the request, unless a different period or a legally permitted extension applies. Where GDPR applies, we will respond within the applicable GDPR period, normally one month.

The right to deletion is not absolute. We may refuse or limit deletion where continued processing has another lawful basis, is required by law, is necessary to protect another person's rights, or is necessary to establish, exercise, or defend a legal claim. If only limited retention is necessary, we may block the information from ordinary use rather than continue using it for all original purposes.

There is no charge for an ordinary privacy request. Applicable law may permit a reasonable fee or refusal where a request is manifestly unfounded, excessive, or repeatedly made.

12. Children

PinoyLoads is a payment-based service intended for adults aged 18 or older. We do not knowingly request or collect personal data directly from children for their own use of the service.

If we learn that a child has directly provided personal data without valid authorisation, we will take reasonable steps to delete or restrict it. A parent or legal guardian may contact support@pinoyloads.com.

A mobile number belonging to a minor may be entered by an adult sender as a top-up recipient. In that situation, we process only the information necessary to deliver and support the top-up and apply heightened care to any request concerning that information.

13. Third-Party Websites and Services

Our website may link to third-party websites, applications, telecommunications providers, payment services, or other resources. Their processing is governed by their own terms and privacy policies when they act as independent controllers. We are not responsible for unrelated processing carried out independently by a third-party website merely because PinoyLoads links to it.

14. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, technology, providers, or our services. The current version will be posted at https://pinoyloads.com/privacy, and the "Last Updated" date will be changed.

Where a change materially affects the purposes of processing, legal bases, categories of recipients, retention periods, or individual rights, we will provide additional notice where required by law.

15. Contact and Complaints

Please use the subject line "Privacy Request" when contacting us about personal data.

If a concern is not resolved, an individual may lodge a complaint with the State Audit Office of Georgia, another competent supervisory authority where applicable, or a court in accordance with applicable law.