PRIVACY POLICY STATEMENT

PRIVACY POLICY STATEMENT

1.Introduction

This declaration is adopted as the Privacy Policy Statement (hereinafter referred to as "the Statement") of Hong Kong Finance Company Limited and EasyLend Finance Company Limited (“hereinafter referred to as "Hong Kong Finance and EasyLend"). The purpose of this declaration is to establish the policies and practices of Hong Kong Finance and EasyLend in its full implementation and compliance with the Guarantee Data Principle, so as to comply with the terms and provisions of the Personal Data (Privacy) Ordinance (hereinafter referred to as the "Ordinance"), and to implement the guidelines promulgated by the Hong Kong Association of Licensed Moneylenders on this Ordinance. Hong Kong Finance and EasyLend will do its part in compliance with the Ordinance and the principles laid down in this statement.



2.Purpose of using personal data

2.1 A customer needs to provide personal data to Hong Kong Finance and EasyLend from time to time when opening and/or renewing credit accounts, establishing and/or renewing credit facilities, and/or providing other financial services.

2.2 Failure to provide such personal data may result in the inability of Hong Kong Finance and EasyLend to open or renew a credit account, establish or renew credit facilities for the customer or provide other financial services to the customer.

2.3 In the normal course of business operation of Hong Kong Finance and EasyLend, for example, when a customer communicates with Hong Kong Finance and EasyLend orally or in writing, Hong Kong Finance and EasyLend collect personal data of the customer, either in the form of a document or through a telephone recording system of Hong Kong Finance and EasyLend respectively, as the case may be.

2.4 The personal data of a customer may be used for the following purposes:

  • (a)daily operation of providing credit account, credit facilities and other financial services to the customer;
  • (b)conducting credit checks at the time of application for credit and at the time of regular or special reviews;
  • (c)developing and maintaining credit scoring model of Hong Kong Finance and EasyLend;
  • (d)assisting other creditors and/ or financial institutions to make credit checks and collect debts;
  • (e)ensuring that the customer maintains ongoing creditworthiness and good standing;
  • (f)designing financial services or related products for customers;
  • (g)determining the amount of indebtedness owed to or by the customer;
  • (h)collection of debts from the customer and those providing security for the customer’s obligations;
  • (i)disclosure made by Hong Kong Finance and EasyLend for the purpose of meeting the requirements under any binding regulations, or for the purpose of following and taking guidance issued by a regulatory or other institution to which it is expected that Hong Kong Finance and EasyLend are subject;
  • (j)enabling an actual or proposed assignee of Hong Kong Finance and EasyLend, or a participant or a sub-participant of the rights of Hong Kong Finance and EasyLend in respect of customer, to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;
  • (k)marketing financial services or products provided by Hong Kong Finance and EasyLend; and
  • (l)purposes relating thereto.

Purposes listed out from paragraphs (a) to (j) (both items inclusive) and the related purposes under paragraph (l) above are “compulsory”, meaning that customers have to agree to allow Hong Kong Finance and EasyLend to use their personal information for the said purposes if they wish to use the service rendered by Hong Kong Finance and EasyLend. Purpose listed out from paragraphs (k) and the related purpose under paragraph (l) above are “optional”, meaning that customers can choose whether they allow Hong Kong Finance and EasyLend to use their personal information for the said purposes.



3.Security of Personal Data

The policy of Hong Kong Finance and EasyLend provides appropriate safeguards to ensure the security of personal data, the sensitivity of the data to be used and the damage caused by unauthorized access, so as to prevent unauthorized access, processing or other use of the data. In order to achieve a proper level of security, Hong Kong Finance and EasyLend strictly restrict the access to data consistently by providing secure storage facilities and by implementing security measures on data storage equipment. Hong Kong Finance and EasyLend will also take steps to ensure that those dealing with such information have good ethics, prudence and competence. The information will only be transmitted in a proper security manner.



4.Accuracy of Personal Data

The policy of Hong Kong Finance and EasyLend is to ensure that all data collected and processed through Hong Kong Finance and EasyLend is accurate. Hong Kong Finance and EasyLend will implement appropriate procedures to regularly check and update all personal data to ensure that the relevant information is used for the purpose of being reasonable and accurate. If a statement of opinion is contained in the personal data held by Hong Kong Finance and EasyLend, Hong Kong Finance and EasyLend will take all reasonable and practical steps to ensure that any claims in support of the statement of opinion are correct.



5.Collection of Personal Data

5.1 In the course of collecting personal data, Hong Kong Finance and EasyLend will provide the individua ls concerned with a "Personal Data Collection Statement" informing them of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data, and other relevant information.

5.2 In relation to the collection of personal data on-line, the following practices are adopted by Hong Kong Finance and EasyLend:

  • (a)On-line Security
    Hong Kong Finance and EasyLend will follow strict standards of security and confidentiality to protect any information provided to Hong Kong Finance and EasyLend online. Encryption technology is employed for sensitive data transmission on the Internet to protect individuals’ privacy.
  • (b)Cookie
    Cookies are small pieces of data transmitted from a web server to a web browser. Cookie data is stored on a local hard drive such that the web server can later read back the cookie data from a web browser. This is useful for allowing a website to maintain information on a particular user.

    Cookies are designed to be read only by the website that provides them. Cookies cannot be used to obtain data from a user’s hard drive, get a user’s e-mail address or gather a user’s sensitive information.

    Hong Kong Finance and EasyLend use cookies only to identify users for a specific period of time, and does not store sensitive information about users in the cookies. When a user browses the Hong Kong Finance and EasyLend website, all contacts will use the cookies to identify the user. When the user ends up visiting the Hong Kong Finance and EasyLend website, the cookies will also be invalid. If users attempt to disable the cookies of their web browsers, they may not be able to use the online and other financial services of Hong Kong Finance and EasyLend.
  • (c)On-line Correction
    Personal data provided to Hong Kong Finance and EasyLend through an on-line facility, once submitted, it may not be facilitated to be deleted, corrected or updated on-line. If deletion, correction and updates are not allowed online, users should approach relevant departments or branches of Hong Kong Finance and EasyLend.
  • (d)On-line Retention
    Personal data collected on-line will be transferred to Hong Kong Finance’s and EasyLend’s relevant departments or branches for processing. Personal data will not generally be retained in web server.


6.Hyperlink policy

6.1 Although the website of Hong Kong Finance and EasyLend contains hyperlinks or links to other websites/web addresses, there is no indication or hint that Hong Kong Finance and EasyLend would certify, verify, explain, approve or recognize such hyperlinks, links, websites/web addresses or the owners’ identity or information.
6.2 Hong Kong Finance and EasyLend expressly disclaim any liability for any content, supply, accuracy or omission of information provided by or contained in the hyperlinks, links, other websites/web addresses linked to the website of Hong Kong Finance and EasyLend.
6.3 You are exposed to the risks arising from all the hyperlinks, links or other websites, web addresses or sources due to the use of hyperlinks.



7.Request to the access and alteration of information

7.1 The policy of Hong Kong Finance and EasyLend is to comply with and process all the requests to access and alter information according to the regulation and to help all the relevant staff become familiar with the stipulations thereunder so as to provide assistance during the process of making request.
7.2 Hong Kong Finance and EasyLend may demand reasonable charge for information access request in accordance with the regulation. Information access request to an additional copy of personal information ever provided by Hong Kong Finance and EasyLend at an earlier information access request may cost the requester a service charge aiming at fully compensating Hong Kong Finance and EasyLend for their administrative cost or other costs of providing such an additional copy.
7.3 Request with regard to the access and alteration of information may be made to the Head of Information Protection or other relevant personnel designated.



8.Other practices

To ensure compliance with the stipulations under the regulation, Hong Kong Finance and EasyLend has maintained:
8.1 an information log book, i.e. the log book stipulated under Article 27 of the regulation;
8.2 internal policies and guidelines for the staff of Hong Kong Finance and EasyLend to refer to in order to ensure their observance of the regulation.



9.Appointment of Head of Information Protection

9.1 Hong Kong Finance and EasyLend have appointed the Head of Information Protection who is in charge of the coordination and the monitoring of the regulation as well as the compliance with the personal information protection policy of Hong Kong Finance and EasyLend.
9.2 The contact information of the Head of Information Protection is as follows:
Head of Information Protection
Unit 3410, 34/F., Tower II, Lippo Centre, 89 Queensway, Admiralty, Hong Kong
Tel: 2523 7861 / 3700 3650
Fax: 2525 3534