This Statement applies to Lendela Limited (“the Company” or “we”) or its subsidiaries from time to time (“the Group”).
In this Statement, the term “data subjects” or “you” shall include visitors to this website and applicants for loan-related products or facilities from our network of third-party lenders (which may be licensed banks, financial institutions or licensed money lenders) through this website (“Loan Providers”).
The content of this Statement shall apply to all data subjects and form part of the terms and conditions of any agreement or arrangement that the data subjects have or may enter into with the Company from time to time. In the event of any inconsistency or discrepancy between this Statement and the relevant agreement or arrangement, this Statement shall prevail insofar as it relates to the protection of the data subject’s personal data.
Purpose of Collection
1. For the purposes of the provision of services by us, it is necessary for data subjects to supply us with personal data for the purposes of the establishment of loan facilities or the processing of new or renewal applications or other services from the Loan Providers.
2. Failure to supply such personal data by data subjects may result in the Company being unable to provide relevant information to the Loan Providers for providing you with loan facilities or process applications or other services.
3. For the purposes of the establishment of loan facilities or the processing of new or renewal applications or other services by the Loan Providers, personal data of data subjects may also be obtained by the Loan Providers from credit reference agency (whose contact details can be provided by the Loan Providers upon request) or from the public domain through different channels, including public registers, public search engines, public directories or any social media with public view setting authorised by the data subject. In addition, device information may be collected from data subjects’ web browsers.
Collection of Personal Data
4. Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. We may collect the following data relating to you, which may be personal data from time to time, including but not limited to:
HKID number or passport number;
nationality or residency status;
personal finance status, intention or goals (including need for loans)
income or assets information;
bank account or stored value facility account details;
Facebook ID and first name displayed in Facebook;
LinkedIn ID and related information;
TE record (Softmedia);
preferences related to any products or services;
communications between you and the Company;
data regarding your visits to and use of our website and Chatbot; and
5. In addition, when you use our website or services, we may automatically collect certain data which may, when combined with other information about you, be personal data, including but not limited to:
attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
device locations, including specific geographic locations identified through GPS, Bluetooth or WiFi signals or other means;
connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
the website from which you have reached our website;
our website pages viewed;
details of the products and services on our website that you look at, information, tools and content available on our website that you use; and
links from our website that you click on.
Use of Personal Data
6. The personal data of data subjects may be used by the Company for:
matching you with the Loan Providers and providing referral services;
responding to your queries and requests and contacting you for customer service, if necessary;
customising your experience with our website;
resolving complaints and handling requests and enquiries;
organising promotional events;
enabling the Loan Providers to consider and process applications for loan facilities or new or renewal applications and the daily operation of products and services (including loan facilities and related products and services provided by the Loan Providers to data subjects);
enabling the Loan Providers to conduct credit checks whenever appropriate (including at the time of application for loan and when we review credit which normally takes place one or more times each year);
enabling the Loan Providers to assist other institutions to conduct credit checks and to collect debts;
enabling the Loan Providers to design and develop loan/credit facilities and related financial products and services for customers’ use;
conducting marketing research or developing membership programs;
subject to obtaining the consent of data subjects, direct marketing services, marketing products, services and other subjects as described in paragraphs 8 and 9 below;
meeting obligations, requirements and arrangements, of the Company or its affiliates within the Group, whether compulsory or voluntary, to comply with or in connection with:
any law, regulation, judgement, court order, voluntary code, sanctions regime applicable to the Company or its affiliates within the Group, existing currently or in the future;
any guidelines, guidance, rules or codes of practice or requests given, published or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, relevant stock exchange, self-regulatory or industry bodies or associations of financial service providers within or outside Hong Kong existing currently or in the future;
any present or future contractual or other commitment with legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, court or other authorities, relevant stock exchange, self-regulatory or industry bodies or associations of financial service providers or any of their agents that is assumed by, imposed on or applicable to the Company or its affiliates within the Group; and
any agreement or treaty between the authorities described in (iii) above;
complying with any obligations, requirements, policies, procedures, measures or arrangements of the Company or its affiliates within Group for the use of data and information for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
enabling an actual or proposed assignee or transferee of all or any part of the Company’s business and/or assets, or participant or sub-participant of the Company’s rights in respect of loans/credit facilities relating to data subjects, to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation and enabling the actual assignee or transferee to use such data in the operation of the business or rights assigned;
enabling the Loan Providers to compare data of data subjects or other persons for credit checking, data verification or otherwise producing or verifying data, whether or not for the purpose of taking action against such data subjects;
enabling the Loan Providers to maintain a credit history of the data subjects (whether or not there exists any relationship between the data subjects and the Company) for present and future reference;
administering, enhancing, maintaining and providing Chatbot and processing, handling or communicating with data subjects in respect of any enquiry or requests raised by data subjects via Chatbot; and
any other purposes relating to the purposes listed above.
Disclosure of Personal Data
7. All personal data held by the Company will be kept confidential, but the Company may disclose or transfer such information to the following parties for the purposes set out in paragraph 6 above:
(a) the Loan Providers;
(b) any agent, contractor, sub-contractor or associates of the Company or its affiliates within the Group (including its employees, officers, agents, contractors, service providers and professional advisers);
(c) any third-party service provider who provides administrative, professional, advisory, telecommunication, information service, computer, payment, data processing, debt collection or other services to the Company or its affiliates within Group in connection with the operation or maintenance of its business;
(d) any other person who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential;
(e) the drawee bank providing a copy of a paid cheque (which may contain data about the payee) to the drawer;
(f) credit reference agencies and, in the event of default, debt collection agencies;
(g) any authority, body, association or persons mentioned in paragraph 6(l) above;
any actual or proposed assignee or transferee or the Company or, participant or sub-participant of the Company’s rights in respect of loans/credit facilities relating to data subjects;
any entities within the Group;
business partners or co-branding partners of the Company together with whom the Company provides products or services to data subjects;
subject to obtaining the consent of data subjects in connection with the purpose set out in paragraph 6(k) above:
third party financial institutions, insurers, credit card companies, securities, commodities and investment services providers, third-party membership program providers or our co-branding partners; and
external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies).
Personal data collected in Hong Kong by the Company may be transferred in and to a place outside Hong Kong.
8. The Company intends to use a data subject’s data to conduct direct marketing of products or services and requires the data subject’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
the name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data of data subject held by the Company from time to time may be used by the Company in direct marketing;
the classes of services, products and subjects which may be marketed includes credit/loan facilities and other financial services and products, membership programs and related products and services, products and services offered by our co-branding partners;
the above services, products and subjects may be provided by the Company or its affiliates within the Group, third party financial institutions, insurers, securities and investment services providers, third-party membership program providers or our co-branding partners;
in addition to marketing the above services, products and subjects itself, the Company also intends to provide the data described in sub-paragraph (a) above to all or any of the persons described in sub-paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the data subject’s consent (which includes an indication of no objection) for that purpose; and
the Company may receive money or other property in return for providing the data to the other persons in sub-paragraph (c) above and, when requesting data subject’s consent or no objection as described in sub-paragraph (d) above, the Company will inform the data subject if we will receive any money or other property in return for providing the data to the other persons.
9. If you do not wish the Company to use or provide to the other persons your data for use in direct marketing as described above, you may exercise your opt-out right by notifying us:
Data Protection Officer
17/F, Glenealy Tower, No. 1 Glenealy
Access and Correction of Personal Data
10. Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data (the “Code”), you have the right:
to check whether the Company holds personal data about you and to access such data;
to require the Company to correct any personal data relating to you which is inaccurate;
to ascertain the Company’s policies and practices in relation to personal data and to be informed of the kind of personal data held by the Company;
in relation to consumer credit data, to be informed, upon request, which items of personal data are routinely disclosed to credit reference agencies or debt collection agencies and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency; and
in relation to consumer credit data, upon termination of your account by full repayment and on condition that there has not been, within 5 years immediately before account termination, any material default on your account, to instruct the Company to make a request to the credit reference agency to delete from its database any account data relating to your terminated account.
11. In accordance with the terms of the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
12. You should send any requests for access to personal data or correction of personal data or for information regarding our policies and practices to:
Data Protection Officer
17/F, Glenealy Tower, No. 1 Glenealy
13. Nothing in this Statement shall limit the rights of the data subjects under the Ordinance.
14. The Company may have obtained a credit report on or access the database of the data
subject from a credit reference agency in considering any application for loan-related
products or facilities or conducting credit reviews from time to time. In the event that
the data subject wishes to access the credit report, the Company will advise the
contact details of the relevant credit reference agency.
15. In case of discrepancies between the English and Chinese versions, the English version shall prevail.