Privacy Policy and Personal Information Collection Statement

General

This Privacy Policy and Personal Information Collection Statement (the “Policy”) sets out how the Company collects, holds, uses, discloses and transfers personal data in connection with the Website and our services.

By accessing or using the Website, or by submitting any personal data to us, you confirm that you have read, understood and agreed to this Policy. If you do not agree, you must not use the Website or submit personal data to us.

We may amend this Policy at any time, without prior notice, by posting the revised version on the Website. The revised Policy takes effect immediately upon posting. Your continued use of the Website after any amendment constitutes your acceptance of the Policy as amended. You are responsible for reviewing this Policy from time to time.

This Policy forms part of, and is to be read together with, the Website’s Terms of Use. In the event of any inconsistency, the Terms of Use shall prevail to the extent permitted by law.

If this Policy is published in both English and Chinese, the English version shall prevail to the extent of any inconsistency.

Excluded Jurisdictions and Territorial Scope

The Website is operated from China and is directed solely at persons located in China. The Website, and the products and services referred to on it, are not offered or directed to, and are not intended for use by, any person located or resident in the United States of America, the United Kingdom, or the European Union or European Economic Area (each an “Excluded Jurisdiction”).

We employ technical measures to block access to the Website from the Excluded Jurisdictions. We do not market to, monitor the behaviour of, or knowingly collect personal data from, persons in any Excluded Jurisdiction, and we do not intend to be subject to, and do not accept any obligation under, the data protection or privacy laws of any Excluded Jurisdiction, including the EU General Data Protection Regulation, the UK General Data Protection Regulation and Data Protection Act 2018, and any United States federal or state privacy law (including the California Consumer Privacy Act). This Policy, and our collection and handling of personal data, are governed exclusively by the laws of China.

If you are located or resident in an Excluded Jurisdiction and gain access to the Website — including by circumventing our blocking measures through a virtual private network (VPN), proxy server or any other means — you must leave the Website immediately and must not submit any personal data to us.

By accessing or using the Website, you represent and warrant that you are not located or resident in an Excluded Jurisdiction and that you have not circumvented, and will not circumvent, any blocking or access-control measure we employ.

Any access to or use of the Website from an Excluded Jurisdiction, or by circumvention of our blocking measures, is entirely at your own risk and constitutes a material breach of this Policy and the Terms of Use. Any personal data submitted in such circumstances is provided without our solicitation and will be handled solely in accordance with China law; to the maximum extent permitted by law, we disclaim all duties, obligations and liabilities under the laws of any Excluded Jurisdiction in respect of such data.

You shall indemnify and hold harmless the Company, its group companies and their respective directors, officers and employees, on demand, from and against all losses, damages, claims, demands, regulatory or enforcement actions, fines, penalties, costs and expenses (including legal costs on a full indemnity basis) arising out of or in connection with your access to or use of the Website from an Excluded Jurisdiction or your circumvention of our blocking measures. We reserve the right to commence legal proceedings against you in respect of any such breach.

Personal Data We Collect

We may collect the following categories of personal data:

(a) identity and contact data, including name, telephone number, email address and correspondence address; (b) financial and business data you submit through the Website, including loan amount sought, purpose of borrowing, income or business revenue, employment or business particulars, and existing borrowing details; (c) records of your communications with us, including enquiries, correspondence and call records; (d) technical and usage data, including IP address, device identifiers, browser type, operating system, referral source, pages viewed, time spent and clickstream data; (e) data collected through cookies and similar technologies (see section 7); and (f) any other data you choose to provide to us.

Provision of personal data to us is voluntary. However, if you do not provide the data we request, we may be unable to provide some or all of our services to you, including processing your enquiry or matching you with credit providers or other partners.

You warrant that all personal data you provide is true, accurate, complete and up to date. Where you provide personal data relating to any other person (for example, a director, partner, shareholder or guarantor), you warrant that you have obtained that person’s consent to the provision and use of their data in accordance with this Policy. We are entitled to rely on the data you provide and accept no liability for any consequence arising from inaccurate, incomplete or outdated data supplied by you.

Purposes for Which Personal Data May Be Used

We may collect, hold, use and process your personal data for the following purposes:

(a) operating the Website and providing our services, including assessing and processing your enquiries and matching or referring you to credit providers, financial institutions and business partners; (b) verifying your identity and maintaining records; (c) communicating with you in relation to your enquiries, applications and our services; (d) conducting research, statistical analysis and analytics, and designing and improving our services and the Website; (e) personalising content and your experience of the Website; (f) direct marketing, subject to section 6 below; (g) preventing, detecting and investigating fraud, crime or unlawful activity, and complying with any law, regulation, court order, code or guideline applicable to us, whether within or outside Chnia; (h) exercising, establishing or defending our legal rights; (i) evaluating or effecting any merger, acquisition, reorganisation, financing, sale or transfer of all or part of our business or assets; and (j) any other purposes directly related to any of the above.

Disclosure and Transfer of Personal Data

We may disclose or transfer your personal data to the following classes of persons, within or outside China, for the purposes set out in section 4:

(a) members of our group of companies, including our holding company, subsidiaries and affiliates (including those incorporated or operating in Singapore); (b) credit providers, banks, licensed money lenders, financial institutions, brokers and other business or referral partners whose products or services you enquire about, or who may offer products or services relevant to your enquiry; (c) our agents, contractors and service providers who provide administrative, information technology, hosting, data storage, analytics, marketing, communications, payment or other services to us; (d) our professional advisers, including legal, accounting and audit advisers; (e) any person to whom we are required or permitted to make disclosure under any law, regulation, court order, or request of any regulator or law enforcement agency, whether within or outside China; (f) any actual or proposed assignee, transferee, participant or successor of all or any part of our business or assets, and their advisers; and (g) any other person without your consent.

Use of Personal Data in Direct Marketing

We intend to use your personal data — namely your name, contact details (telephone number, email address and correspondence address), demographic data, and details of the products and services you have enquired about or used — in direct marketing of the following classes of products and services: loans and credit products; banking and financial products and services; insurance products; investment and wealth management products and services; property and real estate related products and services; professional and business services; and the products, services, promotions, rewards, events and offers of the Company and members of our group.

We may also provide the personal data described in clause 6.1 to the classes of persons described in clauses 5(a) and 5(b) for use by them in direct marketing of the classes of products and services described in clause 6.1, and we may receive money or other property in return for providing your personal data to such persons.

We may use your personal data in direct marketing, or provide your personal data to other persons for their use in direct marketing.

Cookies and Similar Technologies

The Website uses cookies, pixels, tags and similar technologies, including third-party analytics services (such as Google Analytics), to operate the Website, analyse traffic and usage, remember your preferences and support our marketing.

You may disable cookies through your browser settings, but some features of the Website may not function properly as a result. By continuing to use the Website without disabling cookies, you consent to our use of cookies as described in this Policy.

Cookies and technologies set by third parties are governed by those parties’ own privacy policies, for which we are not responsible.

Transfer of Personal Data

Your personal data may be transferred to, stored and processed in jurisdictions outside China, including Singapore and other places where members of our group or our service providers operate. By using the Website or providing personal data to us, you consent to the transfer of your personal data outside China for the purposes set out in this Policy.

Retention of Personal Data

We retain personal data for as long as is necessary to fulfil the purposes for which it was collected (including any directly related purposes), and thereafter for such period as is required or permitted by applicable law, regulation, or our legal, regulatory, accounting, audit or risk management requirements after the end of the relevant relationship or your last interaction with us, or longer where the data is or may be relevant to any claim, dispute, investigation or legal proceeding.

Security

We take reasonable steps to protect personal data we hold against unauthorised or accidental access, processing, erasure, loss or use.

However, no method of transmission over the internet or method of electronic storage is completely secure. Any transmission of personal data by you to us through the Website or by other electronic means is at your own risk. To the maximum extent permitted by law, we shall not be liable for any loss or damage arising from any unauthorised access, hacking, interception, alteration or disclosure of personal data caused by circumstances beyond our reasonable control, or from the acts or omissions of any third party to whom personal data has been disclosed in accordance with this Policy.

Third-Party Websites

The Website may contain links or redirections to websites operated by third parties, including the websites and application pages of credit providers and other partners. Such links are provided for convenience only. We have no control over, and are not responsible for, the privacy practices or content of such websites. Any personal data you provide to a third party is governed by that party’s own privacy policy, and you should review it before providing any data.

Minors

The Website is not directed at persons under the age of 18, and we do not knowingly collect personal data from such persons. If you are under 18, do not use the Website or submit any personal data to us.

Governing Law and Jurisdiction

This Policy is governed by and construed in accordance with the laws of China. You irrevocably submit to the exclusive jurisdiction of the courts of China in respect of any dispute arising out of or in connection with this Policy.