Privacy Policy Statement

(the “Privacy Policy”)

FundingReach Holdings Ltd and its subsidiaries, including FundingReach Ltd, iFinHealth Ltd, iFinPulse Ltd, iFinGate Ltd and its affiliates (“FundingReach”) are committed to protecting and respecting your privacy.

This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The rights and obligations of each of the Company under FundingReach under this Privacy Policy are several and not joint. No Company shall be liable for any act or omission by another Company. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it in compliance with all the requirements under the Personal Data (Privacy) Ordinance (the “Ordinance”).

1. Information collection 

1.1.   FundingReach collects information and other data from you to assist us to provide credit analysis services, compliance monitoring services, other financial technologies services and credit products (“financial services”). From time to time, it is necessary for you and various other individuals (including but not limited to applicants for financial services, sureties and persons providing security or guarantee for credit facilities, directors, shareholders, controlling persons, officers and managers of a corporate customer or applicant, partners or members of a partnership, beneficial owner, trustee, settlor or protector of a trust, payee of a designated payment, representative, agent or nominee of a customer, or any other persons with whom a customer has a relationship that is relevant to the customer’s relationship with FundingReach) (collectively named as ‘relevant individuals’), to provide FundingReach with data required for the provision of financial services.

1.2. The types of information collected included but are not limited to:

a) Information which identifies you or relevant individuals (for ‘know-your-customer’ purpose); It may include details of name, residential address, date or place of birth, unique identification number(s) such as tax identification or equivalent number(s), background information (which may include demographic data relating to education or family background), telephone number, email address or other contact details, or any other information from which you or relevant individuals can be identified, whether in electronic form or otherwise;

b) Information which relates to you or relevant individuals’ financial wealth and affairs, business, employment, income or assets;

c) Information which arises or is required in connection with the transactions a customer do with us or through us;

d) Information which helps us to process applications made by you for particular products and services and to manage our exposures if you borrow funds from us or provide security;

e) Information relevant to product development or marketing;

f) Information that you provide by filling in forms on our websites www.fundingreach.comwww.ifinhealth.comwww.ifinpulse.com, www.ifingate.com and any other websites of FundingReach (the “Site”). This includes information provided at the time of registering to use our Site, subscribing to our financial services, posting and uploading information for requesting further services (if any).

1.3 In case of a corporate customer, we might collect this information directly from corporate representatives within your organisation acting on your behalf; Besides, we may also collect information from publicly available resources, and receive or derive information in the course of our relationship with you. You must ensure that the relevant individuals involved are made aware of how we will process their personal data. Whenever you or a corporate representative within your organisation provide us with personal or financial information about a relevant individuals and by providing us with personal or financial information about a relevant individuals and allowing us to continue holding, using, processing, transferring and disclosing such information, you warrant, and it shall be deemed, that you have provided this Privacy Statement to your relevant individuals and have obtained written consents from your relevant individuals for such information to be held, processed, used, disclosed and transferred (including international transfer) in accordance with this Privacy Statement (including any amendment thereto). You agree to provide us with evidence of such consent as and when requested by us and shall inform us immediately if such consent is revoked by any relevant individual.

1.4 Failure to supply the information as quoted, may result in FundingReach being unable to provide or continue the financial services to you as requested.

 

2. Purpose of Collection

2.1 The Personal Data and any information provided by the customers will be used by FundingReach for one or more of the following purposes:

a) processing applications from customers (including assessing the merits and/or suitability of the customers’ application(s)) for the establishment of financial services;

b) operating, maintaining and providing financial services to customers;

c) conducting credit checks on customers;

d) creating and maintaining the FundingReach’s credit models;

e) maintaining credit history of customers for present and future reference;

f) assisting other financial institutions to conduct credit checks and collect debts;

g) ensuring ongoing credit worthiness of customers;

h) designing financial services for customers’ use;

i) marketing financial services as set out in Section 5;

j) determining the amount of indebtedness owed to or by customers;

k) determining the amount of investment portfolio maintaining by customers;

l) enforcement of customers’ obligations, including without limitation the collection of amounts outstanding from customers and those providing security for customers’ obligations;

m) meeting or complying with any obligations, requirements or arrangements for disclosing and using data that apply to FundingReach or any other member of the FundingReach or that it is expected to comply according to:

(i) any law or regulation binding on or applying to it within or outside the Hong Kong existing currently and in the future;

(ii) any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or  outside Hong Kong existing currently and in the future;

(iii) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on the FundingReach or any member of the FundingReach Group.

n) enabling an actual or potential assignee of all or any part of the business and/or asset of the FundingReach or participant or sub-participant of the FundingReach’s rights in respect of the customers, to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation, and/or

o) any other purposes relating to the purposes listed above.

2.2 FundingReach may also record any communications between you or your corporate representatives and us including telephone calls. We will use these recordings to check your instructions to us, for identification, investigation, regulatory, fraud prevention and quality purposes and to analyse, assess and improve our services.

 

3. Disclosure of your personal data

3.1 FundingReach will keep the personal data we hold confidential but may provide information to the following parties (whether within or outside Hong Kong) for the purposes offering the customers with the financial services from time to time:

a) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (including their employees, directors and officers);

b) our subsidiaries, overseas offices, affiliates, business partners and counterparts (if any);

c) persons under a duty of confidentiality to us;

d) any person with the express prescribed consent of customers;

e) persons to whom we are required to make disclosure under applicable laws and regulations in or outside the Hong Kong Special Administrative Region; or

f) actual or proposed transferees or participants of our services in or outside the Hong Kong Special Administrative Region.

g) as a voluntary purpose, selected persons for use in direct marketing;

 

4. Cookies 

4.1 All websites of FundingReach use cookies for statistical purposes and to improve user experience and online advertising campaigns. All cookies we use are essential for our site to operate and have already been set. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. By continuing to browse the Site, you are agreeing to our use of cookies.

4.2     We use the following cookies:

a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, submit loan applications or make use of e-billing services.

b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

4.3 We may also use the above mentioned cookies to assist us in fraud prevention.

4.4 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

4.5 We may use the following third party web analytic services on the website. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse how visitors use the website. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. These analytic services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

a) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google’s ability to use and share information collected by Google Analytics is in accordance with their policies: https://www.google.com/policies/privacy/partners/

b) You can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).

4.6 You may opt-out of cookies (and the use of this website) at any time, by deleting the cookies that were set by the site. This can be done via the settings of your internet browser, and deleting all cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

 

5. Direct Marketing

5.1 FundingReach intends to use the data subject’s data in direct marketing. Unless we obtain your consent or indication of no objection, we will not use your personal data for direct marketing. In this connection, please note that:

a) your name, contact details, financials services’ portfolio information, transaction pattern and behaviour, financial background and demographic data held by FundingReach from time to time may be used for direct marketing purpose;

b) the following classes of services, products and subjects may be marketed:

(i) financial services and products.

(ii) reward, loyalty or privileges programmes in relation to our financial services and products;

(iii) the financial services and products offered by FundingReach’s co-branding partners (the names of such co-branding partners can be found in the application form(s) in relation to the relevant services and products, if applicable); and

(iv) donations and contributions for charitable and/or non-profit making purposes;

c) the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by FundingReach and/or:

(i) any member of our Group;

(ii) third party financial institutions, insurers, securities and investment services providers;

(iii) third party reward, loyalty, co-branding or privileges programme providers;

(iv) co-branding partners of FundingReach (the names of such co-branding partners can be found in the application form(s) in relation to the relevant services and products, if applicable); and

(v) charitable or non-profit making organisations;

5.2 in addition to marketing the above services, products and subjects itself, FundingReach intends from time to time it may provide the data described in 5.1 a) as quoted above, to any or all of the other parties as described in 5.1 c) for direct marketing purposes, and FundingReach requires your consent (which includes an indication of no objection) for that purpose;

5.3 FundingReach may receive money or other property in return for providing the data to any or all of the other parties as described in 5.1 c) and your consent or no objection would be sought for the purpose.

5.4 In case we engage third party service providers as our agents to market the financial services and products, we would only pass the data to these service providers who are under contractual obligations to protect your personal data against unauthorised or accidental access.

5.5 If you do not wish FundingReach to use or provide to other persons your data for use in direct marketing, you may exercise his opt-out right by notifying us.

 

6. Retention of personal data

6.1 It is the policy of FundingReach to take all practical steps to ensure that personal data are not kept longer than is necessary for the fulfilment of the purposes (including any directly related purposes) for which the data are or are to be used.

6.2 We will retain personal data for as long as we are allowed to for legitimate business purposes, to help prevent fraud and other financial crime, and for other legal and regulatory reasons.

 

7. Security

7.1 It is the policy of FundingReach to ensure an appropriate level of protection for personal data in full compliance with the requirements under the Ordinance, in order to prevent unauthorized access, processing or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by unauthorized access to that data.

7.2 FundingReach enhances data security by restricting physical access to data with secure storage facilities, and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data. Data is only transmitted by secured means.

 

8. Accessing your personal data

8.1 Under the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”), individuals have the right:

a) to check whether we hold personal data about you and to access such data;

b) to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate;

c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and

d) to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.

8.2 In accordance with the terms of the Ordinance, we have the right to and may charge a reasonable fee for processing any data access request.

8.3 Request for access to personal data or correction of personal data or for information regarding policies and practices on personal data and kinds of personal data held should be addressed to:

 

Compliance Office
FundingReach Holdings Ltd.

Rm 10, 9/F, Core F, Cyberport 3,

No. 100 Cyberport Road, H.K.

Email: co@fundingreach.com

 

Should there be any inconsistencies between the English and Chinese versions, the English version shall prevail.

 

FundingReach Holdings Ltd

September 2019