Privacy Policy - Hello Credit
Last updated June 04, 2024 This privacy policy (Policy) together with our Terms of Use and Loan Account Agreement and any additional terms of use applies to your use of: Hello Credit("Hello Credit", "Hola Crédito", "us", "us" or "our") mobile application software (App), a software that provides loan services to individuals, available on our site OR hosted on the Google Play Store (App Sites), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device). Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party Sites (Service Sites). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood and accept the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy. This Privacy Policy describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You must read this Privacy Policy in its entirety. What data does Hello Credit collect and process? •Identification data (e.g., first name, surname, data and place of birth); •Data provided by you through your loan application (e.g., information about your income or employment, your proposed use of your loan proceeds, customer-provided information about your mobile device); •Contact details (e.g., address, phone number, alternate phone number, email address); •Mobile device data (e.g., SIM, IMEI, or other device identifiers, type of device, device operating system, device settings, user account information for your mobile device or Google Play Store account, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, etc.), information about network proximity); •Location data (e.g., mobile device location, time zone setting); •Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information); •Phone data (e.g., Contact lists, SMS logs,Photo images, installed mobile applications found on your mobile device,your phone number); •Hello Credit App usage (e.g., traffic (volume) data, information about your usage of the Hello Credit App); •Data related to your communications with Hello Credit (e.g., your communications with Hello Credit via in-app chat, email, telephone or other channels); •and Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies, mobile network providers). (collectively, your "Information") Hello Credit may collect your Information from: •You, when download the Hello Credit App and/or indicate that you want to apply for a loan; •Your other interactions with us, including Information you may voluntarily share with our customer support team or other Hello Credit employees or agents; •Your mobile device (e.g., mobile device data, location data, transaction data, Hello Credit App usage and/or phone data as more fully described above); •Credit reference agencies (who may check your Information against other databases – public and private – to which they have access) or fraud prevention agencies; and/or •Third parties and other publicly available sources, with your consent, when necessary (e.g., we may receive Information from financial rails (or other disbursement channel vendors) or other business partners that may assist us in providing services to you). Collection and processing of your Information by Hello Credit is necessary for the provision of Hello Credit's products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Hello Credit is subject. Aside from such cases, we do not collect Information without your specific prior consent. Details: SMS Log Due to the needs of product services, it may be necessary to request permission to read SMS Log. Here, we will disclose how to access, collect, use and share your SMS log information, please read carefully. Access: When using the app, you will need to access your SMS logs in a few places. (i) When you choose the SMS verification code to log in, after sending the verification code, we will try to get the text message. By getting the 4-digit or 6-digit verification code SMS, we can help you log in quickly; (ii) When submitting the loan When applying, access to your SMS log information is required due to our financial risk management mechanism. Collection: We provide financial products and services. Due to the needs of our financial risk management mechanism, only when you submit a loan application, we will collect all your SMS log information, including SMS content, SMS name, etc., for your Individual risk assessment. We will securely encrypt the collected data, and then upload it to our server hc.holacredito.net via the HTTPS protocol. Use: The collected SMS log information is mainly used for your credit risk assessment (i) to detect your financial risk status, and to determine your financial status through SMS log information related to financial transactions, including the name of the transaction party, transaction description, transaction amount, etc. Risk level; (ii) Discovering the existence of financial fraud through fraudulent text messages; (iii) Conducting credit assessment to obtain a credit score; after the credit risk assessment is completed, we can match you with suitable loans and services based on your credit score; After the credit evaluation is completed, your SMS log data will be deleted immediately, and we guarantee that our server will not save this data. Sharing: Your data is only authorized to be used on this product, and the scope of use is strictly controlled. It will be deleted immediately after use, without backup or storage. Your data will never be shared with any other third parties, please You can use it with confidence. Contact List Data collection: When using our products, during the application submission process, we will ask users to upload the phone numbers of 2 or 3 emergency contacts. These phone numbers are selected through the phone system's contact selector. We will not obtain any other contact information from your address book, and the application does not have permission to read the address book, so please rest assured that we will not upload your address book information. Use of data: Our customer service staff will only try to contact the emergency contact if they cannot contact you multiple times. We will not use these contact numbers casually. Data storage: Contact information will be uploaded to our server hc.holacredito.net. Data uploads will be securely encrypted and uploaded using the HTTPS security protocol. Data sharing: We will not share your data information with any third party. We focus on protecting users' personal privacy. Please feel free to use our products. Phone number Our app needs to be logged in, and we can provide you with services only after logging in. First of all, you need a mobile phone number, and you can register and log in to the app by receiving the verification code through the mobile phone number. Your mobile phone number will be encrypted and uploaded to our server. Please rest assured that we will ensure the safety of your personal information and will never disclose your information. In addition, during the application process, we may require you to fill in 1 or 2 emergency contact phone numbers, usually we will not use the emergency contact phone number, unless in some cases (such as payment failure, loan overdue etc.), the customer service will only use it with caution when the customer service cannot contact you for many times. Rest assured, these phone numbers will not be used indiscriminately and your information will never be disclosed. All data will be encrypted and uploaded to our server through a secure HTTPS transmission protocol. The data will be stored encrypted and will never be shared with third parties to ensure data security. Installed applications We need permission to access your Installed Application information (i) for purposes of conducting identity and fraud detection; (ii) to allow us to conduct credit assessment and identify products and services that match your preference and credentials. We collect each installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and provide you with pre-approved customized loan offers. Your data will be encrypted and uploaded to our member server {hc.holacredito.net} via the HTTPS protocol. At no time, we will share this data with any third parties. Location We collect and monitor the information about the location of your device to provide serviceability of your loan application, to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us to verify the address, make a better credit risk decision and expedite your KYC process. Image Data collected: We need to collect images of your ID card, including front or back, and if necessary, your selfies. It mainly obtains image information by taking pictures. Mainly due to the need for loan applications, we need to verify your unique identity and qualifications to prevent fraudulent behaviors such as machine applications or repeated applications. Please rest assured that your data will be encrypted and then uploaded to our server through secure methods such as HTTPS. How this data is used and shared: This data is primarily used to confirm your unique identity and confirm whether you meet our qualifications. We guarantee that your data will not be shared with any third party, and your data will only be authorized for use in current product. Phone Our app collect and monitor specific information about your device including your hardware model, build model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID; SIM information includes network operator, roaming state, MNC and MCC codes, WIFI information includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorized device act on your behalf to prevent frauds. This also helps us in assessing credit worthiness for credit profile enrichment. Storage We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the right KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application. MEDIA & PHOTOS & FILES We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey. What are the purposes for which your Information is processed? How does Hello Credit use your Information? •To assess your eligibility to use our products or services (including, but not limited to, by assessing your creditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product); •To service your loan with Hello Credit (including, but not limited to, by processing your transactions and processing disbursement of your loan and collecting repayment of your loan); •To verify your identity and/or other information you have provided to us; •To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services; •To analyze customer behavior; •To administer out systems, maintain service quality and compile general usage statistics; •To analyze and improve our services; •To troubleshoot any problems you or other customers encounter with Hello Credit's services; •To comply with applicable laws, regulations, and rules, such as those relating to "know-your-customer" and/or anti-money laundering; •To the extent you have not objected to the use of your information for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers; •To provide service updates; •To provide staff training (where we may monitor or record customer interactions); •To interface with credit reference or fraud prevention agencies; •To provide customer service or support; •To contact you by telephone using autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy. We process your Information for the purposes set out above on the following grounds: In connection with the nature of our business in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date; To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you); and/or With your prior consent. Who do we share your Information with? General Hello Credit shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Hello Credit's products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Hello Credit will only share your Information with third parties in an anonymized format. You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to: •a subsidiary, affiliate or parent company of Hello Credit (collectively, the "Hello Credit Group"); •employees, subcontractors, agents, service providers, or associates of the Hello Credit Group (including directors and officers); •intermediary, correspondent and agent banks, non-banks, quasi-banks or other financial institutions, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, licensed electronic or mobile wallet providers, credit reference agencies or credit bureaus; •service providers with contractual or fiduciary relationships with Hello Credit (e.g., to facilitate transaction processing, fraud prevention, cloud data storage or data transfer); •external collection agencies (to assist in the collection of any unpaid obligations to us); •tax authorities; •a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Hello Credit and/or any company within the Hello Credit Group; •to other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Hello Credit, the Hello Credit Group and/or our customers. The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy. Further, Hello Credit may also share your information with law enforcement or other government agencies pursuant to a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you. Referrals To promote its products and services, Hello Credit administers and services a referral program ("Hello Credit Referral Program", for brevity) for its current and future customers. If you choose to accept a referral from another Hello Credit customer and accept a Hello Credit loan in connection with that referral, Hello Credit will provide a bonus to the customer who refers you upon your successful repayment of your Hello Credit loan. If you choose to participate in the Hello Credit Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the imbedded referral link and subsequently applying for and accepting a Hello Credit loan through such referral. Sharing of your Information in connection with the Hello Credit Referral Program shall be limited to the information described above and shall remain anonymized – Hello Credit will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Hello Credit. More information on the Hello Credit Referral Program is available within the Hello Credit App. For how long will we retain your Information? Your Information will be stored or retained by Hello Credit and its transferees only for so long as necessary for the purposes listed in Sections 2 and 10 of this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services. We may also retain your Information (i) as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Lending decisions When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources. Our credit and underwriting models utilize machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased. Detecting fraud Hello Credit also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual's access may be suspended or refused. Your rights in relation to automated decision-making In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through peneloperalph079@gmail.com. Your rights as a data subject You may contact us to exercise your rights at peneloperalph079@gmail.com Rights to notice and consent We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Hello Credit App and in this Privacy Policy. Right to access You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request. Right to rectification You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the thereof. Right to erasure ("right to be forgotten") You may ask us to delete your personal data (as defined under applicable law) from our system: •If you believe it is no longer necessary for us to retain such personal data; •If you do not believe we have legitimate ground for processing it; •If you think we are using such personal data unlawfully; and/or •If you think applicable law requires that we do so. Right to restrict processing You may ask us to stop using your personal data (as defined under applicable law): •if you think such personal data is inaccurate; •if you think it's illegal for us to use such personal data; •if you don't want us to destroy such personal data because you need it for legal proceedings; •if you've informed us that we don't have a legitimate reason for using it and we're considering your request. Right to data portability If we're using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller. Right to object You have a right to object whenever we are using your personal data (as defined under applicable law) on the basis of our legitimate interests (Please see section 2 for the ways in which we rely on legitimate interests to use and process such personal data). Right to file a complaint You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject. Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation). Advertising and Marketing You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through peneloperalph079@gmail.com and we will remove you from such communication lists. Consequences of not providing us with your Information You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Hello Credit, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts. Consent and Authorization By downloading the Hello Credit App, you: •accept the terms of this Privacy Policy; •give Hello Credit consent to collect, use, share, or otherwise process your Information, which may include personal information, sensitive personal information or privileged information (in each case, as defined under applicable law), as outlined in this Privacy Policy; •certify that all Information you have provided and will provide to Hello Credit is true and correct to the best of your knowledge; •authorize Hello Credit to verify/investigate the accuracy of your Information; General If you to contact us, please do so at: peneloperalph079@gmail.com To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Hello Credit App or by email.