- Purpose of use of personal data
2.1 The Customer is required to provide Simple Credit with such information from time to time when opening or continuing a credit account, establishing or extending credit or providing the Services.
2.2 Failure to provide such information to Simple Credit may result in Simple Credit being unable to open or renew credit accounts and related services and/or products.
2.3 Simple Credit may, from time to time, collect or receive information about the Customer, including but not limited to information obtained in person or by telephone or online application for a loan or renewal of a credit account, including the information through a credit reference agency.
2.4 Personal data of the Client may be used for the following purposes:
(a) The regular operations of providing services and credit facilities to customers.
(b) Credit checks conducted when customers apply for credit and periodic or special examinations conducted once a year or more.
(c) To establish and maintain Simple Credit’s credit scoring model.
(d) Assisting other money lenders and/or financial agencies in credit checks and debt collection.
(e) To ensure that customers maintain reliable credit.
(f) Financial services or related products designed for customers use.
(g) For the promotion of services, products and other subjects (see point 6 of the Personal Data Collection Statement for details).
(h) Selected Financial services or products of Simple Credit.
(i) Calculate customer’s debt with Simple Credit.
(j) Collection of debts from customer, and persons who pledge their responsibilities.
(k) Simple Credit makes a disclosure in order to comply with the requirements of any law or to comply with and give effect to any guidance issued by any regulatory or other institute which Simple Credit is expected to comply.
(l) Make sure Simple Credit ‘s actual or proposed assignee, or a participant or sub-participant in Simple Credit’s rights to a customer, to evaluate transactions intended to be an assignment, participation or sub-participation; and
(m) Other uses related to the above.
- Simple Credit’s policy is to ensure the security of personal data, provide appropriate safeguards according to the sensitivity of the account data and damage caused by unauthorized access, processing or other use of data. In order to achieve an appropriate level of security, the consistence practice of Simple Credit is to strictly limit access to data by providing secure storage facilities and implementing security measures at data storage facilities. Simple Credit will also take steps to ensure that persons handling such information have good conduct, prudence and competence. Information will only be transmitted in a properly secured manner.
- Simple Credit’s policy is to ensure that all information collected and processed through Simple Credit is accurate. Simple Credit will implement appropriate procedures to regularly collate and update all personal information to ensure that it is reasonably accurate for the purposes for which it is used. Where personal data held by Simple Credit contains a statement of opinion, Simple Credit will take all reasonably practicable steps to ensure that any statement is correct while any opinions is in support of the facts of that statement.
- Collection of personal data
5.1 In the course of personal data collection, Simple Credit will provide the data subject with a Personal Data Collection Statement setting out the purpose of data collection, the identity of the person to whom the data will be transferred, the right of access and correction of the data and other relevant information.
5.2 In relation to Simple Credit’s collection of personal data from the Internet, Simple Credit will adopt the following practices:
(a) Online security Simple Credit will protect any information provided to Simple Credit over the Internet in accordance with strict security and confidentiality standards, encryptions are also have been used to transmit sensitive data over the Internet to protect the privacy of individuals.
(b) “Cookie” File A “cookie” file is a small piece of information sent from a web server to a browser, which is stored on a computer’s hard drive so that the web server can read it from the browser later. This helps the website to keep information about certain users. The “cookie” file is designed to be readable only by the issuing website, but cannot be used to obtain a user’s hard drive data, email address or to collect sensitive information about the user. Simple Credit only uses the “cookie” file to identify users for a specific period of time and does not store sensitive information about users in the “cookie” file. When a user visits our website, all contacts will use the “cookie” file to identify the user. The “cookie” file is also invalidated when the user ends the visit to Simple Credit’s website. Users may not be able to use Simple Credit’s online and other financial services if they try to set their web browser’s “cookie” file to be blocked or stop working.
(c) Online Correction of Information Personal information provided to Simple Credit through online may not be able to be cancelled, corrected or updated online once submitted. Users who are unable to make cancellations, corrections or updates online should contact the relevant department or branch of Simple Credit.
(d) Online retention of information Personal data collected online will be transferred to the relevant departments or branches of Simple Credit for processing. Personal information is generally not stored on the web server.
- Hyperlink Policy
6.1 Although Simple Credit’s Website contains hyperlinks or links to other websites/websites, this does not constitute or imply any endorsement, verification, representation, approval or approval by Simple Credit of such hyperlinks, links, websites/websites or of their own identity or information.
6.2 Simple Credit expressly disclaims any responsibility for the content, availability, accuracy or omission of the information provided or attached to such hyperlinks, links, other websites/websites linked to or from Simple Credit’s website.
6.3 All hyperlinks, links or the usage of hyperlinks to other websites, web links or information sources are used at your own risk.
- Data access requests and data correction requests
7.1 Simple Credit’s policy is to comply with and process all data access and correction requests in accordance with the provisions of the Ordinance; and to familiarize all relevant staff with the requirements to assist parties in making such requests.
7.2 Simple Credit may impose an appropriate fee for data access requests subject to the requirements of the Ordinance. If anyone that making a data access request is requesting Simple Credit to provide an additional copy of the personal data provided, is pursuant to an earlier data access request, Simple Credit may charge a fee to fully cover the administrative or other costs incurred in providing such additional copy.
7.3 Requests for access to and correction of data may be made to the Data Protection Officer or other relevant designated officer.
- 8. Other practices To ensure compliance with the provisions of the Ordinance, Simple Credit has:
8.1 Data logbook, being the logbook required under section 27 of the Ordinance.
8.2 Internal policies and guidelines for Simple Credit’s employees to use, to ensure compliance with the provisions of the Ordinance by all employees.
- Appointment of the Data Protection Officer
9.1 Simple Credit has appointed a Data Protection Officer to co-ordinate and monitor compliance with the Ordinance and Simple Credit’s personal data protection policy.
9.2 The contact details of the Data Protection Officer are as follows:
Flat 902A1, 9/F, Fourseas Building, 208-212 Nathan Road, Kowloon, Hong Kong
Simple Credit Limited
Data Protection Officer