Personal Information Collection Statement
Statement on the Collection of Personal Data of Our Customers and Applicants for Loans and Other Services
General Statement
Throughout your relationship with Eloan Financial Services Limited we will collect personal data from you from time to time in accordance with this statement. Erdai Finance Limited is one of the companies under Erdai Finance Group. “Eloan Financial Group” means Eloan Financial Services Limited and its holding companies, subsidiaries, representative offices and associated companies wherever located. Affiliates include branches, subsidiaries, representative offices and affiliates of the holding company of ELDA Finance Limited (regardless of their location).
Purpose of Collection
1. The data subject (in this case, you) needs to provide personal data to Eloan Financial Services Limited for the purposes set out in the “Use of Personal Data” below.
2. If the data subject fails to provide such personal data to Eloan Financial Services Limited, it may result in Eloan Financial Services Limited being unable (or continuing) to open accounts, provide credit or other related financial services, or process applications for you or related applicants or persons connected with you.
3. In order to provide services to Eloan Financial Services Limited, we may collect information directly or indirectly from you or from persons acting on your behalf in the following circumstances:
1. In the ordinary course of our business or to maintain our relationship with you;
2. When you browse or use our websites and mobile applications;
3. Collected from other sources, such as:
i. any member of the Eloan Group (other than Eloan Financial Services Limited);
ii. third parties, such as our business partners (our business partners must obtain your consent before they can transfer your information to us), credit reference agencies (“CRAs”) (including those approved to join the multi-consumer CRA model) and third party service providers (including third party service providers you engage with in connection with the promotion of Eloan Financial Services Limited products and services and/or your application for Eloan Financial Services Limited products and services);
iii. Various public areas, including public registers, public search engines, public directories or any social media that the data subject has authorized to be shared publicly, cookies, behavioral or location tracking tools.
The information may also be combined with other information available to any member of the Eloan Services Group.
Use of Personal Data
4. We may use the information for the following purposes (or any of them), which may vary depending on the nature of your relationship with us:
1. Processing and approving product and service applications for you or related applicants or persons connected with you, as well as daily operations related to products and services (including but not limited to loans and related financial products and services provided to data subjects);
2. Carry out credit checks where appropriate (including but not limited to regular or special reviews when a customer applies for a loan or usually once a year or more);
3. Establish and maintain Eloan Financial Services Limited’s credit scoring criteria, risk-related criteria or anti-money laundering system;
4. Ensure your continued creditworthiness and good reputation;
5. Assist other financial institutions, including credit reference agencies approved in Hong Kong to join the model of multiple personal credit reference agencies, to conduct credit checks and debt collection;
6. Design loan/credit services or related products and services for customers to use;
7. Conduct market research, develop and provide membership plans or recommendation activities and compile and classify customer profiles;
8. Analyze how you access and use our products and services;
9. With the consent of the data subject, direct marketing services, market products and services and other matters referred to in paragraphs 9 and 10 below (including but not limited to cross-marketing with other members of the Eldai Financial Group);
10. Determine the amount of the liability of the data subject to the Company or the liability of the Company to the data subject;
11. In relation to mortgages, the credit reference agency will also use the data to compile statistics on the number of mortgages held by you (as a borrower, mortgagor or guarantor, whether in your sole name or jointly with other persons) from time to time for sharing with credit providers in the credit reference agency's customer credit database.
12. To ensure that Eloan Financial Services Limited can exercise its rights under the contract with the data subject, including collecting outstanding amounts from the data subject under the contract;
13. To enable Eloan Financial Services Limited and any entity within the Eloan Group to comply with any obligation, requirement or arrangement, whether mandatory or voluntary, to comply with or observe any obligation relating to:
i. any law, regulation, judgment, court order, code of obligations or sanctions regime existing now or in the future within or outside the Hong Kong Special Administrative Region that is legally binding or applicable to Eloan Financial Services Limited and any entity within the Eloan Group ("Law");
ii. any guidelines or instructions or codes of practice or requirements made or issued by any legal, regulatory, governmental, tax, law enforcement or other authority, or relevant stock exchanges, self-regulatory or industry bodies or associations of financial services providers, whether within or outside the Hong Kong Special Administrative Region and whether existing now or in the future, and any international guidelines, internal policies or procedures;
iii. any existing or future contractual or other commitments undertaken by, imposed on or applicable to us or any member of the Eloan Group with any local or overseas legal, regulatory, judicial, administrative, public or law enforcement authority, or governmental, tax, revenue, fiscal, court or other authority, or self-regulatory or industry body or association of financial services providers or their agents (collectively and each an “Authority”) having jurisdiction over the whole or any part of the Eloan Group;
iv. any agreement or treaty between us or any member of the Eloan Group and any authority.
14. comply with any obligations, requirements, policies, procedures, measures or arrangements in relation to the sharing of data and information and/or any other use of data and information within Eloan Financial Services Limited or any institution within the Eloan Group, as specified in any programme established by Eloan Financial Services Limited or any institution within the Eloan Group for the purpose of complying with sanctions or preventing or detecting any acts or attempts to circumvent or violate any laws relating to money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or circumvent or violate any laws relating to such matters;
15. Assist the Eloan Group in comprehensive supervision (conduct internal audit and risk management);
16. To enable an actual or potential transferee of all or any part of the business and/or assets of Eloan Financial Services Limited, or a participant or sub-participant of the rights of Eloan Financial Services Limited in relation to the data subject’s loan/credit facilities, to measure the transaction involved in the transfer, participation or sub-participation and to allow the actual transferee to use such data in carrying on the business or assigning the rights;
17. To conduct credit checks, fraud checks, data verification purposes, compare your information with other persons, other financial institutions and/or any member of the Eloan Group or to generate or verify information for other purposes in relation to your application for products and services, or the provision of credit, products and services by us or any member of the Eloan Group;
18. Maintaining the credit history or other records of the Data Subject (whether or not the Data Subject’s relationship with Eloan Financial Services Limited already exists) for present or future reference;
19. For our defence or response to any legal, governmental, regulatory or quasi-official matter, action or proceeding (including any potential action or proceeding);
20. For us to make or investigate insurance claims or respond to any insurance-related matters, actions or legal proceedings;
21. Manage, improve, maintain and provide the Eloan Financial Services Limited Chatbot and process or communicate with the data subject about any enquiries or requests made through the Eloan Financial Services Limited Chatbot;
22. Any other purposes related to the above purposes.
Disclosure of Personal Data
5. All personal data held by Eloan Financial Services Limited will be kept confidential, but Eloan Financial Services Limited may disclose (as defined in the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong)) (the "Ordinance") or transfer such data to the following parties or any party (whether in or outside Hong Kong) to achieve the purposes in paragraph 4:
1. any agent, contractor, sub-contractor or partner of Eloan Financial Services Limited or any entity within the Eloan group (including its employees, personnel, agents, contractors, service providers and professional advisers);
2. Any third party service provider who provides administrative, professional, consulting, telecommunications, information services, computer, payment, data processing, debt collection or other services to Eloan Financial Services Limited or any entity within the Eloan Group in connection with the operation of the business of Eloan Financial Services Limited or any Eloan Group entity;
3. The paying bank provides the drawee with a copy of the payment cheque (which may contain information about the payee);
4. credit reference agencies (including operators of any central database used by credit reference agencies under the multi-person credit reference agency model) and, in the case of outstanding debts, debt collection agencies ("Debt Collection Agencies");
5. Any authority, body, association or person referred to in paragraph 4(m) above;
6. any actual or proposed assignee of Eloan Financial Services Limited or any rights of Eloan Financial Services Limited or any participant or sub-participant in respect of the loan/credit facilities of the Data Subject;
7. Any person giving or offering to give security or guarantee to guarantee or secure the Data Subject’s obligations to Eloan Financial Services Limited;
8. Any person whose information you provide is acting on your behalf;
9. Any recipient of payment;
10. Any institution within the Eloan Group, including but not limited to WeLab Bank;
11. business partners or brand partners of Eloan Financial Services Limited who provide products or services to the Data Subject;
12. Charitable or non-profit organizations;
13. Based on the consent of the data subject for the purposes mentioned in paragraph 4(i):
i. third party financial services institutions, insurers, credit financing companies, credit card companies, securities and futures and investment service providers, third party membership program providers or our brand partners; and
ii. third party service providers engaged by us for the purposes mentioned in paragraph 4 above (including but not limited to courier services, telecommunications companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies);
14. Third-party service providers you use who use the Erdai Finance Limited application programming interface (“API”).
Using algorithmic evaluation, big data analysis and artificial intelligence
6. When considering and processing your application for establishing credit, products and services, we may use certain algorithms and big data analysis and artificial intelligence ("BDAI") technologies and applications. BDAI generally involves computers simulating human intelligence, enabling them to learn, feel, think and act to achieve automation and gain analytical insights from large amounts of structured and unstructured data created by preserving and recording human, tool or machine activities. Examples of BDAI include machine learning, biometric authentication techniques, natural language processing, decision trees, Internet cookies, and web logs.
7. Algorithms and BDAI may provide automatic assessments and decisions based on the information we collect from you, which may be personal information and non-personal information. Our use of BDAI in relation to personal data is governed by this Statement. The parameters used in such assessments should be selected to provide a fair and objective assessment of your information and have been tested for reliability and fairness. We have established robust policies and procedures to ensure the security and integrity of data and that BDAI is used fairly and in accordance with applicable laws and regulations. In addition, we may use BDAI, either by ourselves or through our service providers, to: (a) analyze statistics, trends, markets, behaviors, usage patterns, customer segments and pricing; (b) conduct planning, research and development, service or product design, and improve customer experience; (c) create predictive models; (d) perform credit, anti-money laundering, fraud prevention and other risk assessments; and (e) any other purposes related to the foregoing.
8. The accuracy of the assessments and decisions generated by the algorithms depends to a large extent on the accuracy of the personal data provided. If we are unsure about the accuracy of information that may be used in algorithmic evaluations, we will endeavor to seek clarification from you. You may also make inquiries or request a review of the decisions made by our BDAI through such channels as we may specify from time to time. The use of algorithms may involve certain other risks, including but not limited to risks relating to input data (such as mismatches between data used to train the algorithm and data input for establishing and using any account and/or any product or service), algorithm design (such as coding errors), and output determination (such as misinterpretation of outputs).
Direct Marketing
9. If Eloan Financial Services Limited intends to use the data subject's information for direct marketing of products and services, Eloan Financial Services Limited must also obtain the data subject's consent (including an indication of no objection to such use). In this regard, please be informed that:
1. We may use customer names, contact details, product and other service portfolio information, transaction patterns and behaviour, financial background and demographic data held by us from time to time for direct marketing by Eloan Financial Services Limited;
2. The following types of services may be used for promotion:
i.Eloan Financial Services Limited products and projects include loans;
ii. banking or financial services and products, credit financing, insurance, mortgages, investments, wealth management and related services, products and credit;
iii. telecommunications network services, delivery services, travel agency services, concierge services, catering, automobile products/services, gaming products/services, entertainment and media services, lifestyle products/services, social and medical services, electronic and electrical products, goods, consumer products and/or merchandise;
iv. Rewards, incentives, co-branding or promotional programmes and related services and products; and/or
v. Donations and contributions for charitable and/or non-profit purposes;
3. The above services, products and projects may be provided by:
i. Any member of the Eloan Group
ii. Third-party financial institutions, insurance companies, credit card companies, securities and investment service providers;
iii. third-party providers of rewards, incentives, co-branding or discount programs;
iv. telecommunications network service providers, delivery service providers, travel agencies, concierge service providers, catering service providers, automotive product/service providers, gaming product/service providers, entertainment and media service providers, lifestyle product/service providers, social and medical service providers, retailers, wholesalers and/or manufacturers of goods, consumer products and/or commodities;
v. our brand partners and those of any member of the Eloan Group; and/or
vi. charitable or non-profit organizations;
4. In addition to the promotion of the above services, products and projects by Eloan Financial Services Limited, Eloan Financial Services Limited also intends to provide the data mentioned in paragraph (a) above to all or any of the persons mentioned in paragraph (c) above for use by such persons in the promotion of such services, products and projects, and Eloan Financial Services Limited must obtain the consent of the person who holds the data at the time for this purpose (including an indication of no objection to such use);
5. Eloan Financial Services Limited may receive money or other property in return for providing the data to other persons as described in paragraph (c) above, or for requesting the consent or no objection of the data subject as described in paragraph (d) above. If Eloan Financial Services Limited will receive any money or other property in return for providing information to other persons, Eloan Financial Services Limited will inform the data subject.
10. If you do not want Eloan Financial Services Limited to use or provide your personal data to others for direct marketing as described above, you may exercise your right to opt-out of marketing by notifying our Data Protection Officer through the means described in paragraph 17 below.
Access and Correction of Personal Data
11. Under the terms of the Ordinance and the Code of Practice on Personal Credit Information (the “Code”), you have the right to:
1. Check whether Eloan Financial Services Limited holds your personal data and access such data;
2. Request Eloan Financial Services Limited to correct any inaccurate personal data held about you;
3. To ascertain Eloan Financial Services Limited’s policies and practices in relation to personal data and to be informed of the types of personal data held by Eloan Financial Services Limited;
4. In relation to consumer credit, you may request to be informed of which information will be routinely disclosed to credit reference agencies or debt collection agencies, and obtain further information from Erdai Finance Limited in order to make a request to the relevant credit reference agencies or debt collection agencies to access and correct the information; and
5. In relation to consumer credit, upon closure of an account after full repayment, instruct Eloan Financial Services Limited to request the credit reference agency to delete any account information relating to the closed account from its database, provided that such instruction is made within five years of closure and there is no material default.
12. If you default on repayment, unless the amount in arrears is fully repaid or written off (except in the case of a bankruptcy order) before the expiry of 60 days from the date of default, the credit reference agency may retain the repayment data (as defined in the Code) of the account until five years have passed since the date of full repayment of the amount in arrears.
13. If any account balance is written off due to a bankruptcy order being made against you, regardless of whether the account repayment data (as defined in the Code) shows any material default, the account repayment data will continue to be retained by the credit reference agency for a further period of 5 years after the default repayment is fully settled, or after you have provided evidence to notify the credit reference agency that you have been discharged from bankruptcy, whichever is the earlier.
14. For the purposes of this Statement, we may obtain a credit report on you from a credit reference agency when considering any application for credit. If you wish to view the credit report, we will inform you of the contact details of the relevant credit reference agency.
15. For the purpose of this paragraph (Access and Correction of Personal Data), account repayment information refers to the last due payment, the repayment amount made during the last reporting period, the remaining available credit or outstanding amount and outstanding balance information (i.e. the overdue balance, the number of days overdue, the date on which the overdue balance is settled and the date on which the material outstanding balance (i.e. the outstanding balance that is overdue for more than sixty (60) days, if any) is fully settled).
16. In accordance with the terms of the Ordinance, Eloan Financial Services Limited has the right to charge a reasonable fee for the processing of any data access request.
17. You should send any requests for access to personal data or correction of personal data, or any inquiries regarding our policies and practices regarding personal data to:
Data Protection Officer
Eloan Financial Services Limited
Address: Flat/RM 01 11/F Tern Plaza No.5 Cameron Road Tsim Sha Tsui KL
Email:eloanhk@gmail.com
Personal data of another person
18. If you provide us with information about another person, you should provide that person with a copy of this statement and should specifically inform that person how we will use their information.
Other
19. This statement does not limit the rights of data subjects under the Ordinance.
20. Where permitted by law, we and other members of the Eldai Financial Group may record and monitor electronic communications with you to ensure compliance with legal and regulatory requirements and internal policies.
21. In case of any discrepancy between the Chinese and English versions, the English version shall prevail.
English 
Chinese