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Personal Data Privacy and Personal Information Collection Statement

This Statement applies to Cashing Pro Limited (referred to as “Cashing Pro” or “The Company”).

In this Statement, the term “data subjects”, “you” or “customer” shall include visitors to the Company’s website, users of Cashing Pro’s official WhatsApp (+852-2366-8859), applicants for loan facilities, guarantors for loan facilities and customers of loan facilities. In addition, in this statement, the term “group company” refers to the Company’s local and overseas group companies (such as parent companies or subsidiaries of the same holding).

The content of this Statement shall apply to all data subjects and form part of the terms and conditions of the Loan Agreement and/or any agreement or arrangement that the data subjects have or may enter into with Cashing Pro from time to time. In the event of any inconsistency or discrepancy between this Statement and the relevant agreement or arrangement, this Statement shall prevail insofar as it relates to the protection of the data subject’s personal data.

Privacy Policy Statement

1. The Company’s privacy policy and commitment

Cashing Pro values your privacy. Cashing Pro is committed to ensuring our staff to follow and implement the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”), and the guidance from the Hong Kong S.A.R. Licensed Money Lenders Association Limited based on the Ordinance in order to fully protect the privacy of your data from leaking. This Statement is intended to assist you in understanding Cashing Pro’s privacy policies and practices in relation to personal data.

2. Purpose and Collection of collecting personal data

2.1 

Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. In order to enable Cashing Pro to provide better services, it is necessary from time to time for customer to provide Cashing Pro with personal data when opening or continuing loan accounts, establishing or continuing loan facilities or receiving other financial services. We may collect the following data relating to you, which may become personal data from time to time, including but not limited to:

a. Name;

b. HKID number or passport number, including copies of the identity card and travel document and data embedded in the integrated circuits in such documents;

c. Nationality or residency status;

d. Birth date;

e. Biometric data; including but not limited to facial image(s) and data embedded in biometrically enabled identity and/or travel documents whether obtained through biometric sensor moduled on the electronic devices of the data subject(s) or otherwise;

f. Telephone/mobile phone number(s);

g. Personal financial status;

h. Income or assets information;

i. Employment information;

j. Residential information;

k. Bank account or stored value facility account details;

l. The content of all conversations between you and Cashing Pro, including your browsing and use of the Cashing Pro’s website, the content of the conversation data of Cashing Pro’s official WhatsApp, and the content of the call, is for the purpose of identifying the individual who uses the Company’s services, assisting in the investigation and handling of complaints, and resolve any disputes that may arise in the future;;

m. Any other or further information regarding loan application approval, loan account management or maintenance that Cashing Pro deems necessary.

2.2 Failure to supply such personal data may result in Cashing Pro being unable to open or continue loan accounts, or to establish or continue loan facilities, or to provide other financial services to customers.

2.3 In the normal course of business, for example, customers communicate with Cashing Pro verbally or in writing (including but not limited to e-mail, postal mail), Cashing Pro will also collect personal data from customers through electronic records or telephone recordings (depending on situation). This includes information obtained from credit reference agencies approved for the participation in the Multiple Credit Reference Agencies Model (“credit reference agencies”).
Multiple Credit Reference Agencies Model is developed by the Hong Kong Association of Banks, the Hong Kong Association of Restricted Licence Banks and Deposit-taking Companies, and the Hong Kong S.A.R. Licensed Money Lenders Association Limited, with the support of the Hong Kong Monetary Authority. It is a new operating model for, among others, enabling lenders to share and use consumer credit data through more than one credit reference agencies. For details on the Multiple Credit Reference Agency Model, please refer to: https://www.hkab.org.hk/en/industry-infra/overview-of-mcra/

2.4 In order to enable Cashing Pro to provide better services, subject to consent of customers, personal data of customers may be obtained from credit reference agencies (whose contact details can be provided upon request). Cashing Pro may also obtain personal data through different channels, such as public registers, public search engines, public directories or any social media in the public domain with settings authorized for public viewing by customers. In addition, device information may be collected from data subjects’ web browsers.

2.5 

The personal data of data subjects may be used by Cashing Pro for the following purposes:

a. processing and approving applications for products and daily operation related to providing loan services to customers;

b. conducting credit checks for new application, re-application or renewal application of data subjects;

c. Cashing Pro shall have the right to inquire data subject’s credit information for the purposes of processing loan application and assessing future repayment within the credit reference agencies. Credit Information includes information in whole or in part such as amount applied for, instalment periods, approval, rejection, payout, overdue payment, arrears, debt collection agencies, bad debt, and interest arrears.

d. In order to obtain data subject’s credit assessment, Cashing Pro is entitled to upload data subject’s credit data and subsequent repayment status data to the credit reference agencies to facilitate the approval of the loan application and/or the provision of the related financial services;

e. credit data uploaded by data subject, may be used as credit reference by other companies and organizations of the credit reference agencies;

f. creating and maintaining the Cashing Pro’s credit scoring or risk related models;

g. ensuring ongoing credit worthiness and good standing of data subjects;

h. updating the personal information of data subjects from time to time for assisting the Company and other credit providers in the Hong Kong approved for participation in Credit Data Smart (Multiple Credit Reference Agencies Model) to conduct credit checks and collect debts;

i. designing and developing loan/credit facilities and related financial products and services for data subjects’ use;

j. determining the amounts of indebtedness owed by data subjects to Cashing Pro;

k. exercising the Company’s rights under contracts with data subjects including collecting amounts outstanding from data subjects;

l. 

ensuring Cashing Pro and any company within the group company to implement and comply with such obligations, regulations or arrangements related to the disclosure or use of data:

i. any law, regulation, judgment, court order, voluntary code, sanctions regime applicable to the Company or group company, issued within or outside the Hong Kong Special Administrative Region (“HKSAR”) existing currently or in the future.

ii. any guidelines, guidance, rules or codes of practice or requests given, published or issued by any law, regulatory, governmental, tax, law enforcement or other authorities, relevant stock exchange, self-regulatory or industrial bodies or associations of financial service providers within or outside HKSAR existing currently or 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 Cashing Pro or any group company by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction or the relevant local or foreign legal, regulator, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;

m. complying with any obligations, requirements, policies, procedures, measures or arrangements of Cashing Pro or group company for the use of data and information in accordance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

n. enabling an actual or proposed assignee or transferee of all or any part of the Cashing Pro’s business and/or assets, or participant or sub-participant of the Cashing Pro’s rights in respect of loans/credit facilities relating to data subjects, to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation and enabling the actual assignee or transferee to use such data in the operation of the business or rights assigned;

o. comparing data of data subjects or other persons for credit checking, data verification or otherwise producing or verifying data, whether or not for the purpose of taking action against such data subjects;

p. maintaining a credit history or otherwise, a record of data subjects (whether or not there exists any relationship between data subjects and the Company) for present and future reference;

q. managing, upgrading, maintaining or providing Cashing Pro’s official WhatsApp and processing or responding to any data subjects’ enquiries or requests through Cashing Pro’s official WhatsApp;

r. conducting marketing research or internal study for providing better loan services;

s. subject to the consent of data subjects, direct marketing services, marketing products, services and related matters as described in paragraph 8 below; and

t. purposes incidental, associated or relating thereto. In relation to personal data of customers, the purposes listed in paragraphs (a) to (q) (inclusive) and any purposes related thereto are “obligatory” purposes, meaning that customers must permit Cashing Pro to use their personal data for these purposes if they wish to use Cashing Pro’s services. The purposes listed in paragraph (r) and (s) and any purposes related thereto are “voluntary” purposes, meaning that customers have a choice whether Cashing Pro can use their personal data for these purposes and if a customer does not want Cashing Pro to use his/her personal data for those purposes, he/she can tell Cashing Pro and Cashing Pro will not use his/her personal data for those purposes.
In relation to personal data of Third Parties, the purposes listed in paragraphs (a) to (s) and any purposes related thereto are “voluntary” purposes, meaning that Third Parties have a choice whether Cashing Pro can use their personal data for these purposes and if a Third Party does not want Cashing Pro to use his/her personal data for these purposes, he/she can tell Cashing Pro or the customer of his/her wish not to disclose such personal data to Cashing Pro, and the customer shall not thereafter provide such personal data to Cashing Pro and Cashing Pro will not use his/her personal data for those purposes if Cashing Pro is aware that Third Party does not consent to the use of such personal data for such purposes.

3. Categories of possible transferees of personal data

All personal data held by Cashing Pro will be kept confidential but Cashing Pro may disclose or transfer such information to the following parties for the purposes set out in paragraph 2 above:

3.1 Any service provider who, for the purpose of credit facilities, establishment, operation, maintenance or provision of loan services, provides administrative, mailing, telecommunications, telemarketing, direct selling agent, data services, computer, payment, data processing, regulatory, compliance, law enforcement, professional, consulting debt collection or other dealings with Cashing Pro or any entity within the group of companies (including its employees, officers, agents, contractors, service providers, professional advisors or third-party service providers);

3.2 Any other person who is under a duty of confidentiality to Cashing Pro and has undertaken to keep such information confidential;

3.3 Any person to whom Cashing Pro is obliged or otherwise required to make “Relevant Disclosure”; and “Relevant Disclosure” means: a disclosure under any law binding or applicable to Cashing Pro; or by any government, legal, law enforcement, regulatory, tax or other authority, or financial services provider’s self-regulatory or industry body or organization made or promulgated by Cashing Pro is expected to comply with any guidance and any disclosures to which it refers; or any disclosure pursuant to any contractual commitments or other commitments between Cashing Pro and local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or financial service providers’ self-regulatory or industry bodies or organisations (the above may be are currently or in the future in force within or outside HKSAR);

3.4 Any entities within the Group Company of Cashing Pro;

3.5 Any person with the express prescribed consent of customers or Third Parties (as the case may be);

3.6 Credit reference agencies, and, in the event of default, debt collection agencies;

3.7 External service providers that Cashing Pro engages for the purpose set out in paragraph 2.5(r) and 2.5(s) above;

3.8 Any actual or proposed assignee of Cashing Pro or participant or sub-participant or transferee of Cashing Pro’s rights in respect of the customers; and

3.9 Personal data collected in HKSAR by Cashing Pro may be transferred to a place inside or outside HKSAR.

4. Security of personal data

The policy of Cashing Pro is to ensure sufficient protection to personal data and to fully comply with the requirements under the Ordinance (especially Data Protection Principle 4 under the Ordinance) based on the degree of sensitivity of the data and damage arising from unauthorized access. To prevent data from being accessed, processed or used for other purposes without authorization, Cashing Pro is used to provide secured data storage to limit the access of physical contact. Cashing Pro also takes steps to ensure that persons accessing such information are of good conduct, prudence and competence. Information will only be transmitted in a secure manner.

5. Accuracy of personal data

Cashing Pro’s policy is to ensure that all personal data collected and processed by Cashing Pro is accurate and fully complies with the requirements under the Ordinance (in particular Data Protection Principle 2 under the Ordinance). Cashing Pro implements appropriate procedures to regularly check and update all personal data to ensure that the data is accurate for the purpose for which it is or will be used. If personal data held by Cashing Pro contains a statement of opinion, Cashing Pro will take all reasonably practicable steps to ensure that any facts quoted in support of the statement of opinion are correct.

6. Collection of personal data

6.1 In the course of collecting personal data, Cashing Pro will provide the individuals concerned with a link to the “Personal Information Collection Statement” before the data subjects submit the loan application form, informing them of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data and other relevant information.

6.2 In relation to the collection of personal data by online, the following practices are adopted by the Company:

6.2.1 Online security The Company will follow strict standards of security and confidentiality to protect any information provided to the Company online. Encryption technology is employed for sensitive data transmission on the Internet to protect individuals’ privacy. For details, please refer to “Cashing Pro Online Security” (https://www.cashingpro.hk/online-security/)

6.2.2 

“Cookies”
When users visit our website may be recorded for analysis on the number of visitors to the website and Mobile Application and general usage patterns. Some of this information will be gathered through the use of “Cookies”. “Cookies” are designed to be read only by the sending website, but cannot be used to obtain a user’s hard drive data, email address or to collect sensitive information of user. Small data files are placed on data subject’s device when data subject visits Cashing Pro’s website, engages with Cashing Pro’s official WhatsApp, or clicks on the Company’s online advertisement such that the web server can later read back the cookie data from a web browser. This is useful for allowing a website to maintain information on a particular user. “Cookies” or similar technique applied to the purposes below:

a. Cashing Pro only uses “Cookies” to identify users in a specific period, and does not store sensitive information of users in “Cookies”. When users browse the Cashing Pro website, all contacts will use “Cookies” to identify users.

b. Statistical analysis of your on-site behavior such as number of visits to our site, page views, length of time spent on each page. These are aggregated and therefore anonymous.

c. In order to improve the user experience, remember your preferences when using the Cashing Pro website so that you can easily navigate both the public and member part; and

d. Use of pages visited by the data subject and links to websites opened to promote personalized products:

– make Cashing Pro’s website more relevant to the interests of you;

– provide online advertisements on Cashing Pro’s website or third-party websites that are most likely to interest you; and

– evaluate the effectiveness of Cashing Pro’s online marketing and advertising programs.

The above cookies may be placed on data subject’s device by the Company or by third parties on the Company’s behalf (for example, advertising networks and providers of external services like web traffic analysis services). These cookies will be managed by big, recognizable advertising networks and providers of external services, including but not limited to Google or Facebook. Information recorded through the use of cookies by third parties are aggregated and then shared with the Company as anonymous aggregated research data. No personal contact information about data subjects is collected or shared by third parties with the Company as a result of the use of cookies. The cookies will expire once the session is closed.

To find out more about the information-gathering practices and opt-out procedures of cookies for Google and Facebook, please visit at:

Google:

Facebook:

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

Most web browsers are initially set up to accept cookies. Should you wish not to be tracked by this kind of technology, you can choose ‘not accept’ cookies by changing the settings on your web browser. However, if you block all cookies, including strictly necessary cookies, you may not be able to use Cashing Pro’s website and Cashing Pro’s official WhatsApp properly.

e. Data correction online

Personal data may not be changed, deleted or updated once submitted online. If user cannot change, delete or update data online, you should call Cashing Pro at 2366-8859.

f. Online retention of information

Personal data collected online will be sent to related departments, contractors or service providers for processing. Personal data will not be stored in Cashing Pro website’s server normally.

7. Data retention

Cashing Pro will take all practical measures to ensure that personal data is not kept longer than is necessary to carry out the purpose for which the data is or is to be used (including any directly related purposes), unless the retention is otherwise permitted or required by law. Different retention periods may apply to the various kinds of personal data collected.

8. Direct marketing

Cashing Pro intends to use a data subject’s data to conduct direct marketing of products or services (on a voluntary basis) provided that Cashing Pro and entities in group company shall not use the personal data of the data subject for this purpose without obtaining the data subject’s prior consent (which includes an indication of no objection). In this connection, please note that:

8.1 the name, contact details, loan products and other service portfolio information, transaction pattern and behavior, financial background and demographic data of data subject held by Cashing Pro from time to time may be internally transferred and used by Cashing Pro in direct marketing;

8.2 

the following classes of services, products and subjects to be used in direct marketing:

a. Finance-related services and products;

b. Rewards, loyalty or privilege programs and related services and products;

c. Third party reward, loyalty, co-branding or privileges programme providers; co-branding partners of Cashing Pro (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be).

8.3 Cashing Pro would like to use personal data of data subjects for direct marketing purpose any purpose for direct marketing is entirely voluntary. According to the definition given by the Office of Privacy Commissioner for Personal Data, Hong Kong, the definition of “consent” also includes “an indication of no objection”. If data subjects do not wish Cashing Pro to use or provide to other persons their personal data for direct marketing as described above, or wish Cashing Pro to advise other persons to stop using their personal data for such direct marketing purpose, they may notify us of the same at any other time, without charge.
For the avoidance of doubt, Cashing Pro will not use personal data of third parties for direct marketing purposes unless they have given their express consent.

9. Access and Correction of Personal Data

9.1 

Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data (the “Code”), you have the right:

a. to check whether Cashing Pro holds personal data about you and to access such data.

b. to require Cashing Pro to correct any personal data relating to you which is inaccurate;

c. to ascertain Cashing Pro’s policies and practices in relation to personal data and to be informed of the kind of personal data held by Cashing Pro;

d. in relation to consumer credit data, to be informed, upon request, which items of personal data are routinely disclosed to credit reference agencies or debt collection agencies and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency; and

e. in relation to consumer credit data (including, for the avoidance of doubt, any account repayment data), upon termination of your account by full repayment and on condition that there has not been, to instruct the Company to make a request to the credit reference agencies to delete from its database any account data relating to your terminated account, as long as the instruction is given within five years of termination and at no time was there any default of payment in relation to the account, lasting in excess of sixty (60) days within five years immediately before account termination.
Account repayment data include amount last due, amount of payment made during the last reporting period (being a period not exceeding thirty-one (31) days immediately preceding the last contribution of account data by Cashing Pro to credit reference agencies), remaining available credit or outstanding balance and default data (being amount past due and number of days past due, date of settlement of amount past due, and date of final settlement of amount in default lasting in excess of sixty (60) days (if any)).

9.2 If you default in repayment, unless the amount in default is fully repaid or written off (otherwise than due to a bankruptcy order) before the expiry of 60 days from the date such default occurred, your account repayment data may be retained by the credit reference agencies until the expiry of 5 years from the date of final settlement of the amount in default; and

9.3 

If any amount owed by you is written off due to a bankruptcy order being made against you, your account repayment data (as defined in the Code) may be retained by the credit reference agencies, regardless of whether the account repayment data reveals any material default, until

i. the expiry of 5 years from the date of final settlement of the amount in default; or

ii. the expiry of 5 years from the date of your discharge from bankruptcy as notified to the credit reference agencies by you with evidence, whichever is earlier.。

9.4 In accordance with the terms of the Ordinance, Cashing Pro has the right to charge a reasonable fee for the processing of any data access request.

9.5 Cashing Pro has engaged TransUnion as the credit reference agency for the provision of the Consumer Credit Reference Service (as defined in the Code of Practice for the Multiple Credit Reference Agencies Model (as updated or superseded from time to time)) to enable Cashing Pro to assess credit facility applications of customers and make credit decisions. Cashing Pro may engage other credit reference agencies and Cashing Pro will disclose the name of any such credit reference agency after engagement by updating this Privacy Policy and Personal Information Collection Statement.

9.6 To co-ordinate and oversee compliance with the Ordinance and the relevant guidelines in relation thereto, and the personal data protection policies of Cashing Pro, a Data Protection Officer has been appointed by Cashing Pro. The person to whom requests for access to data or correction of data held by Cashing Pro, or for information regarding Cashing Pro’s data policies and practices and kinds of data held by Cashing Pro are to be addressed is as follows:

 

Cashing Pro Data Protection Officer

CASHING PRO LIMITED

RM 1114, 11/F, Peninsula Center, 67 Mody Road, Tsim Sha Tsui East, Kowloon

Phone: 3155 7600

 

9.7 Nothing in this Privacy Policy and Personal Information Collection Statement shall limit the rights of the data subjects under the Ordinance.

9.8 This Privacy Policy and Personal Information Collection Statement may be updated from time to time and you are advised to visit the Company’s website regularly for the latest version.

9.9 In case of any inconsistency between the English and the Chinese versions, the English version shall prevail.

Effective Date: 12 FEB 2025

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