Privacy Policy and Personal Information Collection Statement

K Cash Limited (hereinafter referred to as the "Company")

Privacy Policy

This Privacy Policy describes the Company's policies and practices regarding the handling of personal data. The Company strives to protect the privacy, security and confidentiality of personal data held by the Company by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance") in the management of personal data. The Company is equally committed to ensuring that all employees and agents comply with these obligations. The definitions of each term in this Privacy Policy are as follows:

Account has the meaning ascribed to it under the Code of Personal Credit Information, including any account between the Company and the Client in relation to the provision of Personal Credit and any new account established for the purpose of any debt repayment arrangement involving one or more prior accounts;
Account Information means any information generated by the Company in the course of operating a Customer's account and as defined in the Personal Credit Data Code;
Code of Credit for Consumer Credit Data means the Code of Practice on Consumer Credit Data issued by the Hong Kong Privacy Commissioner for Personal Data;
Code on Identity means the Code of Practice on Identity Card Numbers and Other Identification Codes issued by the Hong Kong Privacy Commissioner for Personal Data;
Credit Data Bureau means a credit data agency or provider of similar services;
Credit Report has the meaning ascribed to the Code on Consumer Credit Information, i.e. a report provided by a credit reference agency in respect of an individual, which contains the personal credit information held by the credit reference agency in its database about that person, whether disclosed in any form;
Customer means the Company's customers;
Information means personal data and account information;
Loan Services means mortgage, credit and other loan services and facilities;
Group Companies means the Company or any other member of the group of companies to which the Company belongs;
Personal Data has the definition given by the Ordinance and shall include information directly or indirectly about the customer that can be used to identify the customer concerned, and the existence of such information shall be in a form practicable for access to and processing;
Referral Service means mortgage, credit and other loan services and facilities;
Services and credit facilities means the various i) loan service services and ii) referral services provided by the Company and Group companies in the course of their business.
  1. Customers or other data providers need to provide their personal data to the Company from time to time in order to apply for various services and credit facilities. Personal data of customers is also collected in the course of the Company's normal financial and business relationship with customers. The information involved includes, but is not limited to:
    1. Full name;
    2. The identity card number or travel document number includes photocopies of identity cards and travel documents and information embedded in their integrated circuits;
    3. Date of birth;
    4. residential and/or correspondence address;
    5. Phone/mobile phone number;
    6. Email address;
    7. Biometric data, including but not limited to facial images and biometric data stored in biometric identity and/or travel documents, whether or not collected by the User's electronic device or other means using a biometric data sensing module;
    8. salaries and income;
    9. household expenses and number of dependants;
    10. and such other or further information as the Company deems necessary.
  2. The Company's use of personal data of customers and other data providers for purposes is divided into mandatory and voluntary. Data for mandatory purposes means that the customer or data provider must provide the Company with their data if they wish the Company to provide various services and credit facilities. If the customer or data provider fails to provide such information, the Company may not be able to provide the relevant services and credit facilities. For example:
    1. For clients who are sole proprietors or partnerships, the Company may collect identity card or passport numbers and copies of the sole proprietor or relevant partners during the application stage and during the provision of various services and credit facilities in order to verify the identity of such persons in accordance with the relevant regulatory requirements against money laundering and terrorist financing during the "customer vetting" process;
    2. For clients who are companies, the Company may also collect the identity card or passport number of their authorised person (who may be a director of the company) for the purpose of verifying the identity of that person;
    3. The Company may also collect the identity card or passport number of the customer's guarantor to verify the identity of the guarantor;
    4. In relation to paragraphs 2(ii) and 2(iii) above, the Company is required to check whether the data provider has been provided with the correct identification number in accordance with the requirements of the Identity Code. In order for the Company to carry out the above checks, the relevant guarantor or an authorised person of the Client (who may be a director of the Company) may elect:
      1. Present your HKID card or passport to the Company in person; or
      2. If the company decides not to present the above documents in person, he or she may provide the company with a copy of his/her identity card or passport.
  3. Customers or other data providers are required to provide mandatory data for the following purposes:
    1. To provide various services and credit facilities, including but not limited to the implementation of instructions in relation to specific transactions or otherwise;
    2. decide whether to provide various services and credit facilities to customers;
    3. conducting credit checks (including but not limited to conducting such checks when customers apply for credit and regularly review credit);
    4. establishing and maintaining the Company's credit and risk-related model;
    5. Assist other financial companies and institutions in conducting credit checks and debt collection;
    6. ensuring that the credit standing of the customer or relevant data subject is in good standing;
    7. designing financial services or related products for clients;
    8. determine the amount of debt owed or owed by the customer or the relevant information provider;
    9. enforce debts owed by the Client or the relevant data provider to the Company, including but not limited to recovery of amounts owed by the Client or the relevant data subject;
    10. To comply with the various data use and disclosure obligations, requirements, recommendations, instructions or arrangements applicable to or expected to comply with the Company or a member of the Group in accordance with the following legal requirements:
      1. any laws now and in the future governing or applicable to Hong Kong or outside Hong Kong of the Company or a member of the Group;
      2. any guidance, guidance or requirement given or issued by any legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry body or association of financial service providers, now and in the future, in Hong Kong or outside Hong Kong;
      3. any present or future contract or other commitment imposed on the Company and its Group Members, or entered into with the Company and the Group Members, by Hong Kong or foreign legal, regulatory, governmental, tax, law enforcement or other authorities or self-regulatory or industry bodies or associations of financial service providers due to the financial, commercial, business, various rights or activities of the Company and the Group Members;
    11. to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing and/or sharing data and information with Group Companies in order to conduct "customer clearance" procedures, comply with anti-money laundering and counter-terrorist financing requirements and/or in general act in accordance with any common group programmes established by the Company to comply with sanctions or to prevent or detect money laundering, terrorist financing or other illegal activities;
    12. to the Company's assignee or prospective transferee (including, without limitation, any person with whom the Company intends to merge or to whom the Company intends to sell all or any part of its business), a participant or sub-participant of the Company's rights in respect of the Client, to be able to evaluate the subject matter of the assignment, merger, disposal, participation or sub-participation; and
    13. Other uses directly related to the above.
    The Company may carry out "verification procedures" as defined in the Ordinance for all the above purposes.

  4. The Company wishes to use the following types of data for direct marketing purposes in the manner specified in this paragraph – The Company uses personal data in direct marketing for voluntary purposes only. This means that customers have the right to choose whether or not the Company may use their data for such purposes.
    In this regard:
    1. The Company may, from time to time, use the full name, contact details (e.g. telephone number, email address or correspondence address) and K Cash account number of the customer or the relevant data provider held by the customer or the relevant information provider for direct marketing purposes;
    2. The Company may promote various services and credit facilities;
    3. In addition to the above promotional services and credit facilities, the Company may provide such information to the following parties:
      1. the Company's partners (the Company will from time to time list and/or update the Company's partner list on the homepage of the Application and/or the Company's website);
      2. any person who has obtained the agreed consent of the Client; and
      3. Konew Fintech Corporation Limited and its subsidiaries, MoneySQ Fintech Corporation Limited and its subsidiaries, K Cash Corporation Limited and its subsidiaries
        For the following purposes: In this regard, please note:
        1. The Client's name, contact information, including but not limited to: full name in Chinese and English, held by the Company from time to time; Date of birth; residential and/or correspondence address; Phone/mobile phone number; Email address; and other or further information, product and service portfolio information, transaction patterns and behaviour, financial background and demographic data that the Company deems necessary for direct marketing;
        2. May be used to promote the following categories of services, products and promotions:
          1. reward, loyalty or privilege programmes and related services and products;
          2. products and services of above mentioned companies and persons including latest news, offers, promotions, coupons and coupons on loan services, referral services and blockchain technology, technology, real estate, food and beverage industry services, products and programs, and products. The business of the Company's partners includes finance-related services and products, electronic products, computers and accessories, audio-visual products, clothing and accessories, food and beverage, entertainment, cinemas, shopping mall consumption and promotion, furniture, home appliances and supplies, transportation, retail, fuel, tourism, hotels, education, stationery, health care, toys, watches and jewellery, hair products, beauty and cosmetics, logistics, membership, banking, credit cards, insurance, telecommunications, e-commerce and other consumer products and services; and
          3. Finance-related services, products, events or seminars.
        3. To use the customer's name and contact details referred to in paragraph 4iii 1 above for the purpose of establishing a member account on the Katch Platform, (such platform is provided and managed by Katch (HK) Limited), when customers use the Katch platform and use the services provided by the platform, they will be bound by the terms of use of the Katch platform, and the customer can view the website on the Katch website ( https://katch.hk/) Read the Terms of Use carefully. If the Customer does not wish to become a member of the Katch Platform, the Customer may write to the Company (by post, email or fax) or in any other manner acceptable to the Company, notify the Company that he/she does not wish to become a member user of the Katch Platform. If at any time after becoming a member user of the Katch platform, the customer changes his or her mind and no longer wishes to continue to become a member user of the Katch platform, the customer has the right Cancel the membership in the manner specified on the Katch platform.
    4. The Company may provide the personal data referred to in paragraph 4(i) above to members of the Group and other financial companies or institutions for the benefit and when the Company seeks the consent or no objection from the customer or the relevant information provider as described in paragraph 4(iii) above, it will indicate to the customer or the relevant data provider that the personal data is provided to others for the purpose of obtaining the revenue; and
    5. The Company and other Group Companies and other financial companies or institutions may, from time to time, engage third party marketing service providers to conduct direct marketing on their behalf and share the personal data referred to in paragraph 4(i) with the relevant third party marketing service providers for such purposes.
    Customers have the right to choose whether their personal data is used for direct marketing purposes. If at any time the Client consents to the use of his or her personal data in direct marketing but subsequently changes his/her mind, he or she has the right to write to the Data Protection Officer at the address or fax number provided below free of charge or in any other manner acceptable to the Company, to inform the Company that he/she no longer wishes the Company to use his/her personal data in direct marketing.

  5. Information held by the Company relating to the Client or the relevant data provider will be kept confidential but the Company may provide such information to the following parties (whether in the Hong Kong Special Administrative Region or elsewhere) for the purposes set out in paragraph 3:
    1. The Company or any member of the Group is under an obligation or any person to whom a member of the Group is obliged or required to make disclosure under any binding or applicable law, statute, rule or court order, or by any guidance or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authority, self-regulatory or industry body or financial services provider association, or under any contractual obligation, including but not limited to the Hong Kong Monetary Authority, Securities and Futures Commission, Hong Kong Police Force, Independent Commission Against Corruption and Office of the Privacy Commissioner for Personal Data;
    2. any person who has obtained the consent of the customer or the person providing the relevant information;
    3. Any intermediary, contractor or third party service provider who provides administrative, telecommunications, computer, payment, debt collection, securities settlement, data processing to the Company. and in the operation of the Company's business, providing marketing or other services;
    4. Konew Fintech Corporation Limited and its subsidiaries , MoneySQ Fintech Corporation Limited and its subsidiaries, K Cash Fintech Corporation Limited and its subsidiaries
    5. persons under a duty of confidentiality to the Company, including members of the Group that have undertaken to keep such information confidential;
    6. any financial firm or institution in which the Client is conducting or proposing to enter into a transaction;
    7. the Company's assignee or prospective assignee, or the assignee of the Company's rights in respect of the Client (including but not limited to the Hong Kong Mortgage Corporation Limited ("HKMC"), or such other person as may be necessary or necessary pursuant to a contractual arrangement with the HKMC in respect of the sale of mortgages or other collateral by the Company;
    8. a person who writes a cheque to the customer's bank to be able to confirm to that person that the cheque has been paid to the relevant customer;
    9. credit reference agencies and, in the event of arrears, to collection companies;
    10. any person with whom the Company intends to merge or to whom the Company intends to sell all or any part of its business;
    11. If the customer or data provider has given consent in accordance with paragraph 4 above, the customer or the relevant data provider has consented to the transfer of their personal data by the Company for voluntary direct marketing purposes.
  6. In the event of default, the account details and mortgage loan details held by the credit reference agency for the relevant customer and/or guarantor and/or mortgagor will be retained for another year after full repayment of the arrears (except as a result of a bankruptcy order), unless the amount in default is fully repaid or written off before the expiry of 60 days from the date of default. If any amount is written off as a result of a bankruptcy order, regardless of whether the account information shows any serious default of repayment for more than 60 days, the account information and mortgage loan information will be retained by the reference agency for a period of five years after the arrears have been fully repaid, or for a further period of five years after the customer has notified the credit reference agency that it has been discharged from the bankruptcy order, whichever is earlier.
  7. In the case of a consumer credit application, when the customer closes the account by paying off the sum in full, and there has been no material default (more than 60 days in arrears) in the five years immediately preceding the closing of the account, the customer has the right to instruct the Company to request the credit reference agency to delete from the database of the credit reference agency any account information relating to the said closed account and any information relating to the mortgage loan (if applicable).
  8. The Company may obtain a credit report from a credit reference agency in connection with any application to the Company for various services and credit facilities. If the Client wishes to access the credit report, the Company will provide the contact details of the relevant credit reference agency so that the customer can obtain a copy of the credit report and contact the credit reference agency to process the change request.
  9. In addition, for the purpose of reviewing the existing consumer credit facilities, the Company may from time to time enquire the consumer credit information held by credit reference agencies in relation to customers to facilitate the Company's consideration of the following:
    1. increase credit lines;
    2. reduction of credit granted (including but not limited to cancellation or reduction of credit facility); and
    3. Establish or implement a debt repayment arrangement plan for the client.
  10. Subject to the provisions of the Ordinance and the Consumer Credit Data Code, any data provider has the right to:
    1. to enquire whether the Company holds personal data about it and access such personal data;
    2. require the Company to correct any inaccurate personal data relating to it;
    3. enquire about the Company's policies and practices in relation to the holding of personal data and to understand the nature of the data held by the Company;
    4. In relation to consumer credit information, upon request, the information (including information on mortgage loans (if applicable) that will be routinely disclosed to credit reference agencies or debt collection agencies and further information is requested for the purpose of making requests for access and correction of data to the relevant credit reference agencies or debt collection agencies. Subject to the requirements of the Ordinance, the Company reserves the right to charge a reasonable fee to the person who makes the data access request.
  11. Any request for access to or correction of personal data, access to relevant policies and practices, or enquiry about the types of personal data held by the Company should be addressed to the following persons:
    K Cash Limited, Personal Data Protection Officer,
    17/F, Wheelock House, 20 Pedder Street, Central, Hong Kong
    Tel: (852) 2110 2110
    Fax: (852) 2110 0300

  12. This Privacy Policy does not limit the rights of customers or data subjects under the Ordinance.
    These Terms are subject to Chinese version. In the event of any conflict between the language versions of this Privacy Policy in the future, the Chinese version shall prevail.

Personal Data Collection Statement
K Cash Limited and its group members (collectively referred to as "the Group" or "we") are committed to the proper handling and protection of all information provided by customers. The Group adheres to the principles of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Privacy Ordinance") to collect, store, process, use and transfer data for lawful or related reasons and ensure its accuracy. The Group will take all practicable steps to ensure the security of personal data against unauthorised or accidental access, erasure, use or other use.
Section 1: Purpose and Use
From time to time, our customers must provide us with your personal data in order for us to provide and manage relevant products and services. Otherwise, we may not be able to provide or continue to provide services to you. The data we collect may be used for the following purposes:
  1. To provide credit facilities and day-to-day operational services;
  2. Conduct credit checks (including but not limited to personal credit applications and regular credit reviews) where appropriate;
  3. establishing and maintaining the Group's credit and risk-related models;
  4. To ensure that customers maintain reliable credit and good reputation;
  5. Design suitable financial products and services for customers;
  6. Promote loan products or services;
  7. determining the amount of the client's debts (including claims and liabilities);
  8. exercising our rights under our contracts with our clients, including collecting amounts owed;
  9. Let debt collection agencies collect debts;
  10. To perform the obligations of the Group, subsidiaries or affiliates, whether voluntary or not, to comply with any law, regulation, court order, guideline or internal policy.

Section 2: Transfer of Personal Data
The data held by us will be kept strictly confidential but may be provided to the following parties (whether outside or outside the Hong Kong Special Administrative Region) for the above reasons:
  1. all associated companies, subsidiaries or affiliates of the Group;
  2. Any agent, contractor and third party service that provides administrative, telecommunications, computer, bill payment, data processing or storage and other services to us in connection with the operation of our business
  3. any credit reference agency or, in the event of late repayment, to any debt collection agency;
  4. any substantial or proposed transferee, transferee, participant or sub-participant; and
  5. Any body that obliges us to comply with binding laws, rules, regulations, codes of conduct or guidelines, including but not limited to any relevant regulators, government agencies, industry accreditation bodies or other legally recognised bodies.

We will not disclose the information collected to any person or organization without your prior consent.

The Group (in its own capacity and/or as an agent) may provide the following information about the data subject (including any of the following as updated from time to time) to credit reference agencies in relation to the data subject's mortgage application (whether as borrower, mortgagor or guarantor and whether in a single name of the data subject or in joint name with another person) relating to the data subject's mortgage application on or after 1 April 2011:
  1. Full name;
  2. In respect of the identity of each mortgage (i.e. as borrower, mortgagor or guarantor, and whether in the sole name of the data subject or in joint name with another person)
  3. Hong Kong Identity Card number or travel document number;
  4. Date of birth;
  5. correspondence address;
  6. mortgage account number for each mortgage;
  7. the type of credit for each mortgage;
  8. the status of the mortgage account for each mortgage (e.g. effective, closed, write-off (other than for bankruptcy order), write-off due to bankruptcy order); and
  9. Mortgage account end date for each mortgage (if applicable).

The credit reference agencies will use the above information provided by the Group to share in the credit reference database the number of mortgages held by the data subject (as borrower, mortgagor or guarantor respectively, and whether individually or jointly with other persons) with credit providers in the Hong Kong Special Administrative Region from time to time for sharing in the credit reference database (subject to the requirements of the Code of Practice on Consumer Credit Information approved and issued under the Ordinance). The Group may check the number of mortgages held by credit reference agencies from time to time during the following periods:
  1. consider mortgage loan applications submitted by data subjects;
  2. reviewing and/or renewing any mortgage loan provided or proposed to be made to the data subject;
  3. consider applications for consumer credit loans (other than mortgage loans) submitted by data subjects (whether the data subject is a borrower, mortgagor or guarantor); and
  4. Review and/or renew any consumer credit facility (other than mortgage loans) provided or proposed to be provided to the data subject (whether the data subject is a borrower, mortgagor or guarantor).


Section 3: Use and Provision in Direct Marketing
We are our valued customers and we are happy to keep you informed about our latest products, services and promotions. With your consent, we may use your personal data for direct marketing. Please note :
The Company may provide such information to the following parties:
  1. the Company's partners (the Company will from time to time list and/or update the Company's partner list on the homepage of the Application and/or the Company's website);
  2. any person who has obtained the agreed consent of the Client; and
  3. Konew Fintech Corporation Limited and its subsidiaries , MoneySQ Fintech Corporation Limited and its subsidiaries, K Cash Fintech Corporation Limited and its subsidiaries
For the following purposes: In this regard, please note:
  1. The Client's name, contact information, including but not limited to: full name in Chinese and English, held by the Company from time to time; Date of birth; residential and/or correspondence address; Phone/mobile phone number; Email address; and other or further information, product and service portfolio information, transaction patterns and behaviour, financial background and demographic data that the Company deems necessary for direct marketing;
  2. May be used to promote the following categories of services, products and promotions:
    1. reward, loyalty or privilege programmes and related services and products;
    2. products and services of above mentioned companies and person, including latest news, offers, promotions, coupons and coupons on loan services, referral services and blockchain technology, technology, real estate, food and beverage industry services, products and programs, and products. The business of the Company's partners includes finance-related services and products, electronic products, computers and accessories, audio-visual products, clothing and accessories, food and beverage, entertainment, cinemas, shopping mall consumption and promotion, furniture, home appliances and supplies, transportation, retail, fuel, tourism, hotels, education, stationery, health care, toys, watches and jewellery, hair products, beauty and cosmetics, logistics, membership, banking, credit cards, insurance, telecommunications, e-commerce and other consumer products and services; and
    3. Finance-related services, products, events or seminars.
  3. The name and contact details of the customers mentioned above are used to establish a member account on the Katch Platform, (such platform is provided and managed by Katch (HK) limited), and when customers use the Katch platform and the services provided by the platform, they will be bound by the terms of use of the Katch platform, which can be found on the Katch website ( https://katch.hk/) Read the Terms of Use carefully. If the Customer does not wish to become a member of the Katch Platform, the Customer may write to the Company (by post, email or fax) or in any other manner acceptable to the Company, notify the Company that he/she does not wish to become a member user of the Katch Platform. If at any time after becoming a member user of the Katch platform, the customer changes his or her mind and no longer wishes to continue to become a member user of the Katch platform, the customer has the right Cancel the membership in the manner specified on the Katch platform.

Customers have the right to choose whether their personal data is used for direct marketing purposes. If at any time the Client consents to the use of his or her personal data in direct marketing but subsequently changes his/her mind, he or she has the right to write to the Data Protection Officer at the address or fax number provided below free of charge or in any other manner acceptable to the Company, to inform the Company that he/she no longer wishes the Company to use his/her personal data in direct marketing.

Part 4: Biometric techniques
The Group may collect the following biometric data from customers for use in identification systems, including ATMs:
  1. Finger veins
  2. Facial features
All identified biometric data will not be stored. This service is provided voluntarily by the customer to provide a flexible customer experience

Part 5:
Access to and Correction of Personal Data Under and in compliance with the terms of the Personal Data Ordinance, you have the following rights:
  • check whether we hold and have access to information about you;
  • request that we correct inaccuracies in their personal data;
  • For any account assets provided by the Group to a credit reference agency (including any account repayment information for the avoidance of doubt), after full repayment of the loan or within 5 years from the date of formal termination of the credit, if the Group determines that its credit has not been in arrears for more than 60 days, the Group has the right to request the relevant credit reference agency to delete your account information for the terminated credit (if the account has more than 60 days of default on repayment record, or the data subject has been broken by the enactment). If any amount in the account is written off as a result of the property order, the credit reference agency may retain account repayment information for a period of 5 years from the date of full settlement of the amount owed or by the data subject providing evidence notifying the credit reference agency that it has been released from the date of the bankruptcy order (whichever comes first)
  • In the case of consumer credit, to request to know what information is to be disclosed to credit reference agencies or debt collection agencies on a regular basis, or to request further information for the purpose of making access and correction requests to the relevant credit reference agencies or debt collection agencies; and
  • Enquire about the Group's policies and practices with respect to personal data and to understand the categories of personal data held.

Access and correction requests shall be submitted in writing to:
Data Protection Officer
K Cash Limited
17/F, Wheelock Building, 20 Pedder Street, Central, Hong Kong
Fax: (852) 2110 0300

Under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong), we have the right to charge a reasonable fee for any data access request.

Notice on access to personal credit reports
K Cash Limited and its group members collectively referred to as the "Group") are committed to providing consistently high quality services to our valued customers. In order to endeavour to provide services that are more relevant to you, we may periodically review your existing credit facilities and check your personal credit information with a credit reference agency for testing purposes
Consider:
  1. Increase the credit limit,
  2. credit reduction (including cancellation or reduction of credit limit); or
  3. Formulating or implementing debt arrangement schemes.
After enquiry, enquiry records will be retained for reference and you may contact the following credit reference agencies for enquiry by yourself.
TransUnion Information Limited
8/F, Tower 5, Gateway Building, 15 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong

statement
I/We confirm that I have read and understood the Personal Information Collection Statement ("PICS").
I/We hereby give my/our acknowledgement and consent to K Cash Limited in accordance with PICS
Use and transfer of my/our personal data, including using and providing my/our personal data for direct marketing.
Note: If you do not agree to the use of the personal data you have provided for direct marketing purposes as set out in Section 3 "Use and Provision in Direct Marketing", please write to the Data Protection Officer at the address or fax number provided in this Statement or in any other manner acceptable to the Company that he/she no longer wants the Company to use his/her personal data in direct marketing. We will not use your personal information for direct marketing.
This statement is subject to version Chinese. In the event of any conflict between the language versions of this Privacy Policy in the future, the Chinese version shall prevail.
Effective date: July 7, 2023