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Important Notice

Personal Information Collection Statement Pertaining to our Customers and Applicants for Loan Facilities and Other Services ("PICS")

Personal Information Collection Statement Pertaining to our Customers and Applicants for Loan Facilities and Other Services ("PICS")

General

Throughout your relationship with WeLend Limited ("WeLend", "us" or "we"), we will collect your personal data from time to time in accordance with this PICS. WeLend is part of a group of companies under Welab Holdings Limited ("WeLab Group"), which refers to WeLend and its parent company Welab Bank Limited, holding companies, subsidiaries, representative offices and affiliates, wherever situated. Affiliates include branches, subsidiaries, representative offices and affiliates of WeLend’s holding companies, wherever situated.

 

Purpose of Collection

1. It is necessary for data subjects (in this case, you) to supply WeLend with personal data for the purposes set out in the section entitled "Use of Personal Data" below.

2. Failure to supply such personal data by you may result in WeLend being unable to (or continue to) open your accounts, provide loan facilities and other related financial services to you, or process your applications regarding such services to you or to the relevant applicants or persons linked to you.

3. For the purposes of the provision of services by WeLend, we may collect data from you directly, indirectly or from someone acting on your behalf:

  1. in the ordinary course of our business or the continuation of our relationship with you;
  2. when you browse or use our websites; and/or
  3. from other sources, for example:
    1. any member of the WeLab Group (other than WeLend);
    2. third parties such as our business partners (subject to you giving our business partners consent to transfer your data to us), a credit reference agency (“CRA”) (including any CRA approved for participation in the Multiple Credit Reference Agencies Model) and third-party service providers with whom you interact in connection with the marketing of our products and services and/or in connection with your application for and use of our products and services; and/or
    3. the public domain through different channels, including public registers, public search engines, public directories or any social media with public view setting authorised by you, cookies, behavioral or location tracking tools.

Data may be combined with other data available to any other member of the WeLab Group.

 

Use of Personal Data

4. We will use data for the following purposes or any of them (which may vary depending on the nature of your relationship with us):

  1. considering and processing applications for products and services, and the daily operation of products and services (including without limitation loan facilities and related financial products and services) provided to you, or to the relevant customer or persons linked to you;
  2. conducting credit checks whenever appropriate (including without limitation at the time of application for a loan(s) or at the time of regular or special reviews of credit which normally will take place one or more times each year);
  3. creating and maintaining WeLend’s credit-scoring models, risk-related models or anti-money laundering systems;
  4. ensuring your ongoing credit worthiness and good standing;
  5. assisting other financial institutions, including credit providers in Hong Kong approved for participation in the Multiple Credit Reference Agencies Model, to conduct credit checks and to collect debts;
  6. designing and developing loan/credit facilities and related financial products and services for customers’ use;
  7. conducting marketing research, developing and providing membership programmes or referral campaigns and customer profiling and segmentation;
  8. analysing how you access and use our products and services;
  9. subject to obtaining the consent of data subjects, direct marketing services, marketing products, services and other subjects (including without limitation cross marketing campaigns with other members of the WeLab Group) as described in paragraphs 9 and 10 below;
  10. determining the amount of indebtedness owed to or by you;
  11. in respect of mortgages, for the CRA to compile a count of the number of mortgages from time to time held by you (as borrower, mortgagor or guarantor, whether in sole name or joint names with others) for sharing in the consumer credit database of the CRA by credit providers;
  12. exercising WeLend’s rights under contracts it has entered with you, including collecting amounts outstanding under such contracts;
  13. meeting obligations, requirements and arrangements, of WeLend or its affiliates within the WeLab Group, whether compulsory or voluntary, to comply with or in connection with:
    1. any law, regulation, judgement, court order, voluntary code, sanctions regime applicable to WeLend or its affiliates within the WeLab Group, within or outside Hong Kong existing currently or in the future (“Laws”);
    2. any guidelines, guidance, rules or codes of practice or requests given, published or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, relevant stock exchange, self-regulatory or industry bodies or associations of financial service providers within or outside Hong Kong existing currently or in the future and any international guidance, internal policies or procedures;
    3. any present or future contractual or other commitment with any legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, court or other authorities, relevant stock exchange, self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction over any member of the WeLab Group (together the “Authorities” and each an “Authority”) that is assumed by, imposed on or applicable to WeLend or its affiliates within the WeLab Group; and
    4. any agreement or treaty between an Authority and WeLend or its affiliates within the WeLab Group;
  14. complying with any obligations, requirements, policies, procedures, measures or arrangements of WeLend or its affiliates within the WeLab Group and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or acts or attempts to circumvent or violate any Laws relating to these matters;
  15. facilitating consolidated supervision of the WeLab Group for the conduct of internal audit and the performance of risk management;
  16. enabling an actual or proposed assignee or transferee of all or any part of WeLend’s business and/or assets, or participant or sub-participant of WeLend’s rights in respect of your loans/credit facilities, 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;
  17. comparing your data with other persons, financial institutions and/or any member of the WeLab Group for credit checking, fraud checking, data verification or otherwise producing or verifying data in connection with your applications for, or our provision to you of, the products and services by us or any member of the WeLab Group;
  18. maintaining a credit history or otherwise, a record of you (whether or not there exists any relationship between you and WeLend) for present and future reference;
  19. in connection with WeLend defending or responding to any legal, governmental, or regulatory or quasi-governmental related matter, action or proceeding (including any prospective action or legal proceeding);
  20. in connection with us making or investigating an insurance claim or responding to any insurance related matter, action or proceeding;
  21. administering, enhancing, maintaining and providing WeLend Chatbot and processing, handling or communicating with data subjects in respect of any enquiry or requests raised by data subjects via WeLend Chatbot; and/or
  22. any other purposes relating to the purposes listed above.

 

Disclosure of Personal Data

5. All personal data held by WeLend will be kept confidential but WeLend may disclose (as such term is defined in the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”)) such information to the following parties or any of them (whether within or outside Hong Kong) for the purposes set out in paragraph 4 above:

  1. any agent, contractor, sub-contractor or associate of WeLend or its affiliates within the WeLab Group (including its employees, officers, agents, contractors, service providers and professional advisers);
  2. any third-party service provider who provides administrative, professional, advisory, telecommunication, information service, computer, payment, data processing, debt collection or other services to WeLend or its affiliates within WeLab Group in connection with the operation or maintenance of its business;
  3. the drawee bank providing a copy of a paid cheque (which may contain data about the payee) to the drawer;
  4. a CRA (including the operator of any centralised database used by a CRA under the Multiple Credit Reference Agencies Model) and, in the event of default, a debt collection agency (“DCA”);
  5. any Authority, body, association or persons mentioned in paragraph 4(m) above;
  6. any actual or proposed assignee or transferee or WeLend or, participant or sub-participant of WeLend’s rights in respect of loans/credit facilities relating to data subjects;
  7. any persons giving or proposing to give a guarantee or security to guarantee or secure your obligations to WeLend;
  8. any persons acting on your behalf whose data are provided;
  9. any payment recipients;
  10. any entity within the WeLab Group, including without limitation, WeLab Bank Limited;
  11. business partners or co-branding partners of WeLend, together with whom WeLend provides products or services to data subjects;
  12. charitable or non-profit making organisations;
  13. subject to obtaining the consent of data subjects in connection with the purpose set out in paragraph 4(i) above:
    1. third-party financial institutions, insurers, credit facilities companies, credit card companies, securities, commodities and investment services providers, third-party membership programme providers or our co-branding partners; and
    2. external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that WeLend engages for the purposes set out in paragraph 4 above; and
  14. third-party service providers engaged by you using our application programming interfaces (“API”).

 

Use of algorithmic assessments, big data analytics and artificial intelligence

6. We may use certain algorithms and big data analytics and artificial intelligence (“BDAI”) technologies and applications when considering and processing your application for the establishment of our products and services. BDAI involves computers generally to mimic human intelligence, so that they can learn, sense, think and act in order to achieve automation and gain analytics insights from large volumes of structured and unstructured data created by the preservation and logging of activity from human, tools and machines. Examples of BDAI include machine learning, biometric authentication technology, natural language processing, decision tree, internet cookies and web logs.

 

7. The algorithms and BDAI may provide automatic assessments and decisions based on the data we collected from you, which may be personal and non-personal data. Use of BDAI by us in relation to personal data is governed by this PICS. The parameters used in these assessments would have been selected to provide a fair and objective assessment of your data and tested for reliability and fairness. We have in place robust policies and procedures to ensure the security and integrity of data, and the use of BDAI is fair and in accordance with applicable laws and regulations. In addition, we may by ourselves, or via our service providers, use BDAI for: (a) analysing statistics, trends, markets, behaviour, usage patterns, customer segments and pricing; (b) planning, research and developments, designing services or products, improving customer experience; (c) predicative modelling; (d) performing credit, anti-money laundering, fraud prevention and other risk assessments; and (e) any other purposes relating thereto.

 

8. Accuracy of assessments and decisions generated by the algorithms will largely depend on the accuracy of the personal data provided. If we are uncertain about the accuracy of the data that may be used in an algorithmic assessment, we will endeavour to seek clarification from you. You may also enquire or request reviews on the decisions made by our BDAI applications via the channels which we may designate from time to time. There may be certain other risks associated with the use of algorithms, including, but not limited to, risks related to input data (e.g. a mismatch between the data used for training the algorithms and the data inputted for the purposes of the establishment and the use of any account(s) and/or any products or services), algorithm design (e.g. coding errors) as well as output decisions (e.g. incorrect interpretation of the output).

 

Direct Marketing

9. WeLend intends to use a data subject’s data to conduct direct marketing of products and services, and WeLend requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

  1. the name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data of data subject held by WeLend from time to time may be used by WeLend in direct marketing;
  2. the classes of services, products and subjects which may be marketed includes:
    1. WeLend products and services;
    2. banking or financial services, credit facilities, insurance, securities, investment, wealth management and related services, products and facilities;
    3. telecommunications network services, delivery services, travel agency services, hospitality services, food and beverages, automotive products/services, gaming products/services, entertainment and media services, lifestyle products/services, social and healthcare services, electronic and electrical products, merchandise, consumer goods and/or commodities;
    4. reward, loyalty, co-branding or privileges programmes and related services and products; and/or
    5. donations and contributions for charitable and/or non-profit making purposes;
  3. the above services, products and subjects may be provided by:
    1. any member of the WeLab Group;
    2. third party financial institutions, insurers, credit card companies, securities and investment services providers;
    3. third party reward, loyalty, co-branding or privileges programme providers;
    4. telecommunications network service providers, delivery service providers, travel agencies, hospitality service providers, food and beverages providers, automotive products and/or service providers, gaming products and/or service providers, entertainment and media service providers, lifestyle products and/or service providers, social and healthcare service providers, merchandise, consumer goods, commodities retailers, distributors and/or manufacturers;
    5. co-branding partners of any member of the WeLab Group; and/or
    6.  charitable or non-profit making organisations;
  4. in addition to marketing the above services, products and subjects itself, WeLend also intends to provide the data described in sub-paragraph (a) above to all or any of the persons described in sub-paragraph (c) above for use by them in marketing those services, products and subjects, and WeLend requires the data subject’s consent (which includes an indication of no objection) for that purpose; and
  5. WeLend may receive money or other property in return for providing the data to the other persons in sub-paragraph (c) above and, when requesting data subject’s consent or no objection as described in sub-paragraph (d) above, WeLend will inform the data subject if we will receive any money or other property in return for providing the data to the other persons.

 

10. If you do not wish WeLend to use or provide to the other persons your data for use in direct marketing as described above, you may exercise your opt-out right by notifying our Data Protection Officer, whose contact details are set out in paragraph 17 below.

 

Access and Correction of Personal Data

11. 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:

  1. to check whether WeLend holds personal data about you and to access such data;
  2. to require WeLend to correct any personal data relating to you which is inaccurate;
  3. to ascertain WeLend’s policies and practices in relation to personal data and to be informed of the kind of personal data held by WeLend;
  4. in relation to consumer credit data, to be informed, upon request, which items of personal data are routinely disclosed to a CRA or DCA and be provided with further information to enable the making of an access and correction request to the relevant CRA and DCA; and
  5. in relation to consumer credit data, upon termination of your account by full repayment and on condition that there has not been, within 5 years immediately before account termination, any material default on your account, to instruct WeLend to make a request to the CRA to delete from its database any account data relating to your terminated account.

12. 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 (as defined in the Code) may be retained by the CRA until the expiry of 5 years from the date of final settlement of the amount in default.

 

13. 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 CRA, regardless of whether the account repayment data reveals any material default, until the expiry of 5 years from the date of final settlement of the amount in default or the expiry of 5 years from the date of your discharge from bankruptcy as notified to the CRA by you with evidence.

 

14. As stated in this PICS, we may obtain a credit report on you from a CRA in considering any application for credit. In the event you wish to access the credit report, we will advise the contact details of the relevant CRA.

 

15. For the purpose of this section (Access and Correction of Personal Data), account repayment data is the amount last due, amount of payment made during the last reporting period, 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 material default (that is, default in payment for a period in excess of sixty (60) days) (if any)).

 

16. In accordance with the terms of the Ordinance, WeLend 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 for information regarding our policies and practices to:

Data Protection Officer
Welend Limited
Unit 05-12, Level 22, K11 ATELIER King’s Road
728 King’s Road
Quarry Bay, Hong Kong
Email: cs@welend.hk

 

Personal data of another person

18. Where you provide to us data about another person, you should give to that person a copy of this PICS and, in particular, tell him/her how we may use his/her data.

 

Other

19. Nothing in this PICS shall limit the rights of the data subjects under the Ordinance.

 

20. To the extent permitted by law, WeLend and other members of the WeLab Group may record and monitor electronic communications with you to ensure compliance with legal and regulatory obligations and internal policies.

 

21. In case of discrepancies between the English and Chinese versions, the English version shall prevail.

 

Updated as of June 2024

Remark


# The customer must fulfil specific credit requirements to be eligible. Actual time may vary depending on each individual case.

*The loan will be transferred via Faster Payment System (FPS) after the loan is approved and the loan agreement is signed. Actual transfer time is subject to each individual bank's transfer service hours.

^Terms and conditions are applied to cash rebate.

## This suggestion is developed based on information provided by customers. WELEND LIMITED shall not be obliged to any responsibility in case of wrong, incorrect, incomplete or invalid information.

**The financial healthiness score is independently developed by WELEND LIMITED using demographic data collected from customers in accordance with WELEND LIMITED's Privacy Policy and Personal Information Collection Statement.

In the event of any inconsistencies between the English and Chinese version of the Terms and Conditions, the English version shall prevail.
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Remark
1. Loan amount should fall within $5,000 and $1,500,000.
2. Monthly repayment is calculated using an effective rate of 1.88% - 25.00% and is for reference only.
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