This Statement applies to Welend Limited (referred to as “WELEND” or “we”). WELEND is part of a group of companies under Welab Holdings Limited (referred to as “WeLab Group”).

In this Statement, the term “data subjects” or “you” shall include visitors to this website, users of WELEND Chatbot, applicants for loan facilities and customers of loan facilities.

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 WELEND 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

Our Privacy Principles

WELEND values your trust. WELEND is committed to the full implementation and compliance with the six data protection principles and the requirements of the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”). This Statement is intended to assist you in understanding WELEND’s privacy policies and practices in relation to the personal data.

Our Pledge

We pledge to safeguard your personal data by complying with the requirements of the Ordinance as well as the relevant codes of practice and guidance notes issued by the Office of the Privacy Commissioner for Personal Data. We will ensure that all our employees and third parties with permitted access to your personal data uphold these obligations.

Collection of Personal Data

Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. We may collect the following data relating to you, which may be personal data from time to time, including but not limited to:

name;
age;
gender;
phone number;
email address;
HKID number or passport number;
nationality or residency status;
birth date;
personal finance status, intention or goals (including need for loans)
income or assets information;
education level;
employment information;
residential information;
bank account or stored value facility account details;
Facebook ID and first name displayed in Facebook;
LinkedIn ID and related information;
preferences related to any products or services;
communications between you and WELEND;
data regarding your visits to and use of WELEND website and WELEND Chatbot; and
location data.

In addition, when you use WELEND website or services, we may automatically collect certain data which may, when combined with other information about you, be personal data, including but not limited to:

attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
device locations, including specific geographic locations identified through GPS, Bluetooth or WiFi signals or other means;
connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
the website from which you have reached WELEND website;
the WELEND website pages viewed;
details of the products and services on the WELEND website that you look at, information, tools and content available on WELEND website that you use; and
links from WELEND website that you click on.

With your request or authorization, WELEND may additionally receive information about you from our business partners or co-branding partners or from credit reference agencies. WELEND may also obtain information about you from the public domain.

We may use the personal data collected for the purpose set out in the Personal Information Collection Statement (see below). The use and disclosure of personal data and your right to access or correct your personal data held by WELEND are also set out in the Personal Information Collection Statement (see below).

Use of Cookies

Cookies are small data files which are placed on data subject’s device when data subject visits WELEND’s website, interacts with WELEND Chatbot or clicks on WELEND’s online advertisements. Cookies or similar technologies are used for the following purposes:

statistical analysis of your on-site behaviour such as number of visits to our site, page views, length of time spent on each page. These are aggregated and therefore anonymous.
provide enhanced user experience, remember your preference within our website, enable easy navigation between public section and member owner section of our web property.
promote personalized products using your visited pages, and the website links you have followed to:
1. make WELEND’s website more relevant to your interests;
2. provide online advertisements or offers on WELEND’s website or third-party websites which are most likely to interest you;
3. evaluate the effectiveness of WELEND’s online marketing and advertising programs.

The above cookies may be placed on data subject’s device by WELEND or by third parties on WELEND’s behalf (for example, advertising networks and providers of external services like web traffic analysis services). Information recorded through the use of cookies by third parties are aggregated and then shared with WELEND as anonymous aggregated research data. No personal contact information about data subjects is collected or shared by third parties with WELEND as a result of the use of cookies.

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 to ‘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 the WELEND website or WELEND Chatbot properly.

Retention of Personal Data

We will take practical steps to ensure that your personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personal data.

Security Measures

We provide and maintain stringent security measures to protect WELEND’s system and information and personal data retained therein, including:

use of OTP to authenticate users or customers;
use of firewalls and network segregation to protect unauthorized access;
use of encryption to keep data subject’s personal data private at rest and in transit;
regular review of our information collection, use, storage and processing practices;
restriction of access of personal data to relevant employees on a “need-to-know” basis; and
training to employees on the proper handling of personal data.

While internet is not an inherently secure environment for communications, we continuously review and apply industry best practices to protect and secure this channel throughout our systems. Your personal device security and general measure in handling your own personal and transactional digital data are equally important. In most cases, an imprudent transmission and handling of sensitive data such as confidential documents, password, personal identifiers etc. would facilitate unauthorized access resulting in a data breach. Hence, we remind you to be cautious when using WELEND’s website and handling your own sensitive documents and data.

Personal Information Collection Statement

Purpose of Collection

For the purposes of the provision of services by WELEND, it is necessary for data subjects to supply WELEND with personal data for the opening or continuation of accounts and for the purposes of the establishment or continuation of loan facilities and related financial services or the processing of new or renewal applications or other services through WELEND website.
Failure to supply such personal data by data subjects may result in WELEND being unable to open or continue accounts, provide loan facilities and related financial services or process applications or other services.
For the purposes of the provision of services by WELEND, personal data of data subjects may also be obtained from credit reference agency (whose contact details can be provided upon request) or from the public domain through different channels, including public registers, public search engines, public directories or any social media with public view setting authorized by the data subject. In addition, device information may be collected from data subjects’ web browsers.

Use of Personal Data

The personal data of data subjects may be used by WELEND for:
1. considering and processing applications for products and services and the daily operation of products and services (including loan facilities and related financial products and services provided to data subjects);
2. conducting credit checks whenever appropriate (including at the time of application for loan and when we review credit which normally takes place one or more times each year);
3. creating and maintaining WELEND’s credit scoring or risk related models;
4. ensuring ongoing credit worthiness and good standing of data subjects;
5. assisting other financial institutions 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 or developing membership programmes;
8. subject to obtaining the consent of data subjects, direct marketing services, marketing products, services and other subjects as described in paragraphs 6 and 7 below;
9. determining the amounts of indebtedness owed to or by data subjects;
10. exercising WELEND’s rights under contracts with data subjects, including collecting amounts outstanding from data subjects;
11. 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, existing currently or in the future;
  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;
  3. any present or future contractual or other commitment with 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 that is assumed by, imposed on or applicable to WELEND or its affiliates within the WeLab Group; and
  4. any agreement or treaty between the authorities described in (iii) above;
12. complying with any obligations, requirements, policies, procedures, measures or arrangements of WELEND or its affiliates within WeLab Group for the use of data and information for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
13. 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 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;
14. 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;
15. maintaining a credit history of the data subjects (whether or not there exists any relationship between the data subjects and WELEND) for present and future reference;
16. 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
17. any other purposes relating to the purposes listed above.

Disclosure of Personal Data

All personal data held by WELEND will be kept confidential but WELEND may disclose or transfer such information to the following parties for the purposes set out in paragraph 4 above:
1. any agent, contractor, sub-contractor or associates 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. any other person who is under a duty of confidentiality to WELEND and has undertaken to keep such information confidential
4. the drawee bank providing a copy of a paid cheque (which may contain data about the payee) to the drawer;
5. credit reference agencies and, in the event of default, debt collection agencies;
6. any authority, body, association or persons mentioned in paragraph 4(k) above;
7. 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;
8. any persons giving or proposing to give a guarantee or security to guarantee or secure the data subject’s obligations to WELEND;
9. any entities within the WeLab Group;
10. business partners or co-branding partners of WELEND, together with whom WELEND provides products or services to data subjects;
11. subject to obtaining the consent of data subjects in connection with the purpose set out in paragraph 4(h) above:
  1. third party financial institutions, insurers, 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).

Personal data collected in Hong Kong by WELEND may be transferred in and to a place outside Hong Kong.

Direct Marketing

WELEND intends to use a data subject’s data to conduct direct marketing of products or services and requires the data subject’s 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 credit/loan facilities and other financial services and products, membership programmes and related products and services, products and services offered by our co-branding partners;
3. the above services, products and subjects may be provided by WELEND or its affiliates within the WeLab Group, third party financial institutions, insurers, securities and investment services providers, third-party membership programme providers or our co-branding partners;
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.
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 us:

Data Protection Officer
Welend Limited
3rd Floor, OfficePlus @ Sheung Wan
93-103 Wing Lok Street
Sheung Wan, Hong Kong
Email: cs@welend.hk

Access and Correction of Personal Data

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 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
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 credit reference agency to delete from its database any account data relating to your terminated account.
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 credit reference agency until the expiry of 5 years from the date of final settlement of the amount in default.
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 agency, 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 credit reference agency by you with evidence.
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.
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
3rd Floor, OfficePlus @ Sheung Wan
93-103 Wing Lok Street
Sheung Wan, Hong Kong
Email: cs@welend.hk
Nothing in this Notification shall limit the rights of the data subjects under the Ordinance.
In case of discrepancies between the English and Chinese versions, the English version shall prevail.

Updated as of August 2018