LHL ONLINE LENDING, INC whose registered office is Unit D5 Echelon Tower 2100 A Mabini St. Malate Manila
If you do not agree to this Policy or any part thereof, please do not use or access our Platform or any part thereof.
1.COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION
When you use our Platform, whether our Website or our App, we collect and store your information (personal information) which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience and services. This allows us to provide services and features that meets your needs, and to customize our Platform to make your experience safer and easier and to improve the services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.
In general, you can browse the Website or App without telling us who you are or revealing any personal information about yourself. However, to create an account on the Website or App, you must provide us with certain basic information required to provide customized services. The information we collect from you, inter alia, including:
- a. your full name;
c. mailing address;
d. postal code;
e. family details;
f. university/college details;
g. phone number;
h. Permanent Account Number (PAN);
i. Academic records and certificates.
Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the Platform.
We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the Platform) requires registration and for you to provide the above details. The Platform shall clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.
2.COLLECTION OF FINANCIAL SMS INFORMATION
We don’t collect or store your personal SMS from your inbox.
We only collect financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the platform.
While using the app, it periodically sends the financial SMS information to our affiliate server and to us.
3.COLLECTION OF MOBILE NUMBER AND EMAIL ADDRESS
When you sign up with us, we collect your mobile number and email address to uniquely identify you. This helps us ensure that no unauthorised device or person is acting on your behalf.
4.COLLECTION OF LOCATION
We collect location information from your device to reduce the risk associated with your account.
5.COLLECTION OF CONTACT
As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect your contact information to detect close contacts to enable you to autofill the data during the loan application process.
Furthermore, we collect contact information from your device for the purposes of risk analysis by enabling us to detect credible references. The more credible the references are, the lower is the risk associated to a User.
6.COLLECTION OF INSTALLED APPLICATIONS
We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.
We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.
We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.
9.COLLECTION OF OTHER NON-PERSONAL INFORMATION
We automatically track certain information about you based upon your behavior on our Platform. We use this information to do internal research on our users' demographics, interests, and behavior to better understand, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.
If you choose to make a purchase through the Website, we collect information about your buying behavior.
We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.
10.COLLECTION OF DEVICE INFORMATION
The information the App collects, and how that information is used, depends on how you manage your privacy controls on your device.
When you install the App, we store the information we collect with unique identifiers tied to the device you’re using.
We collect information from the device when you download and install the App and explicitly seek permissions from YOU to get the required information from the device.
The information we collect from your device includes the unique ID i.e. IMEI number, information on operating system, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, list of installed apps, wi-fi information.
We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our services and provide an enhanced customized user experience to you.
11.USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We access, store and use the information we collect from you to provide our Services, to research and develop new ones.
We use personal information to provide the services you request, to customize your user experience and to improve our services. To the extent we intent to use your personal information to market any product to you, we will provide you the ability to opt-out of such uses.
We use your personal information to:
- a. resolve disputes;
- b. troubleshoot problems;
- c. help promote a safe service;
- d. analytical analysis;
- e. measure consumer interest and satisfaction in our products and services;
- f. inform you about online and offline offers, products, services, and updates;
- g. customize your experience;
- h. detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
- i. enforce our terms and conditions;
- j. improvement of our services and as otherwise described to you at the time of collection.
In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Website.
12.USE OF YOUR DEVICE INFORMATION
We use the information provided by You in the following ways:
- a. to establish identity and verify the same;
- b. monitor, improve and administer our Website / Platform ;
- c. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
- d. design and offer customized products and services offered by our third-party financial partners;
- e. analyse how the Website is used, diagnose service or technical problems and maintain security;
- f. send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Website;
- g. manage Our relationship with You and inform You about other products or services We think You might find of some use;
- h. conduct data analysis in order to improve the Services / Products provided to the User;
- i. use the User information in order to comply with country laws and regulations;
- j. to conduct KYC for our third-party lending partners based on the information shared by the User;
- k. use the User information in other ways permitted by law to enable You to take financial services from our lending partners.
We will use and retain Your information for such periods as necessary to provide You the Services on our Website, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
14.LINK TO THIRD-PARTY SDK
Our application has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data.
Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.
Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
16.ACCESSING YOUR INFORMATION / CONTACTING US
At any point of time Users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
17.YOUR PRIVACY CONTROLS
You have certain choices regarding the information we collect and how it is used:
- a. Device-level settings:Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.
- b. Delete your entire App account.
- c. You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.
The Website/App intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.
We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.
We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
- a. We use encryption to keep your data private while in transit;
- b. We offer security feature like an OTP verification to help you protect your account;
- c. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
- d. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
- e. Compliance & Cooperation with Regulations and applicable laws;
19.LINKS TO OTHER SITES
Our Website links to other websites that may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mon -Fri (10:00 - 19:00)