Privacy Policy

1. From time to time, eLoan may collect from the following information and data:

• Personal data about a Borrower’s or Lender’s , partners, directors, officers or authorised signatories, employees, borrowers, payors, payees, guarantors, other security providers, and other natural persons related to a Borrower or Lender (collectively all of the foregoing who are natural persons, “Relevant Individuals”). Such personal data may include names, identification particulars, date of birth, contact details and other relevant personal information; and

• Information and data generated in the ordinary course of the relationship with eLoan. Such personal data may include signatures, answers to questions intended for security verification, emergency contact numbers or call back contact details.

• We collect information from or about the computers, phones, or other devices where you install or access our Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. This includes, but are not limited to: 1.) Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; 2.) Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals., 3.) Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

• We collect information about the people you are connected to and how you interact with them, such as the people you communicate with the most. We also collect contact information you provide if you upload, sync or import this information (such as an address book) from a device.

Deemed Consent

2. A Borrower will be deemed to have consented (or obtained the consent of the Relevant Individuals) to the collection, use and disclosure of the above mentioned personal data of Relevant Individuals by the Borrower’s continued dealing, use of eLoan’ services, and/or acceptance of the terms and conditions contained herein. A Lender will be deemed to have consented to the collection of the above mentioned personal data of Relevant Individuals and the use of it (for Permitted Purposes only) by eLoan, by the Lender’s continued dealing, use of eLoan’ services, and/or acceptance of the terms and conditions contained herein.

3. All other parties, including any guarantor or any institution providing escrow services to eLoan, agree to the collection, use and disclosure of the personal data by such persons continued dealing, use of eLoan’ services, and/or acceptance of the terms and conditions contained herein.

Purposes for which Information is Used and Disclosed

4. Information and data of or relating to the Borrower or Lender may be used and disclosed, including to places in or outside Vietnam for the following purposes (collectively, “Permitted Purposes”):

To make decisions relating to the arrangement of the Loan and maintaining accurate “know your client” information;

• To verify the identity or authority of representatives who contact eLoan, or may be contacted by eLoan, and to carry out or respond to requests, questions or instructions from verified representatives or other individuals pursuant to the current security procedures; and

• To conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits, reviews and troubleshooting activities.

Parties to whom Personal Data may be Disclosed for the Permitted Purposes

5. Personal data of the Borrower or Lender may be disclosed, where permitted by applicable law, to the following entities (without limitation) (whether inside or outside Vietnam) below for the Permitted Purposes or for processing in accordance with any Permitted Purposes on a need to know basis:

Any agent, contractor, or third party services provider which provides banking, remittance, administrative, mailing, telecommunications, call centres, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment, debt collection, credit reference checks or securities clearing or other services to eLoan in connection with the operation of business of eLoan;

• Any person or entity which is part of eLoan and is under a duty of confidentiality to the disclosing eLoan entity although only to the extent necessary to fulfil the relevant Permitted Purposes;

• Any person or entity to whom eLoan is under an obligation or otherwise required to make disclosure pursuant to legal process, or any other foreign or domestic legal and/or regulatory obligation, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities; and

• any actual or proposed assignee of eLoan or transferee of eLoan’ rights in respect of any Borrower or Lender, or all or any part of the assets or business of eLoan, or any party giving or proposing to give a guarantee or third party security to guarantee or secure the obligations of the Borrower.