Effective March 21, 2017
Lenddo Pte. Ltd. and/or its subsidiaries and affiliates are committed to protecting and respecting your privacy.
WHAT INFORMATION IS COLLECTED?
The information that we receive and collect about you is information that is required for the purposes of our Services, this may include any of the following depending on the nature of your use of our Services and the details of the consent that you have provided to us: your name, email address, phone number, any other contact details, government or other identity documents, date of birth, gender, employment, educational background, pictures, location, weblogs, device-specific data (such as your hardware model, operating system version, unique device identifiers, other communication data (which may include information stored on your device, like contact lists, call logs, SMS logs, or other digital content and browser data), details of your use of our Services and a record of your consent to our collection of such information. Your Information that is collected may include information that is considered "sensitive" Personal Information (or any equivalent term for a protected sub-set of Personal Information) under the relevant privacy laws in your jurisdiction.
Your Information may be collected from a number of different sources, which is explained further in the "How Is Information Collected" section below.
HOW IS INFORMATION COLLECTED?
We receive information from various sources, including: (i) through your use of our Services, including any interactions that you have with us related to the Services; (ii) from our Clients; and (iii) from Third Parties with whom we contract to perform business functions and services on our behalf.
We use a wide variety of data sources (either ourselves or through our arrangements with Clients or Third Parties) to perform our Services and depending on the consent that you provide the types of data source may include, but is not limited to information: (i) you give us, such as when you submit an application form or when you complete a psychometric test ii) from credit bureaus, credit reference agencies, credit registers, or other third parties, such as e-commerce companies or utility companies iii) from social networks, such as Linkedin, Twitter or Facebook; (iv) from email, such as Gmail, Yahoo or Outlook; (v) from your device or browser.
For example, if you access our Services from one of our Client’s websites as part of a loan application, you may be prompted to provide us with information as part of the application process and you may be asked to authorize us to access Your Information from Third Parties, such as your credit history from the credit bureaus, employment information from your employer, or your social media account information from the applicable social media platforms. Once you have authorized us to access Your Information, we collect such information about you in accordance with the authorization that you have provided. As part of this authorization process, you have the right to select which Third Parties we can access to obtain Your Information.
We may record conversations between us and you. These recorded conversations can be used by us for internal or otherwise, legitimate purposes related to the interaction. You give full consent for us to make such recordings and will not hold us responsible in any way for any possible infringement of the law relating to the interception of communications.
HOW IS INFORMATION USED?
We use Your Information for a number of purposes, including to:
- develop credit risk models and perform risk assessment;
- detect and prevent fraud;
- verify information that you have provided;
- gain insights on your behavior patterns and interests;
- provide you with information and respond to inquiries or other communications from you;
- provide, administer, improve and develop our Services
- conduct statistical and market analysis; and
- satisfy any other legitimate business purposes, including handling any complaints and retaining information as necessary to meet our obligations under applicable laws and regulations.
We may also use anonymized data for the purposes of improving our Services.
If you would like more information on when we will share Your Information with a Client or Third Party, please read the details in the "What Information is Shared" section below.
WHAT INFORMATION IS SHARED?
We may disclose Your Information to:
- our subsidiaries and affiliates as necessary or appropriate to provide Services you requested, to improve our Services, or for other legitimate business purposes;
- our Clients that have been selected by you and only in those situations where you have agreed that we may share Personal Information with them (for example where you access our Services through a Client’s website in accordance with the example provided in the "How is Information Collected" section above);
- Third Parties as part of providing our Services to you, for example, for the purpose of hosting our web servers, analyzing data, providing legal, accounting, and other support services;
- Government agencies, advisors, and other Third Parties where this is required in order to comply with applicable laws (e.g., in response to subpoenas or government investigations), to assert or defend legal claims, and in order to investigate or respond to actual or suspected illegal activities, fraud, and threats of physical harm, or to protect our rights or property or our Clients; and
- any other party to the extent required or permitted by applicable laws.
We may also share Your Information in connection with a business transfer or sale or reorganization of our business.
While we attempt to partner with only companies that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Parties, including our Clients. We do not have control over the use of your personal information once it is shared by our Clients or Third Party Providers, and we are not responsible for their privacy practices. Your rights with respect to their treatment of Your Information will be governed by their own policies. We encourage you to review the privacy policies of any website, service or application that you access which is operated by our Clients or Third Parties.
HOW IS MY INFORMATION PROTECTED?
We take the security of Your Information very seriously and have implemented policies and procedures that are designed to help safeguard Your Information from unauthorized access, use or modification including:
- submitting information provided by you, our Clients and Third Parties through a secure sockets layer (SSL) transmission;
- restricting access to Your Information only to those employees who are required to know such information in order provide our Services to you; and
- ensuring that all of our employees receive appropriate training on all of our security procedures, and conducting regular audits to verify compliance.
However, we cannot guarantee the security of any of Your Information that you disclose online and you accept the security risks inherent in the transfer of information over the internet.
WHERE IS MY INFORMATION TRANSFERRED TO?
We may store Your Information in countries other than your home country, including transferring data outside the EEA and to the United States, using our third party hosting providers, for example, we may use Amazon Web Services or other external hosting services to store Your Information. Our Clients may also require local storage of Your Information where this is necessary in order for our Clients to comply with relevant privacy laws, in which case we will store Your Information in accordance with our agreement with our Client.
HOW LONG DO YOU KEEP MY INFORMATION?
We will store your Personal Information for the maximum time necessary for the provision of our Services, to enable us to comply with our legal obligations under a contract or applicable laws, regulations and other accounting, contractual, fiscal and tax requirements. We may retain anonymized Information for a longer period as necessary for the purposes of our ongoing improvement of our Services and otherwise required for our legitimate business purposes.
WHAT CHOICES DO I HAVE AND WHAT INFORMATION OF MINE CAN I ACCESS?
You have the right to see any Personal Information of yours that we currently hold about you, except to the extent that this has already been deleted or anonymized in accordance with our records retention policies. If you would like to request a copy of such Personal Information or have any requests regarding the correction or deletion of your Personal Information, please contact us by emailing email@example.com. We will do our best to comply with your request but please note that where you request the deletion of your Personal Information we will not be able to continue to provide the Services to you.
WHAT IF I HAVE QUESTIONS OR CONCERNS?