PRIVACY POLICY

1. General Principles

   • This Privacy Policy describes how the Company collects, uses, and discloses the data that the Company has collected and received during the course of providing the Service under the OneManage Platform. The Company only collects, uses, and discloses any data of the Customer in accordance with this Privacy Policy.

   • The Customer hereby acknowledge that he or she is aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, the Company strives to protect the security of the data and are constantly reviewing and enhancing the Company’s information security measures. By accessing and using the OneManage Platform, the Customer is accepting the practices as described in this Privacy Policy.

   • We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be posted on this OneManage Platform and, where appropriate, notified to the Customer by notification in the User Account, or email or text message (SMS) to the Customer's mobile phone. The Customer, who continues using the OneManage Platform, shall constitute the Customer's acknowledgement and acceptance of any changes that the Company makes to this Privacy Policy.

2. Collection of Data

   • The Company may collect the following information, data and document from the Customer:

     • identity, such as name, gender, date of birth, a copy of identity card and/or passport a photo or a selfie photo of the Customer, the Customer’s electronic thumbprint and/or the Customer’s facial or eyes recognition;

     • occupation, such as workplace, business, salary and income with supporting documents,

     • contact, such as billing address, delivery address, email address, phone number and emergency contact;

     • account, such as bank account, payment details and payment card;

     • transaction, such as details about payments to and from the Customer, and other details of goods that the Customer purchases from the Merchant;

     • link to any social networking site or e-mail or telephone number or chat program of and used by the Customer;

     • credit history with any financial institution and other person;

     • any use of other platform similar to OneManage Platform and the knowledge about the OneManage Platform;

     • any use of the E-Commerce Platform and other digital platform similar to the E-Commerce Platform; and

     • other information that the Company may require from time to time for providing Service to the Customer in the OneManage Platform.

   • (All of the above information, data and document shall be hereinafter referred to as the "Data")

   • The Company may collect the Data at the stage of registration for the User Account and later on through providing notification to the Customer via the OneManage Platform and the provided contact information of the Customer.

   • The required Data may be marked as mandatory and optional for the Customer to provide. If the Customer cannot provide any mandatory Data, either collected during the registrational stage or at the later stage, the Company has full discretion not to permit the Customer to open a User Account or to terminate the Customer’s existing User Account.

3. Use and Disclosure of Data

   • The Data that the Company collects may be used by the Company and/or shared with or transferred to third parties (including employees of the Company, consultant or advisor of the Company, auditor of the Company, partnering financial institutions of the Company, the service providers to the Company, the Merchants and other related person), for some or all of the following purposes:

     • to facilitate the Customer to use the OneManage Platform, including to respond to any queries, feedback, claims, or disputes of the Customer through our Customer Service Team;

     • to process any request for Service in the OneManage Platform or any purchase from the E-Commerce Platform or in Physical Store;

     • to process any payments that the Customer makes through the OneManage Platform either in accordance with the Transactional Agreement or any agreement with the Merchants;

     • to verify and validate the provided information with third parties in order to ensure that the information is accurate, true and complete;

     • to administer the User Account (if any) with the Company, the E-Commerce Platform and the Merchant;

     • to verify and carry out financial transactions in relation to payments that the Customer make online;

     • to perform customer due diligence in accordance with applicable laws and regulations;

     • to autofill the Data as required in the Transactional Agreement;

     • to conduct assessment over the Customer’s repayment capacity, behavior and creditability for determining the purchase limit and the amount of financing to provide to the Customer as may be stated in the Transactional Agreement;

     • to study about the market and the Service for developing and providing better Service or other services to the Customers or the market; and

     • to provide Service to the Customer either through the OneManage Platform or other services of the Company.

   • The Company may use the Customer’s contact information to send any newsletters from the Company and from our related companies. The Customer may unsubscribe the recipient of such information through communicating to the Customer Service Team or responding to the delivery of such information.

   • The Company or the Company’s authorized service providers may use cookies, web beacons, and other similar technologies for storing data to help provide the Customer with a better, faster, safer, and personalized experience when the User uses the OneManage Platform.

   • In exceptional circumstances, the Company may be required to disclose information when:

     • there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for the fulfilment of legal and regulatory requirements and requests, or for the fulfilment of the request from the competent authority; and/or

     • there is any legal or commercial requirement for the Company to go through any due diligence requirement.

4. Updating Data

   • It is important that the Data provided by the Customer is accurate and up-to-date. The Customer is responsible for informing the Company or updating the Data in the OneManage Platform if there are any changes to the Customer’s Data, or in the event that the Customer believes that the provided Data is inaccurate, incomplete, misleading, or out-of-date.

   • The Customer can update the Data at any time by accessing to the User Account in the OneManage Platform. If the Customer is unable to update the Customer’s data through the User Account in the OneManage Platform, the Customer shall contact the Customer Service Team of the Company.

   • The Company may share the updates to the Customer’s Data with whom the Company has shared the Customer’s data if the Customer’s data is still necessary for the above-stated purposes.

5. Archiving of Data and Access

   • Any communication or activity of the Customer in the OneManage Platform shall be archived and kept as trial record. This trial record information is the property of the Company. The Customer hereby approves the Company to use the record as the element of proof in any dispute or controversy with the Customer or with the Merchant.

   • The Customer may request through the OneManage Platform or through the Customer Service Team to access to:

     • the trial record as kept by the Company in accordance with Clause V(4)(a) above;

     • the statement of the Customer’s transaction in the OneManage Platform; and

     • the historical performance of the Customer in the OneManage Platform.