2. Personal Information which we collect
3. The use of Personal Information which we collect
4. Sharing of Personal Information which we collect
5. Cross-border transfers of Personal Information
6. Retention of Personal Information
7. Access and correction of Personal Information
8. Where we store your Personal Information
9. Security of your Personal Information
12. Acknowledgement and consent
13. Marketing and promotional material
14. Third party websites
15. How to contact us
2. PERSONAL INFORMATION WHICH WE COLLECT
We collect certain Personal Information about you. The Personal Information which we collect may be provided by you directly (for example, when you opening an Account to use the Service via App, or you otherwise provide Personal Information to us) or by third parties, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).
Information obtained from you or from your Mobile Device directly:
● When you register and create an Account with us using the App, you have to provide to us certain Personal Information, including your name, national ID, date of birth, gender, education background, religion, photo, physical address, e-mail address, working information, marital status, emergence contact, your phone number, SIM card details, financial and credit information (including your Mobile Money Account details, bank account details, and bank verification number, where applicable) and an Account ID and/or password that you will use to access the App after registration.
● When you use the App, you have to provide to us such relevant information as may reasonably be required by us in order for the App to work. For example, when a payment is made through the electronic money facility within the App, you will provide to us information relating to the payment, such as the type of payment card or mobile wallet account used, the name of the issuer of that payment card or mobile wallet account, the name of the account holder for that payment card or mobile wallet account, the number of that payment card or mobile wallet account, and the amount of money paid.
Information collected whenever you use the App or visit our Website:
● Whenever you use the App or visit our Website, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as webpages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, and also information regarding the manufacturer, model and operating system of the device that you use to access the App or our Website.
● Whenever you use the App through your Mobile Device, we will track and collect your geo-location information in real-time. In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your Mobile Device to enable us to give you a better experience in using the App.
● Meanwhile, your will be required to provide technical information to us while using the App, including the type of Mobile Device you use, a unique device identifier (for example, your mobile device's IMEI number, the MAC address of your Mobile Device's wireless network interface, or the mobile phone number used by your Mobile Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting. We will also collect information stored on your Mobile Device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content.
● We collect your geo-location information when the App is running in the foreground. We endeavour to cease collection of your geo-location information when the App is in the background, but such information may still be collected unintentionally. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this may affect the functionalities available on the App.
Information collected from third parties:
Information about third parties you provide to us:
● You may provide us with Personal Information relating to other third party individuals (such as Personal Information relating to your spouse, family members, friends and emergency contact). You will of course need their consent to do so–see Section 12“Acknowledgement and Consent”, below, for further information.
3. THE USE OF PERSONAL INFORMATION WHICH WE HAVE COLLECTED
We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by Applicable Law:
a. We may use your Personal Information:
● to identify you and to register you as a user and to administer, manage or verify your Account as such;
● to facilitate or enable any checks as we may in our discretion consider necessary before we register you as a user;
● to disburse Loan and collect payments for your use of the Service;
● to build credit models and perform credit scoring;
● to comply with Applicable Law, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;
● to communicate with you and to send you information in connection with the use of the App;
● to notify you of any updates to the App or changes to the Service (including interest rate, Transaction Fees, etc.) available;
● to process and respond to enquiries and feedback received from you;
● to maintain, develop, test, enhance and personalise the App to meet your needs and preferences as a user;
● to monitor and analyse user activities and demographic data including trends and usage of the Service available on the App; and
● to send you direct marketing communications and information on special offers or promotions.
b. We may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose):
● to undertake associated business processes and functions;
● to monitor usage of the App and administer, support and improve the performance efficiency, user experience and the functions of the App;
● to provide assistance in relation to and to resolve any technical difficulties or operational problems with the App;
● to generate statistical information and anonymous analytics data for the purpose of testing, research, analysis and product development;
● to prevent, detect and investigate any prohibited, illegal, unauthorised or fraudulent activities;
● to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us and/or any of our Affiliates; and
● to enable us to comply with our obligations under any Applicable Law (including but not limited to responding to regulatory enquiries, investigations or directives) and conducting audit checks, due diligence and investigations.
4. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT
a. We may disclose to or share with Affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by Applicable Law (although we will in each such case always act reasonably and disclose or share no more Personal Information than what is required for the particular purpose):
● where required or authorised by Applicable Law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing and reporting requirements), for the purpose so specified in that Applicable Law;
● where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the Service, for the purposes of that legal proceeding;
● in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
● where we share your Personal Information with third parties (including Credit Reference Bureaus, Mobile Network Providers, collection agencies，our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with), for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, or other conducting activities including marketing, research, analysis and product development;
● where we publish statistics relating to the use of the App and the Service, in which case all information will be aggregated and made anonymous; and
b. Where it is not necessary for the Personal Information disclosed or shared with other parties to be associated with you, we will use reasonable endeavours to remove the means by which the Personal Information can be associated with you as an individual before disclosing or sharing such information.
c. We will not sell or lease your Personal Information to any third parties.
5. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
Your Personal Information may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any Service provided by us (“Alternate Country”), to companies under XGO group which are located outside of your home nation or Alternate Country and/or where XGO group’s servers and/or service providers and partners are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Information out of your home nation or Alternate Country as described herein.
6. RETENTION OF PERSONAL INFORMATION
Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or authorised by Applicable Law. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.
7. ACCESS AND CORRECTION OF PERSONAL INFORMATION
a. You may request us for access to and/or the correction of your Personal Information in our possession and control, by contacting us at the details provided below. Subject to Applicable Law, we reserve the right to charge an administrative fee for such requests.
b. We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal Information in our possession or control, if permitted or required under any Applicable Law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.
8. WHERE WE STORE YOUR PERSONAL INFORMATION
9. SECURITY OF YOUR PERSONAL INFORMATION
Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control. You are responsible for keeping your Account details confidential and you must not share your password with anyone and you must always maintain the security of the Mobile Device that you use.
12. ACKNOWLEDGEMENT AND CONSENT
b. In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends or emergency contact), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us.
c. You also consent and expressly authorise use to contact you and your emergency contact who has expressly agreed upon it, to verify your information or when we are unable to contact you via other methods or when we have not received your payment in connection with Loan.
d. You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information via any “opt-out” or “unsubscribe” facility contained in our messages to you. Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the App or certain of the Service. A withdrawal of consent by you may result in the termination of your Account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.
13. MARKETING AND PROMOTIONAL MATERIAL
a. We may send you marketing and promotional communications via post, telephone call, short message service (SMS), e-mail, online messaging, or push notifications via the App to notify you about special privileges, promotions, or events offered or organised by us, our partners, sponsors, or advertisers, or to provide updates on our App and/or the products and services offered therein.
b. You may opt out from receiving such marketing communications at any time by clicking on any “unsubscribe” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you opt out, we may still send you non-promotional messages, such as Loan disbursement or repayment receipts, or information about your Account or the App.
14. THIRD PARTY WEBSITES
a. The App and Website may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third party websites to find out how they collect and use your Personal Information.
15. LIMITATION OF LIABILITY
We shall not be liable for any indirect, incidental, consequential, special, exemplary or punitive damages arising out of:
a. Your use of or reliance on the App or your inability to access or use the App; or
b. Any transaction or relationship between you and any other third party, even if we have been advised of the possibility of such damages.
We shall not be liable for delay or failure in performance resulting from causes beyond our reasonable control.
16. HOW TO CONTACT US