Personal Information Collection Statement and Privacy Policy Statement
This Privacy Policy describes how Fundermall Limited. (10/F Tai Sang Bank Building, 130-132 Des Voeux Road C, Central, Hong Kong) (“Fundermall”,“iMort,” “we,” “us,” “our”) collects, uses, and shares information about you when you visit and interact on our website (mobile and desktop) and mobile app (collectively, “Site”) or other means connected to the Sites (such as contacting our customer service team via chat or email). Below is a summary of our privacy practices. Our full Privacy Policy is available below, or you can click the links on any of the points detailed in the summary table for further details.
Introduction
1. Collection
We may collect information about you, such as your name, phone number, email address, date of birth, nationality, residential address, corresponding address, address, and other details of property to be mortgaged, personal income information, personal asset information, personal liabilities information, and personal identification documents, loan request details through your use of the Site.
2. Use
We may use your information to provide the requested services, maintain and improve the Site, and send you marketing communications.
3. Mobile Devices
With your consent, we may send you push notifications with information about your request and iMort & its partnering banks’ offers of your choosing.
4. Sharing
We may share your information with suppliers, service providers, and our affiliates.
5. Cookies
We may use cookies and similar technologies to help provide our Site, understand and customize your preferences, and display relevant advertising.
6. Opting out of Marketing Emails
You may opt-out of iMort’s email marketing communications by using the unsubscribe link in our marketing emails or by changing your account settings.
7. Information from Other Partners
We may collect information from affiliated entities, business partners, or other third party providers and you may opt-out of this collection.
8. Security
We maintain reasonable security measures to protect your information and require our service providers to do the same.
9. Data Subject Rights
You may exercise certain rights of access, correction, deletion, portability, or object to certain processing of your information.
10. Updates to Privacy Policy
We will notify you of any material changes by posting the updated version of this Privacy Policy and taking other steps as needed.
11. Third Party Links
We may provide links to Third Party Websites that are not owned or controlled by us, and are governed by separate user terms and privacy statements.
12. Additional Considerations
Information related to minors, policy language, and Terms of Use.
13. Contacting Us
Please contact us with any questions about this Privacy Policy or our privacy practices as detailed below.
1. Information We Collect
We collect information about you that you provide to us when using the Site, such as your name, phone number, email address, date of birth, nationality, residential address, corresponding address, address and other details of property to be mortgaged, personal income information, personal asset information, personal liabilities information, and personal identification documents, loan request detail and your iMort account password for the application.
By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device’s operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access our mobile app or mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics. We may also collect certain information through cookies, tags, and similar technologies as detailed below.
If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.
Where you are making a loan application with other co-borrowers whose details you provide to us as part of your application, or if you make a loan application on behalf of someone else, it is your responsibility to ensure that the co-borrower (either person or people or company or organization) you have provided information about are aware that you have done so, and have understood and accepted how iMort uses their information (as described in this Privacy Policy). Where required by law, we rely on the following legal bases to process personal information:
1. Necessity to Perform Contract with You - we need to process your information in order to provide our loan application services to you, answer questions and requests from you, and provide customer support;
2. Our Legitimate Interests - we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; to customize and provide our loan application services to you; and to respond to lawful requests, court orders, and legal process;
3. Compliance with Legal Obligations - we need to process your information to comply with relevant laws and regulatory requirements;
4. Consent for Direct Marketing Communications and Non-Essential Cookies - we rely on your consent to send direct marketing and to use/allow non-essential cookies. You can unsubscribe from direct marketing at any time by following the instructions set out in this Privacy Policy; and
5. Protect Vital Interest - we may need to process your information in case of emergency involving an individual's life or health.
2. How We Use the Information We Collect
We may use information collected through the Site to:
1. Provide you with the requested services, such as creating a user account, processing and confirming your loan application, and communicating with you about services requested (e.g., change of application details, cancellation of request, chat support), special request, rewards
2. Send you email marketing communications about products and services that may be relevant to you
3. Conduct surveys or provide you with information about our services on our Site or on other websites you may visit
4. Maintain and improve the Site, tailor the user experience, and for internal training
5. Protect the security of you and the Site
6. Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands
When you make a loan application on one of our business partners’ websites or apps, we may also receive certain information such as your name and loan application information, loan outstanding, loan drawdown status, loan repayment record, in order to process your loan application and identify which channel your loan request has originated from.
During calls with our customer support team, live listening may be done or calls may be recorded for quality and reference purposes which includes the usage of the recordings for the handling of claims, training and fraud detection purposes. If you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up. Call recordings are kept for a limited amount of time and automatically deleted thereafter, unless iMort has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.
If you have not finalized a loan application online, we may send you a reminder to continue with your application. We believe that this additional service is useful to you because it allows you to carry on with an application without having to search for the banks again or fill in all the application details from scratch. You may opt-out of receiving these reminders as detailed below under by selecting Opt-out for marketing during the registration process or send email to our customer service team.
Please note that the confirmation emails and text messages sent after your application, as well as the progress update emails sent after your application, are not marketing messages. These messages are part of your loan application process. Respectively, they contain information for you to review your application submitted. You will continue to receive them, even if you have opted out of our marketing messages.
As mentioned above, if you are completing the application for another person / company / organization who will co-borrower of this loan, you also have the option to insert the his/her email address for the purpose that the co-borrower will receive the application confirmation and loan application progress update.
Communications on the Site
We offer you and Lending Partners various means to communicate about Lending and financing application, directing the communications through the Site. You can contact us with questions about your Finance or Lending application via the Site, and via other channels that we may make available. We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you or, lending or finance partners, us, or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us. Business partners through whose platform you made the application may choose to communicate with you directly via email or other channels that we do not control.
3. Mobile Devices
With your consent, we may send you push notifications with information about your application, potential future use, or as part of any iMort programs that you registered in, including coupons. You may grant us access to your location information or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such information or the receipt of (or opt out of receiving) push notifications. Different device operating systems may have different default settings, so please familiarize yourself with such settings governing push notifications.
4. Sharing Your Information
In connection with your visit to our Site and use of our services, we may share your information as follows:
1. Partnering Banks. These banks may contact you as necessary to obtain additional information about you or your company, facilitate your loan application including communicating with you or your company. Information passed to their company may subject to their own independent privacy policy.
2. Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes including business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
3. Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners. An example of a business partner would be a third-party valuation firm or credit checking organizations, which provide that information required for the loan application assessment.
4. Our Affiliated Group Companies - our affiliated (group) companies’ employees who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
5. Where Required or Permitted by Law - such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of iMort, our users, or others.
6. Business Reorganization - such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.
We provide appropriate protections for such sharing as required by applicable law to prohibit third parties from using your information for their own purposes, and to address the security and confidentiality of your information. Except as disclosed in this Privacy Policy or as required or permitted by applicable law, we will not disclose your information to third parties without your consent.
5. Cookies
Our Site uses and allows third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces (“APIs”), and other technologies (collectively, “Cookies”) on our Site that collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the Site to you, such as to keep you logged in while your visit our Site, while other Cookies are used to provide you with a better user experience, such as
1. To personalize the Site by remembering information about your activities on the Site;
2. Perform website analytics, such as impression reporting, demographic reporting and interest reporting to improve our Site and services; and
3. To provided you advertising tailored to your interest (see below for details)
Interest Based Advertising
We may also allow certain third parties to place Cookies on our Site in order to collect information about your online activities on our Site (e.g., pages visited on the Site and searches you performed) and over time and across different websites you may visit. This information is used to provide advertising tailored to your interests from us (via email, on our Site, and on other websites) and by third parties on other websites you may visit, also known as interest based advertising, and to analyze the effectiveness of such interest based advertising. We may also share one-way hashed information with third party partners (e.g., Facebook) who may combine hashed information with other identifiers in order to serve custom iMort advertisements on other websites or mobile apps based on your prior visits to the Site. iMort neither supports nor endorses the goals, causes, or statements of any websites or mobile apps that display our advertisements.
Cross-Device Tracking
We may also combine information collected through Cookies and certain usage information from a particular browser or mobile device with another computer or device that may be linked to you (cross-device tracking) in order to optimize our services and provide tailored iMort communications and advertisements to you. If you do not want iMort to combine such information for its optimization of communications to you please unsubscribe from the iMort communications i.e. the newsletter.
Your Choices
Please review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details. To learn more about certain Cookies used for interest based advertising (including through cross-device tracking) and to exercise certain opt-out choices you may have regarding Cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or for our mobile app, by updating your device settings or downloading the AppChoices app.
Please also visit the following third parties’ websites to exercise certain opt-out choices over Cookies:
1. Google Analytics - https://tools.google.com/dlpage/gaoptout?hl=en
2. Appsflyer (mobile app analytics) - By emailing appsflyer at: privacy@appsflyer.com
3. Baidu - http://www.baidu.com/duty/safe_control.html
4. Apple - https://support.apple.com/en-us/HT202074
5. Facebook - https://www.facebook.com/ads/settings
6. Google Ads - https://adssettings.google.com/
7. Criteo - https://www.criteo.com/privacy/
By exercising such choice regarding interest based advertising, you may still receive advertisements, but the network from which you opted out will no longer deliver ads tailored to your interests. You should also know that logging out of your user account will not actually mean that you opt out of personalized advertisements. You may need to make such choices on each browser and device you may use to exercise choice regarding certain Cookies. Lastly, at this time the Site is not configured to honor browsers’ “Do Not Track” signals.
6. Opting Out of Marketing Communications from Us
You can opt out of receiving marketing communications from us at any time by using the “Unsubscribe” link in each newsletter or communication, or through your iMort account (if you’ve created one) - the email subscriptions settings is under “Profile”.
7. International Transfers
In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including information transferred to third parties.
8. Information from Other Partners
On occasion, affiliated entities, business partners, or other third party providers may share information with us. One example is if you access or sign in to our Site through social media, we may collect information from you such as your username, and other information made available to us via such services. In general, your ability to provide such information is through the service provider themselves and you can change those settings in your account settings of the relevant service provider. In general, we may work with our partners to improve and personalize your use of our website in accordance with this policy.
9. Protecting Your Information
We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access.
Data Retention
We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy and internal company policies as well as further use for business analysis.
10. How You Can Access or Change Your Information
You can easily correct your account name, the borrower name and contact number at any time by signing in to your account on the website. Alternatively, please contact us via our customer service team.
11. Updates to Privacy Policy
On occasion, iMort may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. iMort will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.
12. Links to Third Party Websites
We may provide links to other websites that are not owned or operated by us (“Third Party Websites”). When you use a link online to visit a Third Party Website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third Party Website before providing any information on that website.
13. Additional Considerations
A Special Note About Minors. Our Site is not directed to minors under the age of 18.
Language
This Privacy Policy has originally been drawn up in the English language. Translations in other languages are available for your convenience. In case of conflict between the English language version and a translated version, the Chinese language version shall prevail.
14. Contacting Us
If you have any questions about this Privacy Policy or our privacy practices, please contact our customer service team atcs@ iMort.com.
Last Updated in February 2021