Tiptop Credit Limited ("the Company")
Notice to Customers Regarding Personal Data (Privacy) Ordinance Policy Guidelines

(a) When opening or maintaining an account, using the Company's website and/or mobile application, applying for or renewing credit or installment loans, or requesting services from the Company (including but not limited to personal loans, revolving loans, mortgage, unsecured home loans, etc.), customers are required to provide relevant information to the Company for processing and approval of the application.

(b) Failure to provide such information to the Company may result in the Company being unable to provide website and/or mobile application services, open or maintain an account, or establish or renew credit or installment loans with the customer, or fulfill customer service requests.

(c) In the course of normal business operations, the Company also collects customer information when customers apply for loans or renew installment loan accounts in person, by phone, or online.

(d) Customer information will only be used for the following purposes:

i. Providing services and facilitating daily operations related to customer loans; 
ii. Conducting credit assessments when customers apply for loans and conducting regular or special account reviews, at least once a year. These reviews assist the Company in determining whether to increase, decrease, or maintain the customer's credit limit;
iii. Developing and maintaining the Company's credit scoring model;
iv. Assisting authorized credit management agencies for credit checks and debt collection purposes;
v. Ensuring customers maintain a reliable credit history; 
vi. Designing financial services or related products for customer use; 
vii. Conducting product development, research, design, implementation, promotion, and marketing for the Company's financial products and services, as well as designated individuals or business partners, for operational and management purposes; 
viii. Calculating debts between the Company and customers; 
ix. Pursuing debt recovery against customers and mortgagors responsible for the customer's obligations;x. Making disclosures required by applicable laws and regulations by the Company, its affiliates, or any branch; 
xi. Comparing customer or other persons' information for the purpose of credit assessment, data verification, or generating/verifying data by any means, whether or not such comparison is unfavorable to the customer in debt recovery actions;
xii. Assessing intentions for the transfer, participation, or involvement of the Company's real or proposed assignees, or any participants or affiliated participants in the customer's rights; and
xiii. Any other purposes related to the above.

(e) The Company maintains confidentiality of customer information it holds, but may disclose such information to the following parties for the purposes listed in paragraph (d):

i. Any agents, contractors, or third-party service providers that provide administrative, telecommunication, computer, payment, securities settlement, or other services related to the Company's business operations;
ii. Any individuals or institutional entities with confidentiality obligations towards the Company, including those within the Company's group who have committed to maintaining the confidentiality of such information;
iii. Copies of paid checks (which may contain information about the payee) provided to the issuer by the Company;
iv. Credit Reference Agency (CRA); in the event of customer default, such information may be provided to authorized credit management agencies;
v. Any person to whom the Company has a legal obligation to make disclosures, whether in relation to the Company or any of its branches; and

(f) Any customer has the right, in accordance with the provisions of the regulations and the Code of Practice on Consumer Credit Data approved and issued under the regulations, in relation to the personal credit data held by the Company's actual or proposed assignees, participants or affiliated participants, or transferees: 

i. To ascertain whether the Company holds his/her data and to have access to such data;
ii. To request the Company to correct any inaccurate data about him/her;
iii. To be informed of the Company's policies and practices regarding data and the types of personal data held by the Company;
iv. To ascertain and be informed by the Company of the types of personal data routinely disclosed to credit reference agencies or debt collection agencies and to be provided with further information to enable him/her to make a request to the relevant credit reference agencies or debt collection agencies for access and correction of data; and
v. When fully settling the outstanding debts and closing the account, customers may instruct the Company to request the credit reference agency to delete the account data previously provided by the Company from their database. However, such instruction must be given within 5 years from the date of account closure, and during the 5 years preceding the account closure, there should be no record of overdue payments exceeding 60 days. If there are records of overdue payments exceeding 60 days, the credit reference agency may retain such records until 5 years have elapsed from the date of full debt settlement or from the effective date of the bankruptcy discharge order received by the Company, whichever occurs earlier.

(g) In accordance with the provisions of the regulations, the Company reserves the right to charge a reasonable fee for processing any requests for access to data. 

(h) Any requests regarding access to or correction of data, or inquiries about data policies, practices, and types of data held, should be addressed to the following individual: 

Data Protection Officer
Tiptop Credit Limited
2/F, Hua Chiao Commercial Centre, 678 Nathan Rd, Mongkok, Kowloon
Telephone: (852) 2912 7929 Fax: (852) 2912 7980

(i) When approving credit applications or reviewing loan accounts in the future, the Company may refer to credit reports about customers provided by credit reference agencies. If customers wish to obtain such reports, they may contact the relevant credit reference agency at the following address: 

TransUnion Limited
Consumer Relations Department
Suite 811, 8th Floor, Tower 5, The Gateway, 15 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong 

Telephone: 2577 1816 Fax: 2578 4425

(j) This notice does not limit the rights enjoyed by customers under the Personal Data (Privacy) Ordinance.

(k) This notice constitutes part of the terms and conditions of the loan account or any related agreements or arrangements that customers currently hold or may hold with the Company in the future. In case of any discrepancies, this notice shall prevail.