Nova Credit Limited (“we”, “us” or “our”) respects the privacy of individuals and strictly comply with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong), the Data Protection Principles, relevant codes of practice and other applicable laws. We are committed to ensuring that our employees comply with relevant security and confidentiality standards when collecting, processing, storing, using, disclosing and deleting personal information.
1. How do we collect your personal information?
We may use the following different methods to collect your personal information for actual business needs:
a. Direct Interaction
When you contact us and provide your personal information through our customer service centre, website, mobile apps, or by post, telephone, email or other means in the following situations:
⦁ Applying for, purchasing or using our services;
⦁ Registering or creating accounts;
⦁ Providing feedback or seeking service support;
⦁ Requesting information or subscribing to marketing communications;
⦁ Registering or attending our events;
⦁ Applying for jobs; or
⦁ Providing services to us.
b. Automated Technology or Interaction
c. Third Parties or Public Resources
We may collect personal information about you from various third parties and public sources, including but not limited to the following:
⦁ Your authorised person or organisation who applies for or uses our services (such as banks, financial institutions and other credit providers who provide us with personal information about you directly or through Credit Reference Platform (“CRP”) of Multiple Credit Reference Agencies Model (“MCRA Model”), etc. );
⦁ Our business partners and service providers who support our services;
⦁ Companies that provide information for our services; or
⦁ Public records.
2. What kinds of your personal information do we collect?
We may collect, use, store and transfer the following personal information about you:
⦁ General Personal Particulars: including name, address, contact number, date of birth, email address, etc.;
⦁ Information for Identity Verification: including identification document type, identification number, proof of identity and address, photographs, bank account number, etc.;
⦁ Credit Information: including personal credit information of mortgage and non-mortgage loans, identity of credit provider, date of credit, file activity data of credit provider’s access to personal information, repayment records, credit reports, etc.;
⦁ Public Records and Related Information: including public records related to debt collection/ personal debt judgments and any official bankruptcy or discharge records, etc.;
⦁ Service Information: including records, communication and documents relating to your application for, subscription to or use of our services;
⦁ Transaction Information: including your transaction records, payment card number, expiration date, security code, etc.;
⦁ Account Credential Information: including your account name, password and account usage records, etc.;
⦁ Complaint, Request, Access and Investigation Information: including information provided by data subjects or data users relating to complaints, requests and access, internal investigation records, etc.;
⦁ Personnel Information: including educational background, work experience and salary records of job applicants and employees, employee benefits, vacation and training records, group insurance records, MPF contributions, performance evaluation, disciplinary records, etc.;
⦁ CCTV Monitoring Information: including those captured when you visit or work on our premises or attend our events;
⦁ Pictures and/or Photographs: including those captured when you visit or work on our premises or attend an event sponsored or organised by us; and
We may also collect other personal information in accordance with the Personal Information Collection Statement (“PICS”) provided to you when collecting your information.
3. What is our purpose of collecting personal information?
The personal information we have collected may be used for the following purposes or other purposes directly related to the following:
⦁ Providing services (such as credit reference agency services);
⦁ Follow up and handling of enquiries and complaints;
⦁ Recruitment and human resource management;
⦁ Disclosures based on applicable laws, regulations or regulatory requirements; or
⦁ Specific purposes stated in the PICS.
4. Will your personal information be used for direct marketing activities?
We may provide you with direct marketing communications through various channels such as email, text message, direct mail, telephone, mobile apps or social media. We will never use your personal information for direct marketing purpose unless you have given your explicit consent. You have the right to opt-in targeted direct marketing communications or not to receive any direct marketing communications.
In order to understand your engagement and improve the effectiveness of our communications, we may use email tracking technologies such as dynamic links and image files in our direct marketing emails to you.
If you want to opt out of receiving or unsubscribe from our direct marketing communications, you may raise a request to us via our website, mobile apps, direct marketing channels, or by visiting our Customer Service Centre. Notwithstanding your opt-out from direct marketing communications, we may still send you information related to your service, your user accounts and your major transaction for providing customer service and protecting your rights.
5. Under what circumstances will we disclose your personal information to others?
We are committed to protecting the security of personal information and will not allow any access, deletion, disclosure or other unauthorised use without your explicit and voluntary consent (including through your information provider (data source provider) or authorised third party). We will never disclose your personal information to any third party for direct marketing purposes without your consent.
We may disclose necessary personal information to advisers, agents and consultants, such as lawyers and accountants, for the provision of professional duties which will be abided by our confidentiality policy. Any person, including our employees, will only be granted access to personal information on a “need-to-know” basis. Your personal information will not be transferred out of Hong Kong unless with your consent. If it is necessary to appoint a third party (including a third party outside Hong Kong) to process your personal information, we will first obtain your consent and ensure that such third party is properly bound by adequate terms to protect your personal information.
6. How do we protect your personal information?
We put in place appropriate security measures (such as data encryption) to protect the confidentiality, integrity and availability of personal information in the process of collection, storage, disclosure and deletion against unlawful or unauthorised access, process, edit, accidental loss or damage from collection to destruction of personal information. We also provide regular training on proper handling of personal information for all our employees and related personnel.
7. How long do we keep your personal information?
We will delete your relevant personal information after the purpose of collection has been fulfilled, and take all practicable steps to ensure the retention period of personal information is not longer than necessary and comply with applicable laws. For your Hong Kong personal credit information, we will retain and delete the relevant information pursuant to the requirements of the Code of Practice on Consumer Credit Data issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong.
8. Can you request to review, modify, delete and/or stop using your personal information?
You have the right to request access to your personal information held by us and request for correction of any incomplete or inaccurate information. Depending on the source of such information, we and/or the information provider (data source provider) will verify the data and make relevant amendments where appropriate. We reserve the right to charge a reasonable fee for data access requests.
We shall retain or process personal information for legitimate reasons, such as complying with legal procedures. Without prejudice to any of your rights under the law, you may request us not to store or process your personal information. Where reasonably practicable, we will stop processing your personal information or delete it from our database.
9. How can you contact us?
If you want to request for access to or correction of your personal information, or have any questions about our information protection policy and your rights, please contact our customer service centre through the following channels:
Customer Service Centre of Nova Credit Limited
By Phone: +852 3854 0188
By Email: [email protected]
By Post: Unit A6, 20/F, NCB Innovation Centre, 888 Lai Chi Kok Road, Kowloon, HK