Data Privacy Notice

What personal information is collected?

We only collect personal information that is reasonably necessary for us to perform our functions. This may include:

• information you give us when you request a product or service from us.
• financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
• communications between us and other professionals that you have authorised, such as your financial adviser or mortgage broker;
• transactional information about the use of a product if you have or had a product with us.

How personal information is collected?

We collect your personal information in a number of ways including:

• directly from you, such as when you provide the information by phone, email or in an application; and
• from third parties such as credit reporting agencies or other credit providers if you authorise us to do so.

Use of your personal information

Your personal information may be used by in a number of ways including but not limited to:

• to verify your identity or transactions which you may enter into with us;
• to provide the product and services that you request;
• to administer and manage the provision of our products and services;
• to respond to queries or complaints;
• to collect payment from you;
• to comply with laws and regulatory requirements including complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
• to comply with Aerapay’s risk management policies and procedures; or
• to train our staff.

We may use your personal information for additional purposes related to the purposes listed above. We will not use your personal information other than for:

• a purpose made known to you;
• a purpose you would reasonably expect;
• a purpose required or permitted by law; or
• a purpose otherwise authorised by you.

Third party access to personal information

We may contract out some of our functions such as mailing, settlement services or identification verification to external service providers from time to time.

Only in those instances will we disclose relevant personal information to those providers.

We may also disclose your information to companies within the group so that products and services may be offered. Where we have obtained your approval to conduct credit checks, we may obtain personal information from or disclose personal information to credit reporting agencies.

Access to your personal information

You may request access to the personal information that we hold about you or request correction to personal information that we hold. Subject to the limited circumstances set out below, we will endeavor to process your request in a reasonable time. In order for us to process your request we will need to verify your identity and, in some circumstances, we may need to charge an administrative fee, of which we will inform you in advance.

In the event that we refuse you access to your personal information, we will provide you with an explanation for that refusal. These reasons may include:

• an unreasonable impact on the privacy of other individuals;
• the information relates to legal proceedings between Aerapay and you;
• the information would reveal sensitive corporate decision-making process; or
• we are prevented by law from disclosing the information or providing access.

Storage and security of information

Aerapay stores personal information in an encrypted database on our servers. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modification or disclosure.

Use of our web site

We will collect some information from you when you visit the Aerapay website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. We will record your email address if you send us an email.

Cookies

When you visit the website, our server places small pieces of data known as ‘cookies’ on your hard drive. Cookies are pieces of information that are transferred to your computer when you visit a website for record-keeping purposes. Most Web browsers are set to accept cookies. However, if you do not wish to receive any ‘cookies’ you may set your Web browser to refuse cookies. We may use cookies to provide us with aggregate (anonymous) information on how people use our website and to help us know what our customers find interesting and useful in our website. We do not link this information back to other information that you have provided to us.

Changes to our Privacy Policy

Aerapay may make changes to this Privacy Statement from time to time for any reason and will make concerted efforts to update the website in a timely manner.

If you would like more information about how we manage your personal information, please contact us on +852 8191 4085, or write to us at the following address:

30C Morrison Plaza
5-9 A Morisson Hill Road
Wan Chai, Hong Kong