CreditGo: Instant Loan App

Privacy Policy

This Privacy Policy was prepared to protect and maintain the privacy of Product Users. The Product was created, owned and operated by MANO CREDIT LIMITED ("CreditGo", "we", "us", or "our"). This Privacy Policy does not apply to any websites or mobile applications that are not operated by us that you may access via the Product. Users are requested to read and understand this Privacy Policy carefully before using the Service. By i) clicking or checking or otherwise indicating the User's intent to accept or agree to this Privacy Policy, and/or ii) accessing and using the Services on the Product, the User acknowledges that he has read, understood and agreed to every provision written in this Privacy Policy and the terms of use of the Product. The Privacy Policy also stipulates the actions in which CreditGo obtains, collects, processes, analyses, stores, rectifies, updates, displays, announces, transfers, disseminates, discloses, deletes, destroys personal information. By visiting or using the Services on the Product, the User is deemed to have read, and agrees to the acquisition, processing, analysis, storage, rectification, updates, display, announcement, transfer, dissemination, disclosure, deletion, and destruction of the User's Information in accordance with the Privacy Policy.

1. General Provisions

CreditGo shall collect from any user and to what degree, extent we may use, process and transfer the information when you register, access or use our Mobile App (CreditGo), Website (https://www.manocreditgo.com), products, and services (collectively, the "Services"). The Service provides users with the opportunity to apply for and be granted credit loans subject to the terms and conditions agreed upon by both parties. By visiting and/or using our Service, you are accepting and consenting to the practices described in this Privacy Policy.

2. Definitions

In addition to those specified elsewhere in this Privacy Policy, the following terms will have the definitions, meanings and interpretations specified below:

2.1 "Personal Information/Data" means shall include all data, information and documents, whether electronic or non-electronic, of or concerning the User and/or related parties of the User (including but not limited to the User's family, associates, employees, companies or service providers, if required for emergency contact or for other legitimate reasons) that CreditGo receives or accesses from the User or third parties, submitted, provided or disclosed by the User to CreditGo, according to the consent of the User concerned and stored and managed in connection with the provision of Services on the Product and in the context of the utilization of Services on the Product by the User.

2.2 "User" means any person registering CreditGo's Application and/or using services provided by us.

2.3 "Terms and Conditions" are the terms and conditions for using the Product set by the Provider, as accessible and have been understood and approved by Users when registering through the Product.

2.4 User's Information means includes

i) User's Personal Information/Data" and

ii) other information/data mentioned in this Privacy Policy.

2.5 "Cookies" means a type of file containing information sent by a website/application to the computer hard disk of every visitor who visits the website/application for the purpose of recording certain information by the computer, such as internet protocol (IP) addresses, browser type and operating system (OS), day, date and time when visitors access the website and data from small-click server streams to monitor website/application access activities and website/application addresses accessed by Users. Cookies function to remember important information that will help in using the website/application, if the User decides to visit the website/application again in the future.

2.6 "You", with grammatical variations and cognate expressions, refers to any other person using the Product and/or the Services whether or not registered on the Product.

2.7 "Process/Processing" means the actions includes:

a. acquisition and collection;

b. processing and analysis;

c. storage; rectification and updates;

d. appearance, announcement, transfer, distribution or disclosure; and/or

e. deletion or destruction.

3. Applicability and Consent

3.1 This Privacy Agreement is compiled and shall become an integral part of the terms and conditions for using Product ("Terms and Conditions"). Words or terms that use capital letters used in this Privacy Policy, unless otherwise specified in this Privacy Policy or if the context otherwise requires, will have the meaning as specified in the Terms and Conditions. Words in the singular are also in the plural and vice versa. By accessing the Product and/or providing Personal Information to Us, You have read and understood Our Privacy Policy and consent to the Processing of Your Personal Information in accordance with this Privacy Policy.

3.2 This Privacy Policy shall legally bind Users from the date:

a. The User clicks or checks or otherwise indicates the User's intent to accept or agree to this Privacy Policy; and/or

b. Users access and use the Service and/or Product.

c. For avoidance of doubts, if this Privacy Policy is amended during Users' accessing and using of the Service and/or Product, by continuing to access and use the Service and/or Product, Users agree to the amended Privacy Policy, and the amended Privacy Policy shall legally bind Users from Users' first access and use of the Service and/or Product after the amendment.

3.3 This Privacy Policy continues to apply as long as:

a. The registered Users are registered as Users on the Product;

b. The registered Users still has obligations, financial responsibilities, debts or similar matters to the the Loan Agreement; and/or

c. The registered Users is still in the process of submitting an application for obtaining a loan along with an assessment of it by CreditGo or any third party cooperated by CreditGo.

d. The registered Users understand that we may share your Personal Information with the authorized government agencies and/or other institutions that may be appointed by government authorities. You agree and acknowledge that the retention of your Personal Information by the relevant government agencies and/or other institutions will follow the respective parties' policies regarding data retention.

e. The registered Users understand that this Privacy Policy is still valid and binding to Users as long as is necessary for the purposes set out herein.

4. Legal Basis for Data Processing

Pursuant to the applicable laws and regulations, We process your Personal Data based on one or more of the following legal grounds:

4.1 Consent: processing based on your explicit consent for specific purposes.

4.2 Performance of a Contract: processing necessary to fulfil Users' and our obligations under the agreement and other relevant documents.

4.3 CreditGo's Legal Obligation: processing necessary to comply with our legal obligations.

4.4 Legitimate Interests: processing necessary for our legitimate interests or those of third parties, provided your fundamental rights are not overridden.

4.5 Interest protection: processing based on the vital interest of personal data subject.

5. Information We Collect

5.1 Collection of Personal Data as data controller shall be conducted by CreditGo or CreditGo's cooperative third parties from data subjects directly or indirectly after CreditGo owns the legal basis mentioned in Article 4 regarding Legal Basis for Data Processing and CreditGo shall collect in compliance to the applicable laws and regulations.

5.2 Collection of information of data subject (including but not limited to User) shall be conducted by CreditGo or CreditGo's cooperative third parties from data subjects directly or indirectly after CreditGo obtains prior consent unless otherwise required or exempted by applicable laws and regulations and CreditGo shall collect in compliance to the applicable laws and regulations.

5.3 The Personal Data collected and submitted, such as:

i. name; ii. place and date of birth; iii. gender; iv. marital status; v. contact number; vi. emergency contacts' relationship with Users, name and phone number; vii. e-mail; viii. company name; ix. company address; x. monthly income.

5.4 The collected device information includes:

a. Ads Tracking Information. With your permission, we collect the Identifier for Advertisers (IDFA) on your device to understand overall usage trends and improve service quality. IDFA is also used to evaluate the effectiveness of advertising campaigns and to assess user quality and conversion performance across different marketing channels. You may revoke access at any time in your device settings.

b. Location Information. With your permission, we collect approximate location information from your device. The purpose of collection is to help prevent fraud and ensure the security of your account by obtaining approximate geographic location information. You may revoke access at any time in your device settings.

c. Calendar Information. With your permission, we request access to your calendar, including details such as the event title, event description, and start/end date. This ensures that support fraud prevention and assists in assessing repayment ability, in order to provide you with secure and reliable services. You may revoke calendar access at any time in your device settings.

d. Application Interaction. We collect data on how you interact with our App to understand usage patterns, detect unusual activity, and support fraud risk assessment. This information helps us improve features and the overall experience.

5.5 All personal data will be securely transmitted via HTTPS and uploaded to our server at https://gh-serv.manocreditgo.com. The data will be used solely for the purposes described in this policy and will not be shared with any third party without your consent, except as required by applicable laws or regulations. To protect your information, we apply industry-standard security measures, including encryption during storage and strict access controls, to prevent unauthorized access, disclosure, or misuse.

6. How We Collect Information

6.1 CreditGo may collect Personal Data directly from you or indirectly from other external sources to enable us to fulfill our mandate as a Product to process your request and to comply with regulatory requirements. We may collect this Personal Data through:

a. User registration: users disclose their Personal Data to us during registration in CreditGo;

b. Collected by Product:

Information automatically collected:

i) when you use our Product, including technical data such as usage activity and Transaction Data;

ii) when the User makes payments in our Product, including CreditGo, the information generated from the use of the CreditGo Product, which is automatically collected from the User;

iii) when the User interacts with the CreditGo Product, and/or

iv) other information accessed through the API;

c. Collection from CreditGo's third parties: information obtained from other CreditGo's third parties in compliance with applicable laws and regulations;

d. Collection from other CreditGo's registered Users;

e. Public available source as permitted by applicable laws and regulations.

6.2 CreditGo may collect and process access information on the User's approximate location and the Personal Data when the User uses the Product with the prior User's permission, provided that:

a. CreditGo shall be prohibited from accessing and reading images, contacts of Users, external storage, fine location, and/or videos;

b. CreditGo shall not access, collect, use and share the Personal Data and the Access acquired through the Product for the purpose other than Article 7 on Disclosure of Information We Collect and Article 8 on Purpose unless otherwise required or exempted by applicable laws and regulations in compliance to the Apple Policy amended, changed and modified from time to time;

c. CreditGo may also transfer data as necessary to service providers or for legal reasons such as to comply with a valid governmental order, request, court decision, Governing Law, or as part of a merger or acquisition with proper notification to Users.

7. Disclosure of Information We Collect

CreditGo is committing to keep your information confidential. However, you agree that CreditGo may disclose, transfer and/or give access to your Information to parties that we deem necessary in connection with our Services and/or for regulatory compliance purposes for their Processing (if applicable) in connection with one or more purposes as set out in this Privacy Policy and in accordance with applicable laws and regulations, including but not limited to:

7.1 directors, officers, employees and/or affiliates of CreditGo;

7.2 Authorised third party service providers with whom CreditGo works, including:

a. Payment service providers;

b. Electronic signature service providers;

c. electronic know-your-customer service providers;

d. Messaging-as-a-Service API providers;

e. credit scoring service providers;

f. anti fraud & risk control provider;

g. any aggregator or other financial digital innovation provider;

h. loan application/credit history provider;

i. AI communication provider;

j. Advertising provider;

k. web and mobile analytics provider;

l. Message/call channeling service provider; and/or

7.3 Banks;

7.4 Third-party money lenders;

7.5 Business partner for channeling cooperation, joint marketing cooperation and/or other parties relevant to our business operations;

7.6 Courts, prosecutors, police, other government institutions either at the initiative of CreditGo or as required by legal provisions and regulations, directives, instructions or policies of government institutions or government officials;

7.7 Any member of Our group (which means Our subsidiaries, Our affiliates, Our ultimate holding company and its subsidiaries) from time to time for one or more of the purpose;

7.8 Other registered Users of CreditGo when checking updates of Your Personal Information or alternative Personal Information in our Product; and

7.9 Any party authorized and/or approved by you.

We may need to disclose Personal Data to third party service providers, agents, our affiliated companies, and/or other third parties. Nonetheless, such third-party service providers, agents and/or affiliates or related companies and/or other third parties shall only manage and/or utilize Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with applicable laws and regulations.

8. Purpose

8.1 User hereby agree that CreditGo is entitled to request, obtain, collect, process, analyse, rectify, update, store, disclose, display, announce, transfer, disclosure and/or use one or more information we collect of data subject, in the framework of or related to for one or more of the below purpose as permitted by laws and regulation is as follows:

a. Sending one of User's Information to the relevant third party for the purpose of providing CreditGo's service to User, including but not limited to: i) registration and credit scoring; ii) electronic signature provider as disclosed in Article 7;

b. Assessment, analysis, verification, validation or examination of

(i) application registration;

(ii) a loan application and line of credit;

(ii) the process or application for registration; and/or

(iii) User profile, by using any methods from CreditGo;

c. Carrying out statistical analysis, credit, risk and anti-money laundering screening, conduct credit checks, reviews and other backgrounds checks and/or risk profile and keep history of Your credit for current and future reference;

d. Comparing information, and verify with the authorized third party service provider whom we may cooperate with to ensure that the information is accurate;

e. Contacting you to determine the availability of the contacts You provide and the fraud-risk of Your application;

f. Requesting the update of User's Personal Information or alternative Personal Information from User, third parties or other Users;

g. Monitoring, detecting, prevent, verify and investigate suspicious transactions or transactions that are indicated to contain elements of fraud, crimes or violations of the Terms and Conditions or applicable legal provisions, as well as taking necessary actions as a follow-up to the results of monitoring or investigating such transactions;

h. Helping us detect and fight abuse, malicious acts, fraud, spam, and illegal activity on the Product;

i. conducting investigations under the prevailing laws including anti-money laundering and prevention of terrorist financing in the financial services sector;

j. Creating, manage, train and/or develop credit assessment models, including but not limited to artificial intelligence or machine learning models and algorithms in connection with the services and products of CreditGo or any other cooperative/related third-parties;

k. Calling and/or send you our marketing and/or promotional Materials from time to time through short message service (SMS), email;

l. Sending newsletters/information from/about the service/products of us, our related companies and any third parties that may be of interest to you;

m. Evaluating the effectiveness of the marketing of the Product/cooperative or related third parties, including for periodic checks, for marketing research, evaluation, academic studies, analysis and product development. This allows Us to understand and analyze Your preferences and needs, and develop new features, products and services;

n. Sending any related loan reminder in Product to User;

o. Responding and processing your inquiries, requests, complaints, and notify any change on Product and services;

p. Fulfillment of CreditGo's rights and obligations based on legal provisions and statutory regulations including but not limited to relevant laws and regulation on Anti-Money Laundering and Counter Financing of Terrorism, Funding Agreements and/or Loan Agreements;

q. Implementation and supervision of the Loan Agreemen;

r. Implementation of CreditGo's business and operational activities from time to time in good faith;

s. Survey, research, evaluation and/or development of products or services by CreditGo or related interested parties;

t. Processing, administering, managing and dealing with the Service or products that any third-party provided to CreditGo; and

u. Use Your Personal Information for any other purpose to which You have provided consent.

We may request, obtain, collect, process, analyse, rectify, update, store, disclose, display, announce, transfer, disclosure and/or use Your Information for other purposes that do not appear above. However, We will notify You of such other purpose at the time of obtaining Your consent, unless processing of Your Information without Your consent is permitted by any applicable law.

8.2 The User hereby grants CreditGo an irrevocable, non-exclusive, royalty-free, transferable permission to use any information and/or content on the CreditGo Product that the User installs, stores, uses, and/or inputs on or in connection with the CreditGo Product ("Permission") during using or enjoying CreditGo Product.

8.3 This Permission shall continue to operate and only end if the User requests on withdrawal consent to CreditGo in writing for the purpose of deleting User information and/or content on the CreditGo Product, provided that such request will follow to CreditGo's internal policy relating to delete User information.

8.4 If Users do not agree with Us using Your Personal Information for such purposes, Users can send a written request to CreditGo. Please note should You wish to object the usage of Your Personal Information in this way, We may not be able to continue to offer You Our products and services, in which case We may need to terminate Our relationship in order to fulfil Your request.

9. Cookies Policy

9.1 CreditGo uses Cookies for various purposes such as when the User shall visit the CreditGo Product website again, count the number of Users, and remember Users especially if the User uses services on the CreditGo Product.

9.2 When Users access or use the CreditGo Product, CreditGo automatically shall use Cookies.

9.3 If Cookies are enabled, Cookies shall record a small amount of data on the CreditGo Product website visited by the User, and Cookies shall help CreditGo to track the features that the User is most interested in and the content that the User has visited before.

9.4 When the User visits CreditGo's website at a later time, Cookies shall make it easier for CreditGo to customize the CreditGo Product content to meet User's needs.

9.5 If the User does not want to send "Cookies" information about them, the User can disable User Cookies in the web browser function, by using "Options" in the web browser to choose not to receive Cookies on the computer hard disk or choose to request permission on the computer when receiving Cookies. You may not benefit from some Services on the Product if Cookies are deleted or prevented from being installed on your device.

9.6 Click "Help" to find out more about the method of accepting specified Cookies. If the User adjusts the User's computer settings which results in rejection of Cookies on the User's computer, then the User cannot enjoy all the facilities.

9.7 Use of Cookies by many other companies is subject to their own privacy policies, and not this Privacy Policy. Advertisers or other companies do not have access to CreditGo's Cookies.

10. Security of Personal Information

10.1 CreditGo appreciates the protection of User privacy and CreditGo maintains the confidentiality of Information and any information related to User's Account based on this Privacy Policy by:

a. shall not disclose any information except as provided in Article 7 on Disclosure of Information We Collect and Article 8 on Purpose of this Privacy Policy;

b. guard technology products to prevent unauthorized computer or network access;

c. limit CreditGo employees who have access to User data;

d. carry out technical security efforts to secure the storage of information; and

e. continuously monitor that User Information is protected and there are safeguards in place to protect Information.

10.2 CreditGo shall take all reasonable steps and actions to prevent loss, misuse or alteration of User's Personal Information without permission by unauthorized parties.

10.3 Regardless of CreditGo's steps and precautions, unauthorized entry or use, as well as hardware or software failure, may occur and compromise the security of User's Personal Information. In connection with these matters CreditGo hereby provides a disclaimer that, to the fullest extent permitted by law, any direct or indirect responsibility or liability arising from or in connection with any loss, theft, or unauthorized access, taking, use, disclosure, copying, modifying, deleting or similar actions regarding Personal Information provided by Users to CreditGo.

10.4 Despite Our measures and precautions, unauthorized entry or use, as well as hardware or software failures, may occur and compromise the security of Your Personal Data. In connection with these matters We hereby provide a disclaimer that, we cannot guarantee that the internet is 100% secure. Users' transmission of Personal Data to and from our Funding Services is at your own risk. Therefore, We recommend that You should only access the Product in a secure and protected internet environment.

10.5 Users understand that we may share your Personal Data with authorized government agencies and/or other agencies that may be designated by government authorities. You agree and acknowledge that the storage of Your Personal Data by the relevant government agencies and/or other agencies will follow each party's policies regarding data storage.

10.6 Users need to pay attention that messages sent via an internet connection cannot be fully guaranteed for security and can be withheld, lost or changed. CreditGo shall not be responsible for messages that are lost, modified by third parties, or withheld and CreditGo is not materially responsible to Users or anyone for damage or other matters in connection with messages sent by Users to CreditGo or by CreditGo to Users via an internet connection.

11. Failure to Secure Personal Data

11.1 CreditGo is committed to safeguarding Your Personal Data and complying with the provisions of applicable laws and regulations.

11.2 In the event of a failure to protect Personal Data on the Product or when we become aware of it from a third party, we will make reasonable efforts to notify in writing via electronic mail to You with and provide the reasons or causes of the failure to protect your Personal Data.

12. Storage of Personal Data

12.1 The Personal Data we collect may be stored or processed overseas, at locations managed by CreditGo, and may also be handled using cloud storage and cloud computing services. Whenever Personal Data is transferred abroad, we take measures to ensure it is adequately protected and require all our group companies, employees, and authorized partners to follow consistent security standards and best practices when handling your data, helping to maintain its confidentiality and security at all times.

12.2 CreditGo will ensure all reasonable steps and measures to prevent the destruction, loss, misuse, disclosure, access or unauthorized alteration of your Personal Data by unauthorized parties. We protect your Personal Data by:

(i) restricting access to Personal Data;

(ii) maintaining and using technology products, including firewalls, and other security procedures to prevent unauthorized computer access and network access; and

(iii) other reasonable cybersecurity measures.

12.3 CreditGo shall also take reasonable steps to protect User data during transfer and storage; steps may include obtaining User consent, implementing contractual protections, and using other legally recognized transfer mechanisms.

13. Change, Return and Destruction of Personal Data

13.1 User's Personal Information can be destroyed at the request of the User, unless CreditGo is required to store it in accordance with statutory provisions.

13.2 Destruction of Personal Information includes removing part or all of the documents related to User Personal Information that CreditGo keeps so that the Personal Information cannot be displayed again in CreditGo's electronic system unless the User provides new Personal Information to CreditGo.

13.3 CreditGo understands that Users need to update or change User Personal Information from time to time. If the User needs to update or change Personal Information, the User can submit a written request via electronic mail (e-mail) to CreditGo and provide CreditGo with the relevant details. CreditGo will help update and/or correct User Personal Information for Users, provided that such changes are not: i) endanger the security, physical health, or mental health of the Personal Data Subject and/or other persons; ii) has an impact on the disclosure of Personal Data belonging to other people; and/or; iii) contrary to the interests of national defense and security.

14. Users' Rights

You as a User of Our Product have rights to Your Personal Data, including but not limited to:

14.1 accepting the obligation from Us to maintain the confidentiality of Your Personal Data;

14.2 getting access to change or update their Personal Data to be accurate in the Product;

14.3 getting access to obtain historical Personal Data that has been provided to Us as long as it is still in accordance with the provisions of the applicable laws and regulations;

14.4 submitting an application for the destruction of Personal Data that We manage and store, unless otherwise determined by the provisions of the applicable laws and regulations;

14.5 receiving information regarding the purpose of use and disclosure of Your Personal Data by Us as mentioned in this Privacy Policy.

15. User Responsibility

15.1 The User agrees that the User must only submit to us your Personal Information that is accurate and not misleading and you must keep it up to date as well as inform us of any changes (more information below). We reserve the right to request for documentation to verify the information provided by you. If you provide Personal Information of any third party to us, including but not limited to contact information of a third party for emergency contact purposes, you warrant to us that you have obtained the required consent from the relevant third party to share and transfer his/her Personal Information to us.

15.2 The user agrees to release and indemnify CreditGo, affiliates, shareholders, directors, commissioners, employees, sub-contractors, providers, and or CreditGo's agents for any requests, lawsuits, claims, losses, damages, including legal consultant fees, caused by violation of this Privacy Policy, Loan Agreement, Services and/or other agreements by User and CreditGo.

16. Amendment

16.1 We reserve the right to amend this Privacy Policy at any time without advance notice unless required by law. All changes will be effective upon publication and shall be applicable to all users. Users are adviced to check this Privacy Policy periodically.

16.2 Your continued usage of the Mobile Application, Website or Services after any change of this Privacy Policy shall be deemed as an acceptance by you of the changed Privacy Policy.

17. Withdrawal of Consent

You may express your objection to our continued use, collection and/or processing of your Personal Data for any lawful purpose and in the manner as stated at any time by contacting us at our email address. This will be your mechanism for terminating or permitting permissions previously granted to us. Please note that if you raise your objection to the processing of certain Personal Data, depending on the nature and subject of your objection, the same may impact the timeline of your application and/or our analysis of your credit worthiness. Our legal rights and remedies are expressly protected by law in such events.

18. Contact Us

If you have questions, comments and requests or other matters related to the Product, you can contact CreditGo's customer service via:

E-mail: contact@manocreditgo.com