Privacy Policy
This Privacy Policy ("Policy") applies to Happylend Finance Limited's ("Happylend", "we", "our" or "us") data processing activities. It represents our commitment to treat information with utmost care, transparency and confidentiality in compliance with relevant and applicable data privacy laws and regulations, and with constantly changing commercially acceptable standards for data protection (collectively, the "Law"). This Policy only covers the information that Happylend collects, uses, processes and shares. It does not explain what third parties do with any information they may collect about you separately from Happylend. This Policy also does not cover any websites, platforms, products, or services provided by others. We encourage you to review the privacy policies or notices of those third parties for information about their practices and we hope you will take some time to read this Policy.
When you use our website and mobile application SikaNow ("SikaNow", "app", or "apps"), as the case may be (collectively, the "Platform"), apply for a loan, and more generally, avail of any of our products and services (the "Products and Services", which include the Platform), we appreciate that you are trusting us with your personal information. In this Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.
Please read this Policy carefully as it will help you understand what we do with the information that we collect.
1. WHY DO WE COLLECT YOUR INFORMATION?
You may register in our Platform and, subject to our Terms, be eligible to apply and receive loans under our Products and Services. To do this, we will need to collect your personal information to the extent needed for you to access and for us to provide to you our Products and Services.
2. WHAT INFORMATION DO WE COLLECT?
2.1 Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our Products and Services, when you participate in activities on the Platform or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use. The personal information we collect may include the following: full name; date of birth; marital status; present address; phone numbers; email addresses; emergency contacts; self-reported income; employment status and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
2.2 Information automatically collected
We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device information, such as your IP address, device name, mobile phone usage, information about who and when you use our Platform and other technical information. This information is primarily needed to maintain the security and operation of our Platform, and for our internal analytics and reporting purposes.
2.3 Information collected through our Platform
If you use our Platform, we may request access to the following device permissions and collect limited information for the purposes described below:
• Advertising ID. We collect your device's advertising identifier (Advertising ID). This helps us measure app performance, prevent fraudulent activities, and improve our marketing campaigns. The Advertising ID is used for attribution and analytics only and may be shared with authorized service providers under data protection agreements.
• Financial SMS Data. With your explicit consent, we may access SMS messages that contain financial transaction information (e.g., bank alerts, salary credits, loan repayments, or payment confirmations). This information is used exclusively to verify your income stability, evaluate your repayment ability, and prevent fraudulent applications. SMS content unrelated to financial transactions is ignored and never collected. All SMS data is encrypted during transmission, processed securely on our servers, and never shared with advertisers or unrelated third parties. You can deny or revoke this permission at any time in your device settings, although certain credit evaluation features may not function without it.
• Phone State Data. We may collect limited phone state information such as SIM card details, carrier name, and network status. This data is used for fraud prevention, account security.
• Installed App List. We may access limited information about the applications installed on your device, such as app names, categories, installation dates, and versions. This information is used strictly to verify device integrity, assess creditworthiness (for example, checking the presence of reputable financial apps), and detect potential fraud (e.g., identification of high-risk or duplicate loan apps).
• Application Interaction Data. We collect information on how you interact with our application (e.g., clicks, slides, error logs). This information is used to improve user experience, identify technical issues, and optimize service functionality.
• Calendar Data. With your explicit consent, we may access your calendar events (titles, dates, and times) to help us understand your financial commitments and repayment capacity as part of the credit risk assessment process. In addition, we may create repayment reminder events in your calendar to assist you in making timely repayments. Calendar data is strictly limited to these purposes, encrypted during transmission, and never used for advertising or marketing. You may revoke this permission at any time in your device settings.
• Coarse Location Data. We collect approximate location data based on network signals (e.g., Wi-Fi, cell tower). This is used to verify service availability in your area, comply with regulatory requirements, and prevent fraudulent activities. Location data is not continuously tracked and is only collected when relevant to service provision.
• App Usage Data. With your explicit consent, we may collect data on your usage of applications, including the frequency and duration of interactions. This information is processed securely in compliance with data protection standards and is used solely to detect abnormal activity, assess responsible use of financial services, and prevent unauthorized access. We do not collect detailed content from unrelated applications, and the data is never shared with third parties for advertising or profiling purposes.
2.4 Personal information transmission
All collected personal and sensitive information is encrypted and securely transmitted to our server at https://serv.happylendfin.com via HTTPS. Access to this data is strictly limited to authorized personnel and service providers bound by confidentiality and data protection obligations. We do not sell, rent, or disclose your personal information to unaffiliated third parties.
3. HOW DO WE USE YOUR INFORMATION?
3.1 We use personal information collected via our Platform for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
• To perform our Know-Your-Customer and Verification procedures. In order to provide to you our Products and Services, we will need to collect your personal information and verify your identity as our customer.
• To perform loan origination, fulfillment, and collection. Once you have submitted your personal information and have been verified by our system, you will be eligible to apply for a loan via our Platform. In this regard, we will use your personal information in the process of originating your loan application/s and, if approved, fulfilling and performing collection/s for your loan repayment/s, as well as performing any other related data processing activities incidental to these activities.
• To comply with our legal obligations. As a Lending Company, we can perform the release, submission or exchange of customer information with regulators of competent jurisdiction, other financial institutions, credit information bureaus (such as the Credit Information Corporation), lenders (potential or actual), their agents and/or representatives.
• To perform loan collections. We may disclose your personal information to collection agencies, counsels and our agents to enforce our rights against you as our borrower as a last resort in case of default.
• To administer our business. We may disclose your personal information to third party service providers solely for the purpose of assisting or rendering services to us in the administration of our lending business.
• To request feedback. We may use your information to request feedback and to contact you about our Products and Services and your use of our Platform.
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our Terms, conditions, and policies.
• To protect our Platform. We may use your information as part of our efforts to keep our Platform safe and secure (for example, for fraud monitoring and prevention).
• To enforce our Terms, conditions and policies for business purposes, to comply with legal and regulatory requirements pursuant to the Law.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Platform.
• To deliver and facilitate the delivery of services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Platform and/or Products and Services.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Platform, subscribing to marketing or otherwise contacting us, we will collect personal information from you.
• To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform, Products and Services, marketing activities, and your overall experience with Happylend.
• Profiling, automated processing, automated decision-making, or credit rating. We may use your personal data for profiling, automated processing, automated decision-making, credit rating. Thus, we may use any of the methods to process your registration, loan application, and your use of our Platform and/or availment of our Products and Services.
3.2 We will only process your information in the aforementioned methods if the same is necessary for our performance of our obligations to you and based on your consent.
3.3 We commit to implement suitable measures to safeguard your rights and freedoms and legitimate interests. If you wish to exercise your rights regarding profiling, automated processing, and/or automated decision-making you may contact us at sikanow@happylendfin.com.
4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4.1 The Company acknowledges its role and responsibilities under the law, subject to the provisions of this Policy. In providing our Products and Services to you, you consent to our outsourcing of our data processing activities within and among Happylend and its data processors. This arrangement shall be covered by a Data Outsourcing Agreement which you may access upon request from us.
We may also process or share your data that we hold based on the following legal basis:
• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill our Terms and your Loan Agreement with the Company.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
4.2 More specifically, subject to the requirements of the applicable law/s, we may also need to process your data or share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
4.3 Any data transfer/processing/sharing to outside parties will be covered by a Data Sharing/Processing/Outsourcing Agreement, when applicable, provided that your consent has been obtained.
5. WILL YOUR INFORMATION BE SOLD TO ANYONE?
5.1 We fully recognize the importance of privacy protection to you and regard data security as a fundamental corporate responsibility. Without the your explicit and affirmative authorization, we strictly prohibit the sale, trade, or commercialization of your information to any third party, whether directly or indirectly, including but not limited to affiliated entities, suppliers, and business partners.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
6.1 We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, and in the case of account termination, we will promptly delete your personal information unless we are required to retain it for the following purposes, in which case we will keep it in accordance with applicable laws and regulations: tax, accounting, anti-money laundering, or other legal requirements.
6.2 When we have no ongoing legitimate business need to process your personal information, we will either irreversibly delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6.3 You understand that you are, at any time, free to delete your account, uninstall our Platform from your devices, and/or submit an official request for deletion of your data, subject to this Policy. Should you wish to have your personal information deleted and destroyed or you wish to withdraw your consent in the processing of your personal information, you may do so by contacting us.
6.4 The deletion of your personal data shall be honored within a reasonable time from request and as long as it will not compromise, damage, injure, or make inefficient the entirety, integrity, confidentiality, and security of Platform and/or Services, and shall be performed within such reasonable time from the time of your request to do so.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
7.1 We have implemented appropriate physical, technical, and organizational security measures designed to protect the security of any personal information we process subject to the requirements of the law and of commercially acceptable standards for data protection.
7.2 We will develop and implement measures to ensure that all Happylend staff who have access to any personal information will strictly process such data in compliance with applicable laws and regulations. These measures may include drafting new or updated relevant policies of Happylend and conducting or sponsoring training programs to educate our stockholders, directors, officers, employees, agents and other interested parties on data privacy-related concerns. A continuing obligation of confidentiality is also imposed on our stockholders, directors, officers, employees, agents or other interested parties in connection with such personal information that they may encounter during the period of which they connected as such with Happylend. This obligation will still apply after they cease to work with Happylend for whatever reason.
7.3 Happylend will, from time to time, conduct a Privacy Impact Assessment relative to all activities, projects and systems involving the processing of personal information. We will review security policies, conduct vulnerability assessments and perform penetration testing, as applicable, within Happylend on a regular schedule to be prescribed by our IT Team.
Our IT team will continuously evaluate this Policy, considering the following:
a. Safeguards to protect Happylend computer network and systems against accidental, unlawful, or unauthorized usage, any interference which will affect data integrity or hinder the functioning or availability of the system, and unauthorized access;
b. Our ability to ensure and maintain the confidentiality, integrity, availability, and resilience of Happylend data processing systems and services;
c. Regular monitoring for security breaches, and a process for identifying and accessing reasonably foreseeable vulnerabilities in Happylend computer network and system, and taking preventive and corrective actions against security incidents;
d. Our ability to restore the availability and access to personal information in a timely manner in the event of a security incident;
e. A process for regularly testing and evaluating the effectiveness of security measures; and
f. Encryption of personal information during storage and while in transit, authentication process, and other technical security measures that control and limit access thereto.
7.4 Despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
8.1 We do not knowingly solicit data from or market to minors, being individuals under 18 years of age. By using the Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age 18, please contact us at sikanow@happylendfin.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
9.1 Under the Law, you are entitled to the following data privacy rights:
a. the right to be informed whether your personal information shall be, are being, or have been processed;
b. the right to object to the processing of your personal information;
c. the right to reasonably access your personal information;
d. the right to dispute the inaccuracy or error in your personal information and have us correct it immediately and accordingly;
e. the right to suspend, withdraw, or order the blocking, removal or destruction of your personal information from our records;
f. the right to file a complaint with proper government authorities for any violation of your data privacy rights;
g. the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information not in accordance with this Policy;
h. the right to data portability of your personal information;
i. the right to be informed whether personal information is being or has been processed. This includes processing through automated processing, automated decision-making and profiling; and
j. the right to inquire whether your information has been, or is currently being, sold to any third parties.
9.2 In respecting your data privacy rights, you may opt to tell us:
a. not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the Services that you have availed with us;
b. to provide you with information that we currently have about you subject to restrictions applied to us as a company operating in the relevant jurisdictions where Happylend operates by certain laws and regulations;
c. to update your personal information;
d. about your other concerns relating to how we collect, use, share, protect or dispose your information; and
e. to request us suspend or cease sharing or selling your information to any third parties.
9.4 Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with applicable legal requirements.
10. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this Policy from time to time. If we make material changes to this Policy, we may notify you either by prominently posting a Policy of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE AND EXERCISE YOUR DATA PRIVACY RIGHTS?
11.1 If you have questions or comments about this Policy, you may contact us by email at sikanow@happylendfin.com.
11.2 You have the right to request access to the personal information we collect from you, change that information, delete it, or intend to stop sharing your information in some circumstances. To request to review, update, delete your personal information, or stop sharing your information, please email us at sikanow@happylendfin.com.
12. YOUR ACKNOWLEDGMENT AND CONSENT
12.1 By communicating with us using the Platform and our Products and Services, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and/or transfer of your Personal Information by us as described in this Policy.
12.2 You agree that we may use our Personal Data and other Information for automated processing, automated decision-making, profiling, in connection with the your application, establishment, maintenance, cancellation and/or closure of your account and your relationship with us including the our provision of our Products and Services and your use of the Platform and our Products and Services.