1. Preface

This declaration takes from Gain Hero Finance Limited’s (referred hereinafter to as “GH Finance”) Privacy Policy Statement (referred hereinafter to as “Statement”). The purpose for setting out this Statement is to establish the policy and obligation of GH Finance in fully enforcing and adhering to the principles protection of information, obey the terms and conditions in the personal information (privacy) regulation (referred hereinafter to as “the Regulation”) as well as implement the guidelines published by the Hong Kong Licensed Moneylenders Association in accordance with the Regulation. GH Finance will fulfil its duty in obeying and acting in accordance with the principles set out in the Regulation and the Statement.

2. Purpose of Using Personal Information


2.1 The customer is required to furnish GH Finance with personal information from time to time when opening and/or extending a loan account, setting up and/or extending loan financing, and/or using other financial services.

2.2 GH Finance may not be able to open and/or extend a loan account or set up and/or extend loan financing or provide other financial services if such personal information is not supplied. 

2.3 GH Finance would also collect customers’ personal information during its normal operation, e.g. when customers communicate with GH Finance verbally or in writing, and would do so in writing or via GH Finance’s phone recording system (depending on the situation)

2.4 Customers’ personal information may be used in the following ways:

  • (a) Daily operation of providing loan account, loan financing and other financial services to customers

  • (b) When carrying out credit investigation during loan application and regular or special inspection from time to time.

  • (c) For the compilation and maintenance of GH Finance’s credit rating model.

  • (d) To assist other lenders and/or financial organizations to carry out credit checks and pursue debts.

  • (e) To ensure that the customers maintain reliable credit.

  • (f) To design financial services or related products for the customers’ use.

  • (g ) To calculate the debt between GH Finance and the customers. 

  • (h) To pursue the debts from the customers and personnel responsible for providing the mortgage for the customer.

  • (i) For disclosures that GH Finance makes in order to fulfil the stipulations of any regulations that are binding on the company, or disclosures that GH Finance makes in order to obey and implement the guidelines issued by the regulator or other organizations that GH Finance is expected to follow. 

  • (j) Turn the intent of assessment of GH Finance’s actual or nominated transferee, or GH Finance’s participant or subsidiary participant of the customers’ interest, into a transfer as well as the transaction of the participant’s or subsidiary participant’s target; and

  • (k) To promote GH Finance’s financial services or products; and 

  • (l) Other purposes related to any of the above.


The purposes listed out from (a) to (j) (inclusive of the two items) as well as the relevant purposes in (l) above are compulsory, meaning that the customers must allow GH Finance to use their personal information for the said purposes if they wish to use GH Finance’s service. The purposes listed out in (k) as well as the relevant purposes in (i) above are voluntary, meaning that the customers can choose whether to allow GH Finance to use their personal information for the said purposes.


3. Protection of personal information

GH Finance’s policy is to provide adequate assurance for the protection of personal information as well as for the sensitivity of information and the extent of damage caused by arbitrary access to such information in order to prevent the information from being arbitrarily accessed, processed or used for other purposes. In order to achieve an adequate level of security, GH Finance’s usual method is to strictly limit the access to the information through providing secure storage facilities as well as implement security measures in the information storage facilities. GH Finance would also adopt measures to ensure that the personnel handling such information have good conduct, are vigilant and are capable in handling matters. The information would only be transmitted in adequately secure ways.


4. Accuracy of personal information

GH Finance’s policy is to ensure that the information collected and processed via the company is accurate. GH Finance would implement appropriate procedures to verify and update all personal information in order to ensure that the relevant information is appropriate and accurate for its intended use. If the personal information that GH Finance possesses contains opinion statements, GH Finance would adopt all reasonable, practical and feasible steps to ensure that all statements made are in support of the facts in the opinion statements and are true and accurate.


5. Collection of personal information

5.1 In the process of collecting personal information, GH Finance would provide a copy of the “Personal Information Collection Statement” to the personnel concerned, in which the purpose for collecting the information, the identification category of the personnel to whom the information collected would be transferred, the right to access and amend the information as well as other information will be explained. 

5.2 GH Finance will adopt the following practices in relation to the collection of personal information from the Internet:

(a) Online security

GH Finance will safeguard all information supplied to GH Finance via the Internet according to stringent security and confidentiality standards. GH Finance also uses encryption for transmitting sensitive information over the Internet in order to protect personal privacy.


(b) Cookies

Cookies are small segments of information that a website server sends to a browser. The information is stored in the computer hard disk to allow the website server to read again from the browser at a later time. This helps the website to store certain user’s information. 

Cookies have been designed to only allow the websites that send them to read them, but are not able to retrieve the user’s hard disk information and email address or collect the user’s sensitive information.

GH Finance uses cookies only to verify users during a specific period and would not store the user’s sensitive information in the cookies. When a user accesses the GH Finance website, all the links would use cookies to verify the user’s identity. When the user finishes browsing the GH Finance website, the cookies would become ineffective. If the user attempts to set his/her browser’s cookies to stop operating, he/she may not be able to use GH Finance’s online and other financial services.

(c) Amending information online

Once the personal information supplied to GH Finance via online facilities have been submitted, it may not be able to be cancelled, amended or updated online. If the user is not able to cancel, amend or update the information online, he/she must contact the relevant GH Finance department.


(d) Information retained online

Personal information collected online will be sent to the relevant GH Finance department to be processed and would not usually be stored in the website server.


6. Hyperlink policy​

6.1 Though the GH Finance website contains hyperlinks or links to other websites/web addresses, this does not indicate or hint that GH Finance certifies, verifies, explains, approves or recognizes such hyperlinks, links, websites/web addresses or the user’s identity or information.

6.2 GH Finance states clearly that it is not responsible for the contents, supplies, accuracy or omissions of the information provided by or contained in the hyperlinks, links, other websites/web addresses connected or linked to the GH Finance website. 


6.3 The user shall assume all risks that come with all hyperlinks, links or the connection to other websites, web addresses or information sources using the hyperlinks.  


7. Request to access and amend information​

7.1 GH Finance’s policy is to comply with and process all requests to access and amend information according to the stipulations of this regulation as well as help all relevant staff to be familiar with the relevant rules in order to help individuals to make the relevant requests.


7.2 GH Finance may collect a reasonable fee for the request to access information under the condition of complying with the stipulations of this regulation. If any personnel who requests to access information requests GH Finance to provide an additional copy of the information that has been provided before at an earlier request, GH Finance may collect a reasonable fee to fully cover the administrative cost or other costs for providing such an additional copy.


7.3 Requests with regards to accessing and amending information may be made to the Head of Information Protection or other relevant designated personnel.


8. Other practices

To ensure compliance with the stipulations of the regulation, GH Finance has:

8.1 An information log book, i.e. the log book stipulated in Article 27 of the regulation.


8.2 Internal policies and guidelines for Gain Hero staff to refer to in order to ensure that every staff obeys the stipulations of the regulation.

9. Appointment of Head of Information Protection

9.1 GH Finance has appointed a Head of Information Protection who is in charge of planning and supervising the regulation as well as the compliance with the GH Finance’s personal information protection policy.

9.2 The contact information of the Head of Information Protection is as follows:

Unit 01, 12F, Chow Sang Sang, No. 229 Nathan Road, Jordan, Kowloon 

Gain Hero Finance Limited

Head of Information 

Fax: 2735 2990


GH Finance (Hong Kong) Co., Limited ("GH Finance") gives this notice to its customers for the purposes of the Personal Data (Privacy) Ordinance (the “Ordinance").


1. From time to time, it is necessary for customers to supply GH Finance with personal data in connection with the opening and/or continuation of loan accounts, the establishment and/or continuation of credit facilities, and/or provision of other financial services.

2. Failure to supply such personal data may result in GH Finance being unable to open or continue loan accounts, or establish or continue credit facilities, or provide other financial services to customers.

3. It is also the case that personal data are collected from customers in the ordinary course of business of GH Finance, for example, when customers communicate verbally or in writing with GH Finance, by means of documentation or GH Finance's telephone recording system (as the case may be).

4. The purposes for which customers' personal data may be used are as follows:

(a) the daily operation of loan accounts, credit facilities and other financial services provided to customers;

(b) conducting credit checks upon an application for credit and when regular or special reviews are conducted from time to time;

(c) creating and maintaining GH Finance's credit scoring models;

(d) assisting other money lenders and/or financial institutions to conduct credit checks and collect debts;

(e) ensuring ongoing credit worthiness of customers;

(f) designing financial services or related products for customers' use;

(g) determining amounts owed to or by customers;

(h) collection of amounts outstanding from customers and those providing security for customers' obligations;

(i) meeting the requirements to make disclosure under the requirements of any law binding on GH Finance and for the purposes of any guidelines issued by regulatory or other authorities with which GH Finance is expected to comply;

(j) enabling an actual or proposed assignee of GH Finance, or participant or sub-participant of GH Finance's rights in respect of customers to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;

(k) marketing financial services or products of GH Finance; and

(l) purposes relating to each of the above.

The purposes listed in paragraphs (a) to (j) (inclusive) and related purposes under paragraph (l) above are "obligatory", meaning that customers must permit GH Finance to use their personal data for these purposes if they wish to use GH Finance's services. The purposes listed in paragraph (k) and related purposes under paragraph (l) above are "voluntary", meaning that customers have a choice whether GH Finance can use their data for these purposes.

5. Personal data held by GH Finance relating to a customer will be kept confidential but GH Finance may provide such information to the following parties (whether within or outside Hong Kong) for the purposes set out in paragraph 4:

(a) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to GH Finance in connection with the operation of its business;

(b) any other person under a duty of confidentiality to GH Finance including a group company of GH Finance which has undertaken to keep such information confidential;

(c) any person with the express prescribed consent of customers;

(d) credit reference agencies, and, in the event of default, debt collection agencies;

(e) any person to whom GH Finance is under an obligation to make disclosure under the requirements of any law binding on GH Finance under and for the purposes of any guidelines issued by regulatory or other authorities with which GH Finance is expected to comply; and

(f) any actual or proposed assignee of GH Finance or participant or sub-participant or transferee of GH Finance's rights in respect of the customer.

6. GH Finance would like to use personal data of customers for direct marketing purposes. GH Finance cannot use a customer's personal data for these purposes without first obtaining his or her consent (which can include an indication of no objection). In this connection, please note that:

(a) the name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of a customer held by GH Finance from time to time may be used by GH Finance in direct marketing;

(b) the following classes of services, products and subjects may be marketed:

(i) financial related services and products; and

(ii) reward, customer loyalty or privileges programmes and related services and products

Customers have a choice whether or not their personal data are used for direct marketing purposes. If a customer at any time consents to the use of his or her personal data for direct marketing but then changes his/her mind, he or she has the right, without charge, to notify GH Finance that he/she no longer wishes GH Finance to use his/her personal data in direct marketing by writing to the Data Protection Officer at the address or fax number provided in paragraph 10 below or any other method acceptable to GH Finance.

7. Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data issued under the Ordinance, every customer has the right:

(a) to check whether GH Finance holds personal data about him and to have access to such personal data;

(b) to require GH Finance to correct any personal data relating to him which are inaccurate;

(c) to ascertain GH Finance's policies and practices in relation to personal data and to be informed of the kind of personal data held by GH Finance;

(d) to be informed on request which items of personal data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of a data access and correction request to the relevant credit reference agency or debt collection agency; and

(e) in relation to personal data which have been provided by GH Finance to a credit reference agency, to instruct GH Finance upon termination of an account by full payment to make a request to the credit reference agency to delete such personal data from its database, as long as the instruction is given within 5 years of termination and at no time did the account have a default of payment lasting in excess of 60 days within 5 years immediately before account termination. Such account repayment data include amount last due, amount of payment made during the last reporting period (being a period not exceeding 31 days immediately preceding the last contribution of account data by GH Finance to a credit reference agency), remaining available credit or outstanding balance and default data (being amount past due and number of days past due, date of settlement of amount past due, and date of final settlement of amount in default lasting in excess of 60 days (if any)).


8. Customers should note that :

(a) in the event of any default in repayment, unless the amount in default is fully repaid or written off (other than due to a bankruptcy order) before the expiry of 60 days from the date such default occurred, the account repayment data may be retained by the credit reference agency until the expiry of 5 years from the date of final settlement of the amount in default; and

(b) if any amount in an account is written-off due to a bankruptcy order being made against a customer, the account repayment data may be retained by the credit reference agency, regardless of whether the account repayment data reveal any default of payment lasting in excess of 60 days, until the expiry of 5 years from the date of final settlement of the amount in default or the expiry of 5 years from the date of discharge from bankruptcy as notified by the customer with evidence to the credit reference agency, whichever is earlier.


9. In accordance with the terms of the Ordinance, GH Finance has the right to charge a reasonable fee for processing any personal data access request.

10. The person to whom (i) requests for access to personal data or correction of personal data or for information regarding GH Finance's Personal Information Collection Statement and kinds of data held and (ii) notifications about use of personal data for direct marketing are to be addressed is as follows:

(a) Unit 01, 12F, Chow Sang Sang, No. 229 Nathan Road, Jordan, Kowloon 

(b) GH Finance (Hong Kong) Co., Limited

(c) The Data Protection Officer

(d) Facsimile: 2735 299 Gain Hero Finance Limited


11. GH Finance may have obtained a credit report on the customer from a credit reference agency in considering any application for credit and/or reviews or renewals of existing credit facilities to customers. The matters GH Finance will be considering if accessing these consumer credit data for the purpose of reviews will be an increase in the credit amount, cancellation of credit, a decrease in the amount of credit or putting in place a scheme of arrangement with relevant customers. GH Finance may also access such consumer credit data about customers for the purpose of reasonable monitoring of indebtedness whilst relevant customers are in default. If a customer wishes to access the credit report, please contact TransUnion Limited directly at 2577 1816.


12. Nothing in this Personal Information Collection Statement shall limit the rights of customers under the Ordinance.

© 2014-2018 Gain Hero Finance. 


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