Lendingpot HK Limited, Privacy Policy
Last Updated on December 26, 2025

Privacy Policy

‍This Data Protection Policy (“Policy”) outlines how Lendingpot HK Limited and/or its related corporations and/or affiliates (“we”, “us”, or “our”, “Lendingpot”) may collect, use, store, disclose or otherwise process personal data you may provide to us when you access and use the Platform and Services. This Policy is an integral part of, and must be read with, our Website Terms of Use and all other policies, procedures and rules published on this Platform, as may be amended from time to time. Unless otherwise stated herein, capitalised words, phrases or terms that appear hereinafter shall have the same meanings as they have been defined or described in the Website Terms of Use as may be updated or amended from time to time.

“You” or “Your” means users or persons who access our Platform.

“Relationship Managers (“RMs”)” means sales representatives of third party financial institutions or licensed money lenders who are connected with you (if applicable).The Policy supplements, but does not supersede or replace, any other consent that you may have previously provided to us in relation to your personal data. It also does not affect any rights that we may have under relevant Hong Kong law, including the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) and its subsidiary legislation, codes of practice and guidelines, in connection with the collection, use, processing and/or disclosure of your personal data.
‍
‍Personal Data
1. As used in this Policy:

“Personal data” means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained;

“Platform” means our platform, and any websites, any mobile application operated by us or linked to our platform, or any page thereof; and

“Services” means such service that we may provide on our Platform.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your address, email address and telephone number.

3. Other terms used in this Policy shall, where the context permits, have the meanings given to them in the PDPO.

‍Collection, Storage, Use and Disclosure of Personal Data

4. We may collect personal information that can identify you (including but not limited to your name and email address, contact details, residential address, gender, age, date of birth and identity card/passport details) as well as other information that does not identify you (including but not limited to specimen signatures, voice recordings of conversations or occupation). When you provide personal information through the Platform or otherwise provide it to us, the information may be sent to and stored on servers located in Hong Kong, Singapore and/or such other country or territory as may be permitted by applicable law.

5. We use various technologies to collect information from you and about your activities on our Platform. We automatically collect information from your browser when you visit our Platform, including your IP address, browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address.

6. We or our third party service providers may use standard Internet technologies, such as web beacons and similar technologies, to track your use of the Platform. We may include such technologies in promotional emails or newsletters to determine whether messages have been opened and acted upon. The information obtained enables us to customise the Services, deliver targeted advertisements and measure the effectiveness of our online activities.

7. We may collect, use and process your personal data for any or all of the following purposes:(a) performing obligations in the course of or in connection with our provision of the Services requested by you;
(b) verifying your identity;
(c) responding to, handling and processing queries, requests, applications, complaints and feedback;
(d) managing your relationship with us;
(e) sending marketing information about our Services, including notifications of marketing events and promotions, subject to your consent and applicable law;
(f) complying with applicable laws, regulations, codes of practice, guidelines or rules, or assisting law enforcement or regulatory investigations;
(g) any other specific purposes for which you have provided the information;
(h) transmitting to affiliated or unaffiliated third parties (including RMs, service providers and regulators), whether in Hong Kong, Singapore or elsewhere, for the above purposes;
(i) incidental business purposes related to or in connection with the above;
(j) engaging third party software providers to collect usage analytics to help us understand user needs and optimise our Services.

8. We may disclose your personal data:(a) where required to perform obligations in connection with the Services requested by you;
(b) in connection with a corporate transaction such as a sale, merger, consolidation or asset transfer;
(c) in response to legal process, court orders or requests from governmental or regulatory authorities;
(d) where disclosure is appropriate to investigate or prevent suspected illegal activity, fraud or wrongdoing, protect rights or property, enforce our terms or comply with law;
(e) to third party service providers or agents (including RMs) engaged to perform functions listed in Clause 7.

9. You acknowledge that we are not responsible for the actions of third parties in respect of their handling of your personal data once disclosed in accordance with this Policy. Such third parties may be located in Hong Kong, Singapore or elsewhere. To the fullest extent permitted by law, we exclude liability for misuse of personal data by such third parties.

10. The purposes set out above may continue to apply after termination of your relationship with us for a reasonable period, including for enforcement of our legal rights.

‍Withdrawing Your Consent

11. Your consent remains valid until withdrawn by you in writing. You may withdraw consent by contacting our Data Protection Officer as set out in clause 22.

12. We may require reasonable time to process withdrawal requests and will inform you of any legal or practical consequences.

13. Withdrawal of consent may affect our ability to provide Services. We will notify you accordingly.

14. Withdrawal does not affect our right to process personal data without consent where permitted or required by law.

‍Protection of Personal Data

15. We have implemented reasonable administrative, physical and technical measures to protect personal data against unauthorised access, use or disclosure.

16. While no system is completely secure, we continuously review and enhance security measures. Where required by applicable law, we will notify affected individuals of data breaches within a reasonable time after becoming aware of the breach.

‍Accuracy of Personal Data

17. You shall ensure that personal data provided is accurate and complete. We will take reasonable steps to correct inaccuracies upon your request.

‍Retention of Personal Data
‍
18. We will not retain personal data longer than necessary for business or legal purposes.

19. Upon written request and subject to applicable law, we may delete or return personal data and confirm deletion where appropriate.

‍Our Use of Cookies

20. By using our Platform with cookies enabled, you consent to our use of cookies.

21. Cookies do not store personal information capable of identifying you directly.

‍Your Rights in Respect of Your Personal Data

22. Subject to the PDPO, you may request access to or correction of your personal data or withdraw consent by contacting our Data Protection Officer at dpo@ifscapital.com.sg. The address of our Data Protection Officer is11/F, United Centre, 95 Queensway, Hong Kong. A reasonable administrative fee may apply.

‍Effect of Policy and Changes
‍
23. This Policy applies to users accessing the Platform in Hong Kong. Personal data may be transferred to Hong Kong, Singapore or other jurisdictions where our servers or service providers are located.

24. This Policy operates alongside other contractual or consent arrangements.

25. We may update this Policy from time to time. Continued use of the Platform constitutes acceptance of the updated Policy.