Expensura Privacy Agreement
Dear Expensura Users: Please read the "Expensura Privacy Policy" carefully and confirm that you understand our rules for handling your personal information. If you have any questions during your reading, please contact our customer service. If you disagree with any terms in the agreement, you should immediately stop accessing Expensura.
Expensura (hereinafter referred to as "we" in this privacy policy) places great importance on user privacy and personal information protection. Before using our products or services, we hope that you read this policy carefully and confirm that you fully understand the content specified herein, allowing you to make choices you deem appropriate according to this privacy policy. We strive to use concise expressions for the relevant terms involved in this privacy policy to help you understand better. By using our products or services and continuing to do so after we update this privacy policy (we will promptly notify you of any updates), you agree to the content of this privacy policy (including updated versions) and consent to our collection, use, storage, sharing, and public disclosure of your relevant information as outlined in this privacy policy.
If you have any questions about this privacy policy or related matters, you can always contact us via customer service email.
How We Collect and Use Your Personal Information
Categories of Information Collected:1. Information related to terminal devices and the Expensura application: Information related to the terminal device you use and Expensura, such as IDFA, iPhone version, model name, application version, etc.
2. Personal information related to loan services: If you use Expensura's loan services, we may collect personal information related to the loan service, such as ID card information, bank card information, contact information, facial photos, etc.
3. We may also collect other various types of anonymous information that are not linked to individuals. For example, when using specific services, we may collect information on user interactions, such as clicks or browsing activities. The purpose of collecting such information is to improve the services we provide to you. The category and amount of information collected depend on how you use, join, or participate in our products and services.
How We Collect Your InformationWe collect your personal information through the following five channels:
1. Information you provide directly: We may collect and store any information you provide to us while using Expensura services, including information you fill out online on our pages, information you provide when contacting us while using Expensura services, and transaction information generated during your use of our services.
2. Information we actively collect: During your use of Expensura-related services, we will collect information sent to us by your mobile phone and other access devices.
3. Information obtained from other sources: With your consent, we may also obtain relevant information about you from Expensura partners, credit institutions, and third-party organizations that legally hold your relevant information. We will confirm the legality of the personal information sources based on agreements with third parties and use your personal information in compliance with relevant laws and regulations after obtaining your consent.
4. Other legally obtained information.
How We Use Your InformationThe primary purpose of collecting your information is to provide you with a safe, efficient, and personalized service experience. We will use your personal information for the following purposes:
1. Real-name verification: We need to verify the authenticity of your identity when you use Expensura. Therefore, you need to provide your identity information, bank card information, and mobile phone number. We will submit this information to legally recognized identity verification agencies to verify the accuracy of the information you provided. If you do not provide the above information, you will not be able to use financial services that require real-name verification under relevant U.S. laws and regulations, such as loans.
2. Qualification, credit, and repayment capacity assessment: While using Expensura, we will use your basic personal information, identity information, property information, and other information collected with your consent during the specific business process to assess your credit status, manage and control risks. Additionally, we will continuously utilize the above information to detect, prevent, or correct activities that may involve fraud or other potential illegal acts during your enjoyment of Expensura services.
3. Provide you with the Expensura-related services you choose: When you use Expensura-related services, such as loan services, we will use your personal identity information, property information, and other information collected with your consent during the specific business process to evaluate the suitability of our products or services, verify transaction authenticity, process service requests, complete transaction instructions, and send transaction notifications, etc. We will also utilize the information to compare accuracy and verify details with third parties. To comply with relevant laws, regulations, and regulatory requirements and to facilitate your inquiry of transaction records or historical status, we will archive your identity information, transaction information, and behavioral information while using Expensura and will properly store this information as required by law and regulations.
4. Provide customer service and handle complaints: Our customer service system will use your account information and transaction information. To ensure your account's security, our online customer service staff will verify your identity using your account information. When you need us to provide customer service and after-sales service related to your transaction information, we will query your transaction information.
5. Improve our products to provide you with more personalized services: We may collect your transaction information and browsing information for data analysis to form user profiles and display product or service information that you are interested in. We may also collect any other information obtained reasonably necessary to provide and improve service quality, including relevant information you provide when contacting customer service. We may correlate information collected from your various devices to provide you with consistent service across these devices. We may combine information from one service with information from other services to provide you with services, personalized content, and suggestions.
6. Functions necessary to ensure transaction security: To enhance system security while you use our products or services, accurately prevent phishing website fraud, and protect account security, we may assess your account risk using your browsing information, transaction information, frequently used software information, device information, etc., and may report some links (URLs) that we consider to be risky. We will also collect your device information to analyze system issues concerning Expensura, statistically inspect traffic, and investigate potential risks, especially when you choose to send us abnormal information.
7. Conduct marketing activities: We may utilize the information you provide and that we collect to recommend personalized products or services to you.
8. Resolve disputes: If disputes arise between you and us that cannot be resolved through negotiation, Expensura may provide your personal information to collection companies, law firms, courts, arbitration committees, or other organizations.
9. Collect user feedback or diagnose and resolve user issues: Your voluntary feedback is invaluable to help Expensura improve our services. To track the feedback you provide, we may use your personal information to contact you and keep records. We may also pinpoint issues and resolve problems based on the logs you provide.
10. Send notifications: We may occasionally use your personal information to send important notices, such as communications related to loans and changes to our terms, conditions, and policies.
You are fully aware that in the following circumstances, we can collect and use personal information without your authorization:1. Related to national security and defense;
2. Related to public safety, public health, and major public interests;
3. Associated with criminal investigations, prosecutions, trials, and enforcement of judgments;
4. Required for safeguarding the major legitimate rights and interests of personal information subjects or others, which it is difficult to obtain consent for;
5. Personal information collected that the personal information subject has made publicly available;
6. Personal information collected from publicly disclosed information legally, such as legitimate news reports and government information disclosures;
7. Necessary for signing a contract at your request;
8. Required for legitimate news reporting purposes;
9. Necessary for academic research institutions based on public interests, and when providing results to external entities, treating personal information contained in those results in an anonymized manner;
10. Other situations stipulated by laws and regulations.
Rules for the Use of Your Personal Information1. We will use the collected personal information according to the stipulations of this privacy policy for the purposes of achieving our product or service functions.
2. Please note that all personal information you provide while using our products or services will continue to authorize our use during your use of our products or services unless you delete or refuse our collection through system settings. Upon account cancellation, we will cease using and will delete your personal information or anonymize it as required by relevant laws and regulations.
3. We will conduct statistical analyses on the usage of our products or services and may share this statistical data with the public or third parties to display the overall usage trends of our products or services. However, this statistical information does not contain any identifying information about you.
4. When we intend to use your personal information for purposes not specified in this policy, or use information collected for specific purposes for other purposes, we will seek your prior consent.
How We Share, Transfer, and Publicly Disclose Your Personal Informationn
Sharing1. We will not share your personal information with any company, organization, or individual outside of Heewan Finance Limited, except in the following situations:
(1) We have obtained your explicit consent or authorization;
(2) Necessary disclosures as required by applicable laws and regulations, legal processes, or mandatory administrative or judicial requests;
(3) Necessary to establish a credit system, submitting relevant information generated during your use of our services, including basic personal information, sensitive personal information, and other information reflecting personal credit to third-party credit institutions. Borrowers agree that micro-lending companies and their affiliated enterprises have the right to cease providing any services to the borrower, and any resulting losses to the borrower are not the responsibility of the aforementioned parties.
(4) Sharing your information is necessary to achieve the core functionality of our products or services and to provide you with the requested services;
(5) To resolve disputes or controversies as required by you;
(6) As stipulated in relevant agreements we have with you (including electronically signed online agreements and corresponding platform rules) or other legal documents;
(7) For academic research purposes;
(8) For uses conforming to the social public interest as per laws and regulations.
2. We may share your transaction information, account information, and device information with partners and other third parties to ensure the smooth completion of the services we provide to you. However, we will only share your personal information for legitimate, proper, necessary, specific, and clear purposes and will only share personal information that is necessary to provide services. Our partners may not use shared personal information for any other purposes.
(1) Providers of technology and consulting services: We may share your personal information with third parties that support us in delivering services. These organizations include those providing infrastructure technology services. However, we require these service providers to use your information solely for the purpose of providing services to us and not for their own interests.
3. For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements, requiring them to process personal information according to our instructions, this privacy policy, and any relevant confidentiality and security measures.
4. To comply with laws, enforce or apply our usage terms and other agreements, or to protect the rights and properties or safety of Expensura, such as preventing fraud and minimizing credit risk, we may exchange your personal information, transaction information, and activity information with other companies and organizations. However, this does not mean we would sell, rent, share, or otherwise disclose personal information for profit, violating the commitments made in this privacy policy.
TransferWe will not transfer your personal information to any company, organization, or individual, except in the following situations:
1. We have obtained your explicit consent or authorization;
2. Necessary disclosures as required by applicable laws and regulations, legal procedures, or mandatory administrative or judicial requests;
3. Necessary disclosures as stipulated in relevant agreements we have with you (including electronically signed online agreements and corresponding platform rules) or other legal documents;
4. Involved in mergers, acquisitions, asset transfers, or similar transactions, if personal information is transferred, we will require the new organization or company that holds your personal information to continue to be bound by this privacy policy; otherwise, we will ask that company or organization to re-obtain your authorization and consent.
Public DisclosureWe will only publicly disclose your personal information under the following circumstances and only after taking security measures meeting industry standards:
1. Disclosing personal information that you have explicitly consented to be disclosed in accordance with your request;
2. As required by laws, regulations, and necessary mandatory administrative enforcement or judicial requests, we may publicly disclose your personal information based on the types of personal information requested and the disclosure methods required.
Security Protection Measures1. Our technical and protective measures for your personal information:
We take personal information security very seriously and take all reasonable and feasible measures to protect your personal information:
We will implement industry-standard security protection measures and commonly used security technology to prevent unauthorized access, modification, leakage, damage, or loss of your personal information:
We manage and regulate the storage and use of personal information by establishing data classification and grading, data security management specifications, and secure development specifications:
(1) We employ strict data access permissions and multi-factor authentication technology to control and protect personal information, conducting comprehensive security control of data to prevent improper use through strict confidentiality agreements with individuals who access the information and monitoring and auditing mechanisms.
(2) We implement code security checks and data access log analysis for personal information security audits.
(3) We will also conduct security and privacy protection training sessions to enhance our employees' awareness of the importance of protecting personal information.
2. Security incident response:
(1) To manage potential risks such as personal information breaches, damage, and loss, we have established multiple systems that define categorization and grading standards for security incidents and vulnerabilities along with corresponding response processes. We will activate safety plans according to security incident response requirements, conducting damage control, analysis, positioning, developing remediation measures, and working with relevant departments to trace and address the root cause.
(2) In the event of a personal information security incident, we will promptly notify you of the basic situation of the security incident and its possible impacts, the measures we have taken or will take, your recommendations for self-protection, and any remediation measures in accordance with legal regulations. We will inform you of the relevant circumstances through email, letter, phone, or push notification. If it is difficult to notify each personal information subject individually, we will take reasonable and effective methods to publish an announcement. Furthermore, we will proactively report the handling status of personal information security incidents as required by regulatory agencies.
How You Can Manage Your Personal InformationExpensura places great importance on your attention to personal information and strives to protect your rights to access, correct, delete, and withdraw consent regarding your personal information, allowing you to fully safeguard your privacy and security. You can exercise your rights through Expensura's privacy settings or by sending an email to our customer service, and we will protect your rights as required by law."