Privacy Policy

Who are we?

‘We’, ‘us’ and ‘our’ refers to BC Mortgages Services Asia Limited (BRN: 72444777) and its related entities that form part of a group of companies under BC Investment Group Holdings Limited (Registration Number MC-347321), its affiliates, subsidiaries, associated entities and any of their branches and offices (together or individually) referred to as a "member of the BC Investment Group" has the same meaning.

Who are you?

In this Policy, the term “data subjects” or “you” shall include applicants for loan facilities and customers of loan facilities.

The content of this Policy shall apply to all data subjects and form part of the terms and conditions of the Loan Agreement and/or any agreement or arrangement that the data subjects have or may enter into with us from time to time. In the event of any inconsistency or discrepancy between this Policy and the relevant agreement or arrangement, this Policy shall prevail insofar as it relates to the protection of the data subject’s personal data.

Our Commitment to Protect Your Privacy

We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

We are committed to the full implementation and compliance with the six data protection principles and the requirements of the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”).

We pledge to safeguard your personal data by complying with the requirements of the Ordinance as well as the relevant codes of practice and guidance notes issued by the Office of the Privacy Commissioner for Personal Data. We will ensure that all our employees and third parties with permitted access to your personal data uphold these obligations.

How Safe and Secure is Your Personal Information That We Hold?

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Retention of Personal Data

We will take practical steps to ensure that your personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personal data.

Personal Data

Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. From collecting your personal information which also includes credit information, we will assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history and any defaults. Usually, credit information is exchanged between credit and finance providers and Credit Reporting Bodies (“CRB”).

To do this, we may disclose personal information such as your name, date of birth, and address to the CRB to obtain an assessment of whether that personal information matches information held by the CRB. The CRB may give us a report on that assessment and to do so may use personal information about you and other individuals in their files. If you are applying for finance, we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses. If we are unable to verify your identity using information held by a CRB we will provide you with a notice to this effect and give you the opportunity to contact the CRB to update your information held by them.

The kinds of personal information we may collect about you include but not limited to: your name, date of birth, address, account details, occupation, and any other information we may need to identify you including publicly available information from public registers and social media. If you use our website or mobile applications, we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information. We may collect some of this information using cookies, as described below.

Credit Information

We may collect the following kinds of credit information and exchange this information with CRB and other entities:

credit liability information being information about your existing finance which includes the name of the credit provider, whether the credit provider holds any Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;
repayment history information which is information about whether your meet your repayments on time;
information about the type of finance that you are applying for;
default and payment information; and
court proceedings information.

We exchange this credit information for the purposes of assessing your application for finance and managing that finance.

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

When we obtain credit information from a CRB about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

We may disclose your credit information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.

Sensitive Information

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional association or trade unions, sexual preferences, criminal record, or health.

Why We Collect Your Personal Information

We collect personal information for the purposes of assessing your application to become a member in our fund and/or your application for finance and managing that finance. If you are applying for any financial products, we collect your personal information to assess your application and manage and administer those financial products. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. The types of organisations to which we are likely to disclose information about you include other mortgage intermediaries, lenders, valuers, lenders mortgage insurers, surveyors, accountants, CRBs, recoveries firms, debt collectors, product issuers, investment managers and lawyers. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your finance, or in our business.

We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. Improvements in technology also enable organisations like ours to collect and use information to get a more integrated view of our customers. From time to time, we may offer you other products and services.

Direct Marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on +61 3 9111 5533 or by writing to us at either info@bcinvest.co or Level 1, 274 Coventry Street, South Melbourne, VIC 3205, Australia.

If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

If the direct marketing is by email, you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

Collection of personal information

In the course of collecting personal data, we will provide the individuals concerned of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data, and other relevant information. When using our website or the BC Digital Portal, you may provide us with certain kinds of your personal data, as defined in the Ordinance, such as your name, address, date of birth and account information, etc. By using our website or the BC Digital Portal, you consent to the capture and use of your personal data in accordance with this document. Your personal data gathered on our website or on the BC Digital Portal is only used for purposes as described in this document. If deletion, correction and updates are not allowed on our website of the BC Digital Portal, then you should approach the Data Protection Officer.

Cookies are small data files which are placed on your device when you visit our website or the BC Digital Portal. Information collected by cookies is anonymous aggregated research data, and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. From time to time, we may also work with third parties, (for example, advertising networks and providers of external services like web traffic analysis services), to research certain usage and activities on parts of our website or the BC Digital Portal on our behalf using cookies and/ or anonymous identifiers. Most web browsers are initially set to accept cookies. If you would prefer, your browser may be set to disable cookies. However, by disabling cookies, you may not be able to take full advantage of our website or the BC Digital Portal.

Disclosing Your Personal Information

Depending on the product or service you have requested, we may disclose your personal information to:

prospective funders or other intermediaries in relation to your finance requirements;
other organisations that are involved in managing or administering your finance such as third-party suppliers, printing and postal services, call centres, lenders mortgage insurers, trade insurers and CRBs;
associated businesses that may want to market products to you;
companies that provide information and infrastructure systems to us;
anybody who represents you, such as finance brokers, lawyers, and accountants;
anyone, where you have provided us consent;
an organisation providing verification of your identity, including on-line verification of your identity; or where we are required to do so by law, such as under the Anti-Money Laundering and Counter-Terrorism Financing Ordinance (Cap. 165, Laws of Hong Kong) (“the AML & CTF Ordinance”);
investors and potential investors, agents or advisers, or any entity that has an interest in our business;
data aggregators who collate and report information between us and our business partners and/or you;
our authorised representatives;
financial institutions including stockbrokers, custodians, fund managers and portfolio service providers and other entity that administer your financial products;
insurers, if you obtain insurance through us; or
your employers, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or

(b) you have consented to us making the disclosure.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located inside or outside the jurisdiction in which the relevant member of the BC Investment Group is operating.

Updating Your Personal Information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and Correction to Your Personal and Credit Information

We will provide you with access to the personal and credit information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you. A Data Protection Log Book is maintained as required under section 27 of the Ordinance.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven (7) working days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal or credit information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.

An explanation will be provided to you, if we deny you access to the personal or credit information we hold about you.

If any of the personal or credit information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven (7) working days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit information within thirty (30) working days.

We may need to consult with other finance providers or CRBs or entities as part of our investigation.

If we refuse to correct personal or credit information, we will provide you with our reasons for not correcting the information.

Business Without Identifying You

In most circumstances, it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Ordinance, you may contact our Complaints or Data Privacy Officer either by:

(a) telephoning us on (852) 3702 5329; or

(b) emailing to us at info@bcinvest.co; or

We will acknowledge your complaint within seven (7) working days. We will provide you with a decision on your complaint within thirty (30) working days.

Consent Statement

We may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information accordingly if you agree to us for doing so.

You may withdraw your consent at any time by contacting us either by:

(a) telephoning us on (852) 3702 5329; or

(b) emailing to us at info@bcinvest.co; or

By providing us your personal information to us, means you explicitly provide consent to us and/or confirm to us that your sensitive personal data are received and provided to us for processing has been obtained. If you provide us with any personal information relating to a third party (e.g. information of spouse, children, parents, employees, authorised representatives or any other similar information), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their personal data for us to process.

Further Information

You may request further information about the way we manage your personal or credit information by contacting us.

Change in Our Privacy Policy

We are constantly reviewing all our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and marketplace practices. Therefore, we may change this privacy policy from time to time or as the need arises. You may request this privacy policy in an alternative form.