Mother Finance

Mother Finance Company Limited’s Privacy Policy Notice

PRIVACY POLICY NOTICE

Welcome to Mother Finance. We believe that consumers deserve the utmost respect when it comes to the privacy of their personal information. This Privacy Policy applies to Mother Finance Co., Ltd, its mobile application, and website (together, “Mother Finance”, “we,” “us” or “our.”). We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use our websites, services, and mobile application. This Privacy Policy also explains your choices for managing information preferences, including opting out of certain uses of your personal information. By accessing or using our services, you consent to this Privacy Policy. If you have questions or complaints regarding our privacy policy or practices, or if you need assistance in exercising any of your decisions and choices under this policy, please contact us at bd@motherfinance.com.mm. This policy applies to all current and former Mother Finance customers. Note that, in order to use our services, you must be 21 years of age or older.

INFORMATION MOTHER FINANCE COLLECTS ABOUT YOU

Mother Finance collects personal information about you which you provide while using www.motherfinance.com.mm, our mobile or desktop application and/or any associated and/or affiliated websites and software applications. We collect most of this information during the registration and/or loan application process for borrowers. Additional information may be gathered during your subsequent use of the website, or software application when we communicate with you via telephone, email or other means. Certain personal information must be supplied during the borrower and/or guarantor registration processes in order to meet our legal obligations, verify your identity, determine eligibility for credit, protect against fraud, and complete your transaction to receive loan disbursement. The following categories of information may be collected:

  • Your basic identifying information (for example, your name, address, email, telephone number, and date of birth);

  • Your national identification number;

  • Your employment and income information;

  • Your bank account information;

  • For a loan to be used with a merchant or service provider, the identity of the merchant or service provider and the name of the party that will receive the good or service; and 

  • Any personal information you provide us. 

In addition, we gather names and email addresses of people who contact us with questions. We collect this information only for the purpose of responding to inquiries and reaching out to you. If you use the comments section of our facebook page, you should be aware that information you submit is stored there and will be visible to other users of the website.

INFORMATION COLLECTED FROM THIRD PARTIES

When Mother Finance checks your qualification for a digital loan through Mother Finance, we will collect information from credit bureaus and other third parties to determine your eligibility for credit, perform creditworthiness analysis, and assess risks related to your potential loan and help determine whether to underwrite and commit to your loan. We also collect information throughout the life of your loan from credit bureaus and other third parties in order to assess risks associated with your loan and provide information to third parties who may be interested in buying or selling your loan, or to provide you with marketing offers. If we engage other third party agencies to refer or assist you in any way in the application process, we may also collect your information from those agencies in order to process your loan application.

The following categories of information are generally collected for loan applicants and borrowers:

  • Your identifying and application information (for example, your name, address, email, telephone number, date of birth, national registration number, and employment information);

  • Your credit score, credit history and other information related to your creditworthiness, unique identity and financial transactions;

  • Your bank account information and recent transactions;

  • If you apply for a loan to be used with a merchant or service provider, information related to any dispute you submit regarding the merchant or service provider; and

  • If you apply for a loan through a third party that is processed through an online finance platform other than Mother Finance, the status and terms of your loan or loan offer through that platform. 

INFORMATION GATHERED BASED ON YOUR ACTIVITY AND BEHAVIOR ON MOTHER FINANCE MOBILE APPLICATION AND LOAN MANAGEMENT SYSTEM

In order to provide services to you, improve our business and maintain records required by law, Mother Finance may collect information about your transactions and activity. For borrowers and guarantors, this includes your payment history as well as information about your computer and your visits to our website, mobile application and other associated and/or affiliated websites and software applications, such as your IP address, SMS and call logs, contact directory, geographical location, browser type, referral source, length of visit, button clicks and page views, with the full permission you have consented to provide to us.

Tracking Technologies

  • Cookies and Web Beacons. Mother Finance and our marketing partners and service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website and mobile application, track users’ movements, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis. We use cookies when you sign in to your account to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which the mobile application and webpages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our site. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of our website and mobile application may be limited.

  • Usage Data & Site Activity. Mother Finance may also use Local Storage, such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.

  • Third Party Technologies. We also partner with third parties to manage our advertising on other sites and evaluate our overall site performance. Our third party partners may use technologies such as cookies to gather information about your activities on our websites and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our marketing efforts or overall site performance.

Do-Not-Track Signals

Mother Finance does not process or respond to “do not track” signals or other similar signals whereby a visitor to a website or mobile application requests that it disable collection of information about the visitor’s online activities over time and across different websites.

HOW MOTHER FINANCE USES YOUR INFORMATION

Processing Your Transaction

If you register as a borrower and/or guarantor, Mother Finance will use your information to facilitate your loan or loan request. This may include:

  • Generating your borrower profile, processing your loan application and verifying your identity and personal information provided;

  • Assigning you a internal credit score rating;

  • Enabling automatic payments and fund transfers with other financial institutions;

  • Implementing collection activities as and when needed;

  • Communicating with you concerning your Mother Finance account and transactions; and

  • Addressing any disputes you may raise concerning your account. 

Analysis & Data Optimization

Mother Finance also uses your information to conduct analyses related to our services, mobile application and website. We use this information to improve our services and credit model. We also use this information to improve our websites’ usability and to evaluate the success of particular marketing campaigns and other activities.

Marketing & Surveys

Mother Finance may also use your personal information to select you for certain marketing offers, newsletters, surveys and/or requests for feedback regarding your experience. Mother Finance may use your personal information both to select you for an offer and to communicate that offer to you.

HOW MOTHER FINANCE SHARES YOUR INFORMATION

We will share your personal information with non-affiliates (companies not related by common ownership or control) and among affiliates (companies related by common ownership or control, including but not limited to the companies covered by this policy) only in the ways that are described in this privacy policy. By law, you are permitted to limit some types of sharing, but not others.

Mother Finance shares your information with third parties as permitted by law, including in the following specific ways:

  • Central Bank of Myanmar, other financial institutions and credit bureaus. All loans originated through Mother Finance may be made by a third party credit underwriter. If you request a loan through Mother Finance, you are also providing your information to the potential credit underwriters, including Mother Finance, and further information may be provided after your loan originates. The use of your information by your originating underwriter is governed by their privacy policy.

  • Third Party Financing Platforms. Certain loan applications through Mother Finance may also be processed by another online finance platform, to which you are providing your information when you apply for a loan. The use of your information by that online financing platform is governed by that company’s privacy policy.

  • Third Party Service Providers. Mother Finance relies on third party service providers to help us conduct our business, collections and marketing activities, such as maintaining our files and records, offering customer service, sending marketing communications, or facilitating fund transfers. Mother Finance may share your information with such companies, which are authorized to use your personal information only as necessary to provide these services to Mother Finance. Information may also be shared among affiliates (including but not limited to the companies covered by this policy) for this purpose where one affiliated company provides services to or on behalf of another affiliated company in connection with your account.

  • Potential Purchasers of Loan. Mother Finance shares your information, including your internal credit rating, on an anonymous basis to allow potential purchasers to decide whether to commit to your loan. This information is also contained anonymously in loan data files available through Mother Finance’s Developer Tools and Marketplace Performance pages. Although your credit information is displayed, your identity is never shared with investors until your loan has been purchased.

  • Purchasers of Loan. If Mother Finance sells your loan originated through our platform, we may provide the purchaser of your loan with your personal and credit information. Information is only released to loan purchasers that are qualified financial institutions with adequate protections to safeguard your personal information.

  • Referral Partners. If you were referred to Mother Finance by another company (a “Referral Partner”) or person, Mother Finance will share your information as necessary to honor the terms of its agreement with that Referral Partner or person and to process your transaction. In some cases Mother Finance may share with a Referral Partner for that Referral Partner’s own business purposes, such as to analyze and improve its business and provide targeted marketing offers to you. Your rights with respect to this sharing are discussed in the following section.

  • Merchants or Service Providers. If you applied for a loan to be used with a merchant or service provider, Mother Finance may share your information with the merchant or service provider associated with your loan application.

  • Credit Bureaus. Mother Finance may share your personal information with credit bureaus to meet our credit reporting obligations.

  • Affiliates. Mother Finance affiliates, including entities covered by this policy and other companies related by common ownership or control may share your information with each other, including information related to your creditworthiness, for purposes of general business analysis or to present targeted marketing offers to you or others. Your rights with respect to this sharing are discussed in the following section.

  • Legal Requests & Regulatory Requirements. Mother Finance may also share information to comply with, or to allow investors or potential investors to comply with, any applicable law, regulation, legal process or governmental request; or for the purposes of limiting fraud; or in connection with an audit or the sale of Mother Finance to a third party.

  • Sharing of Anonymized Data. Mother Finance may share aggregated and anonymized data sets including your information with third parties, including but not limited to business partners, service providers, loan purchasers, potential loan purchasers, and among Mother Finance affiliates. No personally identifiable information will be included in these data sets.

  • In case of misrepresentation and/or default. For whatever reasons, the borrower and/or guarantors misrepresent personal information with respect to the loan application and/or fail to repay the loan timely, the company has the right to use the information given in the loan application submitted through the mobile app as well as the data collected from the mobile with prior consent from borrower and/or guarantors as public service announcement. 

IMPORTANT PRIVACY CHOICES

Consent to information sharing with third party companies (Referral Partners): By accepting this privacy policy, you agree that Mother Finance may immediately begin sharing your information with any third party company that referred you to Mother Finance so that that company may use your information for their own business purposes, including to market to you. For example, if you were referred to Mother Finance by another company through a website link or telephone transfer, Mother Finance may share some of your information, such as the existence and terms of your loan, with that company. You may revoke this consent at any time by following the procedures outlined below. If you revoke consent we will not subsequently share your information with these companies except as necessary to complete the transaction you initiated. Right to restrict information sharing with companies we own or control (affiliates): Mother Finance may share your information among affiliated companies whether or not those companies are covered by this policy. The law may give you the right to limit this sharing where it includes information about your creditworthiness other than your transactions and experiences with Mother Finance or is used for the purpose of marketing to you. If you would like to opt-out of this type of sharing, please follow the instructions below. We may begin sharing your information related to your creditworthiness or any information to be used for marketing purposes 30 days from the date that we first provided this notice if you have not opted-out. If you would like to exercise your right to opt-out of information sharing by a company affiliated with Mother Finance but not covered by this policy, you must consult that company’s privacy policy for instructions on how to exercise your right to opt-out of their information sharing.

ADDITIONAL FACTS ABOUT YOUR PERSONAL INFORMATION

How you can change your personal information

You can access the personal information you have provided to us by logging in to the “Settings” page of your account. As a registered borrower, you may update your password, email, phone number, bank account information or mailing address at any time, though certain changes prior to loan origination may require you to submit a new loan application. To change other information, contact us at bd@motherfinance.com.mm. We will respond to your request within a reasonable time. We will retain your information for a minimum of seven years and as long as needed to provide you services, comply with our legal obligations, resolve disputes, conduct analysis, audits, or to enforce our agreements or as otherwise required by law.

How Mother Finance Secures Your Information

Mother Finance uses significant safeguards, including physical, technical (electronic), and operational controls to protect your personal information, both during transmission and once received. If you have any questions about the security of your information, you can contact us at bd@motherfinance.com.mm. Mother Finance equips all servers with an Extended Validation (EV) Secure Socket Layer (SSL) certificate to ensure that when you connect to our websites you can tell that you are actually on our site and that all data entered into the websites are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected. Data security is achieved through technical safeguards that include a combination of encryption, firewalls, intrusion detection system, malware detection system, and data loss prevention systems. Mother Finance also conducts vulnerability scans of applications and systems regularly. Access to the system is tightly controlled and limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and internal information use policy ensure that only trained and trusted staff are permitted to access personal information. Some additional features of our security program include:

Secure Cloud Storage Data

We store all sensitive financial information in state-of-the-art, highly secure cloud storage data that are audited per SSAE 16 Type II and/or SOC 2 Type II standards. Physical access to the data centers is strictly controlled and we use the latest threat prevention technologies such as network and web application firewalls, VPN, antivirus, Web filtering and antispam technologies.

Session Time-Outs

We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password. You should always choose a password that is difficult for others to guess and change your password frequently.

ADDITIONAL STEPS YOU SHOULD TAKE TO ENSURE THE SECURITY OF YOUR INFORMATION

Mother Finance sends important communications regarding your account via email or sms or notifications through our mobile application. You should therefore take steps to secure and restrict access to your customer account and change your account password frequently. You should also be aware of fraudulent emails known as “phishing,” from companies claiming to be Mother Finance and requesting your login information or other account information. Mother Finance will never ask for your login information in an email. When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files and saved passwords. This step is particularly important if you use a computer that is accessed by other people, such as in a public library or Internet café.

Changes to this policy

Any updates to the privacy policy become effective when posted on the websites and/or mobile application. If we make any material changes, we will notify you by email or by providing the revised privacy policy in your account through Mother Finance©. Your continued use of our services following the update means that you accept Mother Finance’s updated privacy policy. For additional information, or if you have any questions regarding this policy or the privacy practices at Mother Finance, please submit your questions or comments directly to bd@motherfinance.com.mm. You can also send questions or comments to: Mother Finance Co., Ltd

Attn: Legal & Compliance Department

No. 44/46 Street 2, Ward 1 Lanmadaw Township, Yangon Myanmar

Effective date: July 1, 2018