1. GENERAL

It is the corporate policy of BelosCap One Limited, its subsidiaries, affiliates, and associated companies ("the Company" or "BelosCap") to respect and safeguard the privacy of an individual's personal data. Compliance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) ("the Ordinance") is the responsibility of the management as well as every employee of the Company.

This privacy statement ("this Statement") is prepared by the Company in accordance with the Ordinance. This Statement provides information on the obligations and policies of the Company under the Ordinance. Throughout this Statement, the meaning of "personal data" is the same as that defined in the Ordinance. This Statement is intended to notify you the following:

1. Our privacy principles;
2. Our data security measures;
3. Reasons for our data collection and our data collection purposes;
4. Our data disclosure practices;
5. Data access requests; and
6. Our contact information

Nothing in this Statement shall limit the rights of customers under the Ordinance.

2. OUR PRIVACY PRINCIPLES

Our business has been built on mutual trust between our customers and ourselves. To preserve the confidentiality of all information you provide to us, we maintain the following privacy principles:

1. We only collect personal information which we believe to be relevant and required to understand your financial needs, to conduct our business and to provide you with tailor-made services.
2. We use your personal information to provide you with better customer services and products.
3. We may pass your personal information to our subsidiaries, affiliates, and associated companies or agents, as permitted by law. All our staff, subsidiaries, affiliates, associated companies and all third parties with permitted access to your personal information are specifically required to observe our confidentiality obligations.
4. We will not disclose your personal information to any external organization unless we have your consent or are required by law or have previously informed you.
5. We may be required from time to time to disclose your personal information to governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.
6. We aim to keep your personal information on our records accurate and up-to-date. We maintain strict security systems designed to prevent unauthorized access to your personal information by anyone, including our staff.

By maintaining our commitment to these principles, we at BelosCap will ensure that we respect the inherent trust that you place in us and will develop a long-term win-win relationship between us.

3. OUR DATA SECURITY MEASURES

1. Security is our top priority. The Company will strive at all times to ensure that your personal data will be protected against unauthorized or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
2. The secure area of our website supports the use of 128-bit Secure Socket Layer (SSL) encryption technology - an industry standard for encryption over the Internet to protect data.
3. Our web servers are protected behind "firewalls" and our systems are monitored to prevent any unauthorized access.

The Company will take all practical steps to ensure that personal data will not be kept longer than necessary and that the Company will comply with all statutory and regulatory requirements in the Hong Kong Special Administrative Region regarding the retention of personally identifiable information.

4. REASONS FOR OUR DATA COLLECTION AND OUR DATA COLLECTION PURPOSES

The purposes for which data relating to a customer may be used are as follows:The reasons for collecting your personal data are set out as follows:

1. From time to time, we collect your personal information in connection with the opening or continuation of accounts and the establishment or continuation of credit facilities or provision of credit services or debt portfolio underwriting and evaluation or reasonable monitoring of the indebtedness;
2. Failure to supply such data may result in the Company being unable to open or continue accounts or establish or continue credit facilities or provide credit services or underwrite and evaluate the debt portfolio or reasonably monitor the indebtedness; and
3. Data is also collected from customers in the ordinary course of business to continue with our relationship with customers. This includes information obtained from credit reference agencies.

The purposes for which data relating to a customer may be used are set out as follows:

1. Evaluate and underwrite consumer and commercial receivables portfolio;
2. Conduct consumer and commercial debt purchase, valuation, restructuring, recovery, and consulting;
3. Perform daily operations of the credit facilities and services provided to customers;
4. Conduct credit checks, credit reviews (including without limitation, upon an application for consumer credit), reasonable monitoring of the indebtedness and carry out matching procedures (as defined in the Ordinance);
5. Create and maintain the Company's credit scoring and risk related models;
6. Assist other financial institutions to conduct credit checks and collect debts;
7. Ensure ongoing creditworthiness of customers;
8. Design financial services or related products for customers' use;
9. Market financial services or related products of the Company and/or selected third party organizations and monitor the provision, operation and use of such services or products;
10. Determine the amount of indebtedness owed to or by customers;
11. Collect amounts outstanding from customers and those who provide security for customers' obligations;
12. Meet the requirements to make disclosure under the requirements of any law binding on the Company;
13. Compare data of customers or other persons for credit checking, data verification or otherwise, producing or verifying data, whether or not for the purpose of taking adverse action against the customers;
14. Enable an actual or proposed assignee of the Company, or participant or sub-participant of the Company's rights in respect of the customer(s) to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;
15. Record customers' calls to ensure quality of service;
16. Exchange information with authorized institutions and service providers;
17. Compiling statistical information and customer profiles;
18. Maintaining a credit history of customers for statistical and research purposes; and
19. Fulfill any other purposes relating thereto.

5. OUR DATA DISCLOSURE PRACTICES

The Company will keep the customers' data confidential, but the Company may provide such information to the following parties (whether within or outside the Hong Kong Special Administrative Region) for the purposes listed above in paragraph (4).

1. Any agent, contractor, third party service provider who provides administrative, telecommunications, computer, payment, securities clearing, debt collection, or other services to the Company in connection with the operation of its business;
2. Any other person under a duty of confidentiality to the Company, including the Company's holding company, subsidiaries, affiliates, associated companies and companies controlled by or under common control with the Company, which have undertaken to keep such information confidential;
3. Credit reference agencies, and/or in the event of default, debt collection agencies;
4. Any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or any of its subsidiaries, affiliates and associated companies or under and for the purposes of any guidelines issued by regulatory or other authorities with which the Company or any of its subsidiaries, affiliates and associated companies are expected to comply;
5. Any actual or proposed assignee of the Company or participant or sub-participant or transferee of the Company's rights in respect of the customers;
6. The drawee bank providing a copy of a paid cheque, which may contain information about the payee, to the drawer;
7. A person making any payment into the customer's account (by providing a copy of a deposit confirmation slip which may contain the name of the customer);
8. Any banking, financial or other institution with which the customer has or proposes to have dealings;
9. Any party giving or proposing to give a guarantee or third party security to guarantee or secure the customer's obligations; and
10. Selected companies for the purpose of informing customers of services which the Company believes will be of interest to customers.

6. DATA ACCESS REQUESTS

Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data approved and issued under the Ordinance, any individual has the right:

1. to check whether the Company holds data about him/her and of access to such data;
2. to ascertain the Company's policies and practices in relation to personal data and to be informed of the kind of personal data held by the Company;
3. to require the Company to correct any related data that is inaccurate;
4. in relation to consumer credit, to request to be informed which items of data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit agency or debt collection agency; and
5. to instruct the Company to make a request to the relevant credit reference agency to delete from its database any related account data upon satisfactory termination of the account by full payment and on condition that there has been no default in excess of 60 days within 5 years immediately before such termination. If an individual has any such default under the credit as determined by the Company, he/she is liable to have his/her consumer credit data retained by the relevant credit reference agency at least until the expiry of 5 years from the date of final settlement of the amount in default or 5 years from the date of discharge of the individual's bankruptcy as notified to the credit reference agency, whichever is earlier.

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

Nothing in this Statement shall limit the rights of customers under the Ordinance.

7. OUR CONTACT INFORMATION

All requests for access to data or correction of data or for information regarding policies and practices and kinds of data held should be addressed, using the prescribed form, to:

The Data Protection Officer
BelosCap One Limited
P.O. Box 28091
Gloucester Road Post Office
Hong Kong SAR
Tel: 3798 5900

The Company may have obtained a credit report on a customer from a credit reference agency in considering any application for credit and/or for reasonable monitoring of the indebtedness and/or for future account review. If the customer wishes to access the credit report, please contact the following credit reference agency:

Consumer Relations Department
TransUnion Limited
Suite 1006, Tower 6, The Gateway
9 Canton Road, Tsim Sha Tsui
Kowloon, Hong Kong
Tel: 2577 1816

Note: In case of discrepancies between the English and Chinese versions of this Statement, the English version shall prevail.

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