PRIVACY POLICY
Mother Finance Co., Ltd., a corporation organized and existing in
the Republic of Union of Myanmar (“Mother Finance”, “we”, “us” or
“our”) takes your privacy very seriously. We believe that
consumers in Myanmar deserve the utmost respect when it comes to
the privacy of their personal information. This privacy policy
(this “Privacy Policy”) applies to Mother Finance, your use of our
website, found here
(the “Website”) as well as your use of the Mother Finance Android
mobile application found here
(the “App”) and your use of our services through the App or
otherwise.
This Privacy Policy describes what information we collect from
you or that you may provide when you visit our Website and/or
download our App and our practices for collecting, using,
maintaining, protecting, and disclosing that information, the
purposes for which we collect and process it, how we use it, who
we share it with, how long we retain it, and your rights in
relation to it. 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. You should read and understand this Privacy
Policy in its entirety.
This Privacy Policy may change from time to time. If material
changes are made to this Privacy Policy, we will notify you by
means of notice to the website. Changes to this Privacy Policy are
effective at the time they are posted to this Website, and where
necessary, after you are notified and your consent is
acquired.
Without in anyway limiting the introductory paragraph, this
Privacy Policy also does not apply to information collected
by:
-
us offline or through any other means, including on any other
website operated by Company or any third party (including, but
not limited to, our affiliates and subsidiaries); or
-
any third party (including, but not limited to, our affiliates
and subsidiaries), including, but not limited to, through any
application or content (including advertising) that may link to
or be accessible from or on the Website.
If you have concerns and questions regarding our App, please
reach out to our developer contact point at
pm@motherfinance.com.mm.
If you have additional questions 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 pm@motherfinance.com.mm. This policy applies to all current and former Mother Finance
customers. Alternatively, you can visit our office or send postal
mail to:
Mother Finance Co., Ltd (DICA Registration No: 101001296)
Attn: Legal & Compliance Department
No. 44/46 Street 2, Ward 1 Lanmadaw Township, Yangon Myanmar
Note that, in order to use our services, you must be 21 years of
age or older. We do not knowingly collect personal information
from children under 18. If you are under 18, do not use or provide
any information on this Website or App or through any of its
features. If we learn we have collected or received personal
information from a child under 18, we will delete that
information. If you believe we might have any information from or
about a child under 18, please contact us at
bd@motherfinance.com.mm.
What data does Mother Finance collect and process? From where does
Mother Finance collect your information?
CONTACTS
As a part of our loan journey, we require references from the Loan
applicant. In this regard, during filling the form on our App, we
collect your contact infomation to detect close contact to enable
you to autofill the data during the loan application process.
Furthermore, we collect contact information from your device and
upload to our server (https://motherfinance.com.mm) for the purposes
of risk analysis by enabling us to detect credible references. The
more credible the references are, the lower is the risk associcated
to a User.
LINK TO THIRD-PARTY SDK
Our application has a link to a registered third party SDK which
collects data on our behalf. Through SDK, contacts, installed
application list, camera, location, phone status and storage data
will be collected and transmitted to the third-party SDK for risk
assessment. These data are stored to a secured server to perform a
credit risk assessment. We ensure that our third-party service
provider takes extensive security measures in order to protect your
personal information against loss, misuse or alteration of the data.
INSTALLED APPLICATIONS
We will get a list of installed applications data information,
including application name, package name, installation time update
time, version name and version code of each installed application on
the device to evaluate your credit value and enrich your personal
data with preapproved custom loan offers.
STORAGE
This permission is required so that users loan account statements
can be securely downloaded and saved on users phone, and so that
user can upload the right documents for a faster approval and
disbursal of the loan. Also, this helps provide a very smooth
seamless experience while using the app.
LOCATION
User location helps to locate and verify the address which helps in
making better credit risk decisions and fasten the Know Your
Customer (KYC) process.
CAMERA
Camera access is required so that user can easily scan or capture
identity documents etc. And save time by allowing us to auto-fill
the required data and helps in improving the user journey and
experience
IN DETAILS
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Identification data (e.g., name, date and place of birth, image
capture);
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Data provided by you through your responses (e.g., information
and documents about your income or employment, your proposed use
of proceeds, your educational attainment, customer-provided
information about your mobile device);
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Contact details (e.g., address, phone number, alternate phone
number, email address);
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Government-issued identification data and documents (e.g.,
National Registration Card, Passport, Driver’s License, Employee
Identification Card);
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Mobile device specifications (e.g., SIM, IMEI, IP address, or
other device identifiers, type of device, device operating
system, device settings, user account information for your
mobile device or Google Playstore account, the name and network
information of your mobile network provider, device
specifications (such as screen size, resolution, CPU capacity,
etc.), information about network proximity);
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Location data (e.g., mobile device location, time zone
setting);
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Transaction data and financial information (e.g., loans,
transfers, payments, loan requests, tax information);
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Device behavioural data (e.g., contact lists, SMS records,
calendars, types and nature of mobile applications found on your
mobile device as well as storage of applications, and registered
accounts which might include social accounts, and installed
applications, or the detection of fraudulent activities,
including the detection of TOR and VPN type of applications
whose purpose involves a financial-transaction functionality
(for example, dedicated banking, dedicated digital wallet) and
obtaining broader visibility into installed applications solely
for identity verification, security-based purposes and
assessment of eligibility for credit);
-
Telecommunications usage data (e.g., call data records, SMS
logs, subscription data, payment details, applications and usage
data, telco score) through partnerships with telco
companies;
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App usage (e.g., traffic (volume) data, information about your
usage or non-usage of the App);
-
Data related to your communications with Mother Finance (e.g.,
your communications with Mother Finance via in-app chat, email,
telephone or other channels);
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Data provided by you in relation to participation in special
offers and promotional activities conducted by Mother Finance
(e.g., waivers, promo codes, games, contests, discounts, and
participation in by-invitation-only groups); and
-
Certain third-party data (e.g., information provided to or from
credit reference agencies or bureaus, external collections
agencies, mobile network providers).
(collectively, your “Information”)
Mother Finance may collect your Information from:
-
You, when download the App and/or indicate that you want to
apply for credit;
-
Your other interactions with us, including Information you may
voluntarily share with our customer support team or other Mother
Finance employees or agents;
-
Your mobile device (through the device permissions is more
fully described below);
-
Credit reference agencies (who may check your Information
against other databases – public and private – to which they
have access) or fraud prevention agencies; and/or
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Third parties and other publicly available sources, with your
consent, when necessary (e.g., we may receive Information from
financial rails (or other disbursement channel vendors) or other
business partners (such as telecommunications companies and
credit scoring service providers) that may assist us in
providing services to you); and
-
Third parties who communicate with us through the contact
information that you provided to us.
Collection and processing of your Information by Mother Finance
is necessary for the provision of Mother Finance’s products and
services and to comply with applicable legal and regulatory
requirements to which you and/or Mother Finance is subject. Apart
from such cases, we do not collect Information without your
specific prior consent.
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 our App
or Website, or when we communicate with you via telephone, email
or other means.
Certain personal information must be supplied during the borrower
registration processes in order to meet our legal obligations,
verify your identity, determine eligibility for credit, protect
against fraud, and complete your transaction. 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. 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.
Depending on your Android Operating System and the version of the
App installed on your device, the following device permissions may
be accessed by the App. Keep your App updated to make sure you can
experience the latest and most secure features.
-
Camera – Mother Finance will request you to
upload photos of your ID and to take a selfie with your ID.
Mother Finance may also request you to upload copies of
documents as proof of income and business;
-
Read and Upload your contacts – Mother Finance
will retrieve information about your contact lists onto our
servers (such as contact names and numbers and including but not
limited to contact frequency, and date of last contact). Mother
Finance uses this information in its credit and underwriting
models to determine whether you are eligible for Mother
Finance’s services. We use automated processing to understand
your network relationships, and this also helps our fraud models
verify your identity. Mother Finance will never reach out to any
of your contacts or provide any of your information to your
contacts unless you separately and expressly direct us to do
so;
-
Find accounts on your device – Mother Finance
checks the list of user accounts created on your device and
checks the email address used to create each account. This helps
our fraud models verify your identity. Mother Finance also uses
this information in its credit and underwriting models to
determine whether you are eligible for Mother Finance’s
services;
-
Location – This helps our fraud models verify
your identity. Mother Finance also uses this information in its
credit and underwriting models to determine whether you are
eligible for Mother Finance’s services. We also use location
data for research purposes;
-
Read phone status and identity – When you sign
up for a Mother Finance account, we will retrieve your phone
number from your device automatically. This ensures that the
mobile number is active and accurate, and that it is linked to
the device you are using to open the account;
-
Read your text messages – Mother Finance will
retrieve information about the SMS stored in your device (such
as message ID, direction, timestamp, phone number, and content).
Mother Finance uses this information in its credit and
underwriting models to determine whether you are eligible for
Mother Finance’s services. We use automated processing to
understand your financial activity, and this also helps our
fraud models verify your identity. We will never share the
contents of your text messages;
-
Receive text messages – This is used to
automatically confirm the one-time password (OTP) sent to the
user via SMS;
-
Read, modify, or delete the contents of your SD card
– Mother Finance will request you to upload photos of your ID
and to take a selfie with your ID. Mother Finance may also
request you to upload photos of documents as proof of
income;
-
Run foreground service – This permission is
needed by the App to upload photos for KYC;
-
Run at start-up – This allows the Mother
Finance app to send notifications to your device upon restart of
your device;
-
View and change network connectivity – This is
used to notify the Mother Finance app when network connectivity
changes so that we can determine whether you are connected to
internet or not;
-
View Wi-Fi connections – Mother Finance uses
the IP address and network type of your device to detect and
prevent fraud;
-
Receive data from internet – Mother Finance
needs this permission in order to send requests through the app
and to allow the app to access the internet;
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Prevent phone from sleeping – This permission
is required by some of the features and services within the App,
such as in-app messaging;
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Retrieve running apps – Mother Finance will
retrieve a list of apps installed on your device. Mother Finance
uses this information in its credit and underwriting models to
determine whether you are eligible for Mother Finance’s
services.
We may also collect several types of information from and about
users of our Website on or through our Website, and/or as you
navigate through and interact with our Website, you acknowledge,
consent and agree that we may use automatic data collection
technologies to collect certain information about your equipment,
browsing actions, and patterns, including information:
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directly from you when you provide it to us by filling in forms
on our Website;
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records and copies of your correspondence (including email
addresses), if you contact us;
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your responses to surveys that we might ask you to complete for
research purposes;
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your search queries on the Website;
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automatically as you navigate through the site, including usage
details, IP addresses, and information collected through
cookies, web beacons, and other tracking technologies;
-
details of your visits to our Website, including traffic data,
location data, logs, and other communication data and the
resources that you access and use on the Website;
-
information about your computer and internet connection,
including your IP address, operating system, and browser
type
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from third parties, for example, our business partners,
whenever you have consented to such sharing of information
-
by which you may be personally identified, such as name, e-mail
address, telephone number, or any other identifier by which you
may be contacted online or offline;
-
that is about you but individually does not identify you, such
as location or demographic information, and/or
-
about your internet connection, the equipment you use to access
our Website, and usage details.
The information we collect automatically from our Website does
not include personal information, but we may maintain it or
associate it with personal information that you provide to us,
that we collect in other ways or that we receive from third
parties, whenever you have consented to such sharing of
information. It helps us to improve our Website and to deliver a
better and more personalized service, including by enabling us
to:
-
estimate our audience size and usage patterns;
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store information about your preferences, allowing us to
customize our Website according to your individual interests;
-
speed up your searches; and
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recognize you when you return to our Website.
The technologies we use for this automatic data collection on
and/or through our Website may include:
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Cookies (or browser cookies). A cookie is a small file placed
on the hard drive of your computer. You may refuse to accept
browser cookies by activating the appropriate setting on your
browser. However, if you select this setting, you may be unable
to access certain parts of our Website. Unless you have adjusted
your browser setting so that it will refuse cookies, our system
will issue cookies when you direct your browser to our
Website.
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Web Beacons. Pages of our Website may contain small electronic
files known as web beacons (also referred to as clear gifs,
pixel tags, and single-pixel gifs) that permit the Company or
third-party business partners, for example, to count users who
have visited those pages and for other related website
statistics (for example, recording the popularity of certain
website content and verifying system and server
integrity).
Some web content or applications, including advertisements, on
our Website are served by third-parties, including, but not
limited to, advertisers, ad networks and servers, content
providers, web analytics providers, and application providers.
These third parties may use cookies alone or in conjunction with
web beacons or other tracking technologies to collect information
about you when you use our Website. The information they collect
may be associated with your personal information or they may
collect information, including personal information, about your
online activities over time and across different websites and
other online services. They may use this information to provide
you with interest-based (behavioural) advertising or other
targeted content. We do not control these third parties’ tracking
technologies or how they may be used. If you have any questions
about an advertisement or other targeted content, you should
contact the responsible provider directly.
What are the purposes for which your Information is processed?
How does Mother Finance use your Information?
-
To assess your eligibility to use our products or services
(including, but not limited to, credit scoring and assessing
your creditworthiness, determining whether you can afford a
product or service you requested and/or determining whether you
are eligible for additional benefits of an existing
product);
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To service your account with Mother Finance (including, but not
limited to, processing disbursement of your funds and collecting
repayment of your outstanding balance);
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To verify your identity and/or other information you provided
to us;
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To detect, combat and prevent fraud, attempted fraud, money
laundering and/or other illegal uses of our services;
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To analyse customer behaviour;
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To administer our systems, maintain service quality and compile
general usage statistics;
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To analyse and improve our services;
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To troubleshoot any problems that you or other customers
encounter with Mother Finance’s services;
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To comply with applicable laws, regulations, and rules, such as
those relating to “know-your-customer” (KYC), customer
verification, transaction monitoring, and/or anti-money
laundering;
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To the extent you have not objected to the use of your
information for direct marketing purposes after proper
notification, to send you marketing or advertising notices or
other promotional offers;
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To provide service updates;
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To provide staff training (where we may monitor or record
customer interactions);
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To interface with credit reference or fraud prevention
agencies;
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To provide customer service or support and to resolve disputes
and complaints;
-
To contact you by telephone using autodialled or pre-recorded
message calls or text (SMS) messages (if applicable) as
authorized for the purposes described in this Privacy
Policy.
We process your Information for the purposes set out above on the
following grounds:
-
To carry out our obligations to you as a result of any
contracts or agreements entered into between you and us (i.e.,
where necessary for the adequate performance of our contract
with you and/or to take steps requested by you prior to entering
into a contract with you);
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To carry out our legal obligations under applicable law;
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In connection with our legitimate interest in (1) providing you
with credit and/or other financial or technological products or
services, (2) operating our business, (3) marketing our products
and services to you and others and (4) administering our systems
and keeping our records up to date; and
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With your prior consent.
We use information that we collect about you or that you provide
to us, including any personal information on and/or through our
Website:
-
to present our Website and its contents to you;
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to carry out our obligations and enforce our rights arising
from any contracts entered into between you and us;
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to notify you about changes to our Website or any products or
services we offer or provide though it;
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in any other way we may describe when you provide the
information; and/or
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any other purpose with your consent.
We may make certain decisions in relation to our provision of our
products and services to you by using automated decision-making
processes, without human involvement, including:
-
Credit decisions – When you apply for credit, we use automated
processing to decide whether to lend to you and/or make other
decisions about your eligibility for our products and services,
based on the Information collected. This automated processing
enables us to provide rapid, responsive and tailored credit
services to customers who may not have credit histories, prior
bank or other financial data or income from formal sources. Our
credit and underwriting models utilize data science and
machine-learning technology to process your Information and
assess your creditworthiness. The associated processing of your
Information is automated and little to no human intervention is
involved. Using such automated processes to assess your
creditworthiness means we may automatically decide that you may
be ineligible for our services or ineligible for credit of a
particular amount or tenure. Our credit and underwriting models
are regularly tested to ensure they remain fair, accurate and
unbiased.
-
Detecting fraud – Mother Finance also utilizes automated
processes to detect, combat and prevent fraud. Our fraud models
may automatically decide that a certain individual poses a fraud
or money laundering risk (e.g., if our processing reveals
information or behaviour consistent with money laundering or
known fraudulent activity, if the activity is inconsistent with
prior activity on our platform or if an individual appears to be
hiding their true identity). If our fraud models determine that
processing of a transaction or approving a certain individual
creates a risk of fraud, that individual’s access may be
suspended or refused.
-
Your rights in relation to automated decision-making – If you
apply for a credit and your request is declined (or you are
informed that you are ineligible for other or associated
products or services) as a result of an automated credit,
underwriting or fraud decision, you may request that one of our
underwriters review this decision. You may do so by contacting
us at: bd@motherfinance.com.mm
/
pm@motherfinance.com.mm
or you may reach out to our customer service. You may also
object to the automated processing of your Information, but
doing so will prevent us from providing you with our
services.
Who do we share your Information with?
Mother Finance will not disclose any Information containing
personal data (as defined under applicable law) to any third
parties unless it is necessary and/or appropriate in order to
provide Mother Finance’s products or services (provided, that, we
may share limited personal data (as defined under applicable law)
with select partners for research and development). Whenever
practically feasible, Mother Finance will only share your
Information with third parties in an anonymized format.
You understand and agree that we may, as necessary and/or
appropriate for the purposes provided above, transfer and disclose
your information to:
-
a subsidiary, affiliate or parent company of Mother Finance
(collectively, the “Mother Group of Companies” or “Mother
Group”);
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employees, subcontractors, agents, service providers, or
associates of the Mother Group (including directors and
officers);
-
intermediary, correspondent and agent banks, non-banks,
quasi-banks or other financial institutions, clearing houses,
clearing or settlement systems, market counterparties, upstream
withholding agents, licensed electronic or mobile wallet
providers, remittance and transfer companies, credit reference
agencies or credit bureaus;
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service providers with contractual or fiduciary relationships
with Mother Finance (e.g., to facilitate transaction processing,
fraud prevention, cloud data storage or data transfer), which
may be located outside Myanmar;
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telecommunication companies (e.g., MPT, Telenor, Ooredoo,
Mytel);
-
external collection agencies (to assist in the collection of
any unpaid obligations to us);
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external counsel, external auditors, and consultants, when
necessary to resolve disputes or complaints;
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a party in connection with any merger, acquisition or sale of
all or substantially all of the assets of Mother Finance and/or
any company within the Mother Group;
-
a party in connection with any assignment of credit or the
creation of a security interest involving outstanding balances
owned to Mother Finance;
-
to other public or private third parties to the extent (1) we
have a duty to disclose or share your information in order to
comply with any legal obligation (e.g., Central Bank of Myanmar,
Myanmar Credit Bureau), (2) necessary or appropriate to enforce
or apply any agreement with you, and/or (3) necessary or
appropriate to protect the rights or safety of Mother Finance,
the Mother Group and/or our customers.
The above parties may also process or disclose your information
for the purposes set forth above, so long as such processing or
disclosure is in compliance with this Privacy Policy.
Further, Mother Finance may also share your information with law
enforcement or other government agencies in connection with a
formal request, subpoena, court order, or similar legal procedure,
or when we believe in good faith that disclosure is necessary to
comply with the law, prevent physical harm or financial loss, to
report suspected illegal activity, or to investigate violations of
our agreements with you.
Where does Mother Finance process, store or transfer your
Information?
Your Information will be stored or retained by Mother Finance and
its transferees only for so long as necessary for the purposes
listed in this Privacy Policy, and for a reasonable time
thereafter for the delivery of our products and completion of our
services. We are required to retain your Information for a period
of at least seven (7) years
in compliance with anti-money laundering and terrorism financing
prevention regulations, notwithstanding requests for deletion by
the Central Bank of Myanmar. We may also retain your Information
(i) for as long as necessary to comply with any legal obligation;
(ii) whenever such is authorized under the law; and (iii) for the
establishment of legal defences. Information that is no longer
needed for the purpose(s) for which it was collected shall be
deleted or anonymized except as necessary to comply with legal
obligations.
We have implemented reasonable and appropriate technical,
physical and organizational security measures designed to secure
your personal information from accidental loss and from
unauthorized access, use, alteration, and disclosure. All
information you provide to us is stored on our secure servers
behind firewalls. The safeguards we will use will depend on the
circumstances and the party to whom we transfer your Information.
Your Information may be processed by any of the parties described
above. Mother Finance will use all reasonable and appropriate
efforts as required by applicable law to protect your Information.
We use 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 pm@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 Website you can tell that you are actually on our
site and that all data entered into the Website 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. We
also conduct vulnerability scans of applications and systems
regularly. Access to the system is tightly controlled, monitored
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 centres 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 App 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.
Mother Finance sends important communications regarding your
account via email or SMS or notifications through our App. 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.
How you can access, change or delete your Information?
At all times, we maintain and uphold your rights as a data
subject, including:
-
Right to be informed – We must provide you with certain
information related to how we collect your Information, how we
use your Information (and our legal basis for doing so), who we
share your Information with, where we obtained your Information
and your rights as a data subject. This information is provided
within the App and in this Privacy Policy in clear
language.
-
Right to access – You may ask for a copy of the personal data
(as defined under applicable law) we hold concerning you (and
your Information related to such personal data), as well as
information on how such personal data has been processed, unless
providing some or all of it would adversely affect the rights
and freedoms of others or applicable law requires that we do not
comply with your request. The right to access does not apply to
analyses made by the Company with respect to your Information,
such as inferred, derived, modelled, or business-generated
data.
-
Right to rectification – You may ask us to correct any
Information which you believe to be inaccurate. We will promptly
update any such information. In connection with your request,
you may be required to provide supporting evidence or other
documentation so that we may verify the accuracy of the
request.
-
Right to erasure or blocking – Where the processing of your
personal data is based on your consent or our legitimate
interest, you may ask us to stop using your personal data (as
defined under applicable law. You may ask us to erase your
personal data (as defined under applicable law):
-
If you believe it’s no longer necessary for us to retain
such personal data;
-
If you do not believe we have legitimate ground for
processing it;
-
If you think we are using such personal data unlawfully;
and/or
-
If you think applicable law requires that we do so.
-
Right to restrict or object to processing – Where the
processing of your personal data is based on your consent or our
legitimate interest, you may ask us to stop using your personal
data (as defined under applicable law):
-
if you think such personal data is inaccurate;
-
if you think it’s illegal for us to use such personal
data;
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if you don’t want us to destroy such personal data because
you need it for legal proceedings;
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if you’ve informed us that we don’t have a legitimate
reason for using it and we’re considering your
request.
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Right to data portability – If we’re using your information on
the basis of your consent or because we need it to carry out our
contractual obligations to you, you can ask us to give you your
personal data (as defined under applicable law) in a structured,
commonly-used and machine-readable format or have it transmitted
to another data controller. The right to data portability is
limited to data that you provided actively and knowingly, or
that you provided by virtue of the use of our services.
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Right to damages – You have a right to be indemnified if you
suffered damages due to inaccurate, incomplete, outdated, false,
unlawfully obtained or unauthorized use of personal data,
considering any violation of your rights and freedoms as data
subject.
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Right to file a complaint – You have the right to file a
complaint with the relevant government agencies for any
violation of your rights as a data subject.
Operationally, you can access the personal information you have
provided to us by logging in and going to the “Settings” section
of your registered account of our App. 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. You
can request that all the data to be deleted at any time by
following through the account deletion process after logging into
your account in the mobile application.
You may also contact us to exercise your rights as a data subject
at bd@motherfinance.com.mm
in order to request access to, correct or delete any personal
information collected by, or provide to us and/or to exercise any
of your other data privacy rights. Please note that there may be
occasions when you wish to exercise your rights but we may not be
able to accommodate your request because we have compelling
legitimate ground for using or processing your information or
because we need to retain your information to comply with a legal
obligation or we have a good faith belief that the change would
violate any law or legal requirement.
Important Privacy Choices
You are not required to provide us with your Information or any
associated personal data (as defined under applicable law) and you
may withdraw your consent from the use or processing of such
Information or personal data. However, if you do so, we will be
unable to provide our current or future products and services to
you and we reserve the right to terminate our relationship with
you, as permitted under applicable law. Further, to the extent we
have a legitimate interest in retaining your Information and/or
associated personal data (as defined under applicable law), we may
do so. For example, if you have requested that we erase your
Information or associated personal data (as defined under
applicable law), but you have an outstanding balance with Mother
Finance, we may retain your Information or associated personal
data (as defined under applicable law), in order to continue
collection efforts. We are also required to retain your
Information for a period of at least seven (7) years in compliance
with anti-money laundering and terrorism financing prevention
regulations, notwithstanding requests for deletion.
By downloading the Mother Finance App and clicking “Accept” on
the permissions overview screen, you:
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accept the terms of this Privacy Policy;
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allow Mother Finance to access the device permissions more
fully described below;
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give Mother Finance consent to collect, use, share, or
otherwise process your Information, which may include personal
information, sensitive personal information or privileged
information (in each case, as defined under applicable law), as
outlined in this Privacy Policy;
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certify that all Information you have provided and will provide
to Mother Finance is true and correct to the best of your
knowledge;
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authorize Mother Finance to verify/investigate the accuracy of
your Information; and
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acknowledge that Mother Finance may be required to disclose
your Information to the Central Bank of Myanmar and the Myanmar
Credit Bureau, and/or any other governmental body, in compliance
with its legal obligations and in accordance with the principle
of proportionality.