Mother Finance

Mother Finance Company Limited’s Privacy Policy Notice

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

  • Identification data (e.g., name, date and place of birth, image capture);
  • 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);
  • Contact details (e.g., address, phone number, alternate phone number, email address);
  • Government-issued identification data and documents (e.g., National Registration Card, Passport, Driver’s License, Employee Identification Card);
  • 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);
  • Location data (e.g., mobile device location, time zone setting);
  • Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information);
  • 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;
  • 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);
  • 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
  • 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;
  • Prevent phone from sleeping – This permission is required by some of the features and services within the App, such as in-app messaging;
  • 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:

  • directly from you when you provide it to us by filling in forms on our Website;
  • records and copies of your correspondence (including email addresses), if you contact us;
  • your responses to surveys that we might ask you to complete for research purposes;
  • your search queries on the Website;
  • 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
  • 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;
  • store information about your preferences, allowing us to customize our Website according to your individual interests;
  • speed up your searches; and
  • 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:

  • 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.
  • 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);
  • To service your account with Mother Finance (including, but not limited to, processing disbursement of your funds and collecting repayment of your outstanding balance);
  • To verify your identity and/or other information you provided to us;
  • To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;
  • To analyse customer behaviour;
  • To administer our systems, maintain service quality and compile general usage statistics;
  • To analyse and improve our services;
  • To troubleshoot any problems that you or other customers encounter with Mother Finance’s services;
  • 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;
  • 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;
  • To provide service updates;
  • To provide staff training (where we may monitor or record customer interactions);
  • To interface with credit reference or fraud prevention agencies;
  • 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);
  • To carry out our legal obligations under applicable law;
  • 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
  • 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;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • to notify you about changes to our Website or any products or services we offer or provide though it;
  • in any other way we may describe when you provide the information; and/or
  • 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”);
  • 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;
  • 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;
  • telecommunication companies (e.g., MPT, Telenor, Ooredoo, Mytel);
  • external collection agencies (to assist in the collection of any unpaid obligations to us);
  • external counsel, external auditors, and consultants, when necessary to resolve disputes or complaints;
  • 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;
    • if you don’t want us to destroy such personal data because you need it for legal proceedings;
    • if you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.
  • 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.
  • 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.
  • 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:

  • accept the terms of this Privacy Policy;
  • allow Mother Finance to access the device permissions more fully described below;
  • 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;
  • certify that all Information you have provided and will provide to Mother Finance is true and correct to the best of your knowledge;
  • authorize Mother Finance to verify/investigate the accuracy of your Information; and
  • 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.