Privacy Policy

1. Introduction

We are committed to protecting the privacy and security of your personal information. This Privacy Policy details how we collect, receive, store, integrate, process, use, and disclose user information during your use of Hợp Tín. Hợp Tín is exclusively operated and owned by EBC FINANCIAL GROUP (COMOROS) LIMITED (hereinafter referred to as "we" or "the Company"). We are committed to providing users with convenient and secure credit services, while placing particular emphasis on protecting user privacy and strictly complying with relevant Vietnamese laws and regulations.

2. Information Collection and Scope of Application

2.1 Permission Information

• 1. Camera Permission: The application needs access to your camera, primarily for taking and uploading necessary authentication documents (such as ID photos). Images are securely transmitted via an encrypted connection. This permission is solely for authentication purposes.
• 2. Location Permission: Collects approximate location information for security checks and fraud prevention. Data is encrypted and uploaded to https://integrate.myhoptin.com/.
• 3. App List: Collects a list of installed apps on the device for credit risk assessment. Data is encrypted and uploaded to https://integrate.myhoptin.com/.
• 4. Device Information and Ad ID: Collects ADID (Advertising Identifier), device model, system version, and other device information. Purpose: to improve service quality and analyze usage behavior. It is not associated with personally identifiable information. Data is encrypted and uploaded to https://integrate.myhoptin.com/.
• 5. Contacts Permission: Collects emergency contact information (name, relationship, phone number). This is solely for security and risk control purposes. The application will not proactively contact emergency contacts. Data is encrypted and uploaded to https://integrate.myhoptin.com/.

2.2 User-Provided Personal Information

Registration and Verification Information:
Identity Information: Name, Gender, Date of Birth, ID Card Number, Facial Recognition, Document Information, Address, and Other Information
Credit Information:
Bank Information and Other Personal Information

3. Data Collection Methods

3.1 Information Actively Provided by Users

Through processes such as registration, login, loan application, and repayment operations

3.2 Automatically Collected Information

Service usage information and behavioral data
Interaction information
Network connection information

4. Use of User Information

Providing and optimizing credit services
Assessing and managing risks
Customer support and service communication
Product research and development
Legal and regulatory compliance requirements

5. User Information Sharing

5.1 Internal Sharing

Information exchange between group companies

5.2 Third-Party Sharing

Payment service partners
Analysis service providers (Appsflyer, Firebase)
SMS service providers
Government and judicial authorities (as required by law)

6. User Rights

Right to access and modify personal information
Right to request deletion of personal data
Right to withdraw consent
Right to file complaints and resolve disputes

7. Personal Data Storage and Protection

7.1 Security Measures

Data transmission is encrypted via TLS protocol
Sensitive data is stored with static encryption
Strict access control
Real-time security monitoring
Regular data backup

7.2 Storage Period

Complies with Vietnamese law
Based on informed purpose and needs
Automatic deletion when no longer needed

8. Right to Erasure of Personal Data

8.1 Application Method

Through the app: "Settings" → "Cancel Account"
Through the official website
Through email and customer service hotline

8.2 Processing Flow
Verify user identity
Processing within 3 business days
Notify user of processing results

9. Child Privacy Protection

We do not provide services to minors under the age of 18. If we discover that a child has provided information, we will immediately delete the relevant information.

10. Privacy Policy Changes

We reserve the right to modify this policy. Continued use of the service after the policy changes constitutes acceptance of the new content.

11. Applicable Law and Dispute Resolution

This policy is governed by Vietnamese law. Disputes shall first be resolved through negotiation; if negotiation fails, they shall be resolved by a court with jurisdiction in Vietnam.

12. Contact Us

Company Name: EBC Financial Group (COMOROS) Limited
Company Address: 13th Floor, FinTech Building, Tan Binh District, Ho Chi Minh City
Customer Service Email: service@myhoptin.com
Working Hours: Monday to Friday 08:00-17:00 (excluding public holidays)