Privacy Policy

1. Who we are

Tapat ("we", "us") is a money lender operating in Hong Kong under the Money Lenders Ordinance (Cap. 163), supervised by the Companies Registry (Money Lender's Licence No. XXX/2026). This policy explains how we handle personal data in connection with loan applications and loan accounts, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

2. What we collect

When you apply for a loan we collect:

• Identity data: your name, Hong Kong Identity Card details (including date of first registration and condition symbols), date of birth, a liveness selfie for identity verification, and where you choose to provide it, passport details.
• Contact data: mobile number (verified by SMS one-time password) and email address.
• Employment data: your Standard Employment Contract (ID 407), including your employer's name and address, contract salary and contract dates.
• Financial data: your stated monthly salary, e-wallet or bank transaction statements you upload (for example an AlipayHK transaction statement), your existing loan obligations, and your bank account details for disbursement and repayment.
• Optional identifiers: Philippine identifiers you choose to provide (SSS, Pag-IBIG, PhilID, TIN).
• Account data: your repayment history with us and communications with our support team.

3. Why we collect it

• Verifying your identity and preventing fraud and money laundering.
• Assessing your loan application, including the affordability assessment required of licensed money lenders under our licensing conditions.
• Setting up disbursement and collecting repayments (including Faster Payment System transfers and direct debit mandates).
• Servicing your loan: statements, repayment tracking, settlement quotations, and support.
• Complying with legal and regulatory obligations, including record-keeping required by our licensing conditions and responding to lawful requests from regulators and law enforcement.

We do not use your data for marketing by third parties, and we do not sell your data.

4. Who we share it with

• Identity verification (eKYC) providers who verify your HKID and selfie on our behalf.
• Payment providers and banks to disburse your loan and collect repayments.
• Credit reference agencies, where and when applicable under the Credit Data Smart regime, to report and check credit data as required of money lenders serving borrowers in your income band.
• Professional advisers and regulators where required by law.

We never contact, and never share your data with, your family, friends, employer or anyone in your home country in connection with your loan. We do not collect referee information; the law prohibits it and we would not do it regardless.

5. Security

Documents and personal data are encrypted in transit and at rest. Access is limited to staff who need it to assess or service your loan. We log access to application files.

6. Retention

We keep loan application and loan account records for as long as our licensing conditions and other applicable laws require, and delete or anonymise them when they are no longer needed for those purposes. Records of applications that are declined or not proceeded with are kept only as long as regulatory record-keeping requirements demand.

7. Your rights

Under the PDPO you may request access to your personal data and correction of inaccurate data. You may also ask us what data we hold about you and how we use it. Contact us through the channels below; we respond within the timeframes set by the PDPO. You may complain to the Office of the Privacy Commissioner for Personal Data (pcpd.org.hk) if you are not satisfied with our handling of your data.

8. Transfers outside Hong Kong

Your data is stored in Hong Kong or in jurisdictions providing comparable protection by our infrastructure providers. Where a service provider processes data outside Hong Kong, we require contractual safeguards.

9. Changes

We will post changes to this policy on this page with an updated date. Material changes affecting existing borrowers will be notified directly.

10. Contact and complaints

Questions, data access or correction requests, and complaints: call our complaints hotline at +852 XXXX XXXX or message us at m.me/TapatPay. Complaints about our conduct as a money lender may also be made to the Companies Registry, the regulator of money lenders in Hong Kong.