Privacy Policy

Effective Date: October 1, 2022

This Privacy Policy describes how the “Service Provider” (hereinafter referred to as “loanxpay.com” or “loanxpay.com” or “loanxpay.com App”) collects and uses the personal information you provide to the Service Provider through this website accessible at: https://loanxpay.com (the “Website”) or by other means. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. By accessing or using the Website or other service provided by the service provider, you signify that you have read this Privacy Policy, and you expressly consent to our collection, use, disclosure, storage, and protection of your personal information as described in this Privacy Policy.

We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalized term in the Definitions section.

1. What Personal Data Do We Collect?

We collect Personal Data about you when you visit our Sites or use our Services, including the following:

• Registration and user information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address, and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
• Transaction and experience information – When you use our Services or access our Sites, for example, to apply for a loan, to check loan approval status, to process repayments, or any other service provided, we collect information about such activities, as well as other information associated with the activities such as Device Information, Technical Usage Data , and Geolocation Information.
• Participant Personal Data – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.
  • Applying for a Loan: When you apply for a microloan through the Website or services, Personal Data such as name, postal address, telephone number, and financial account information about you and any other participants who you nominate as your references through the registration process to uniquely identify you, perform credit verification and to confirm with statutory requirements may be collected. The extent of Personal Data required about a participant may vary depending on the Services you are using. Except as noted in Section 5 below, Service Provider will not disclose your personally identifiable Loan Transaction information to any third party without your consent.

• Information about your public profile and your friends and contacts – It may be easier for us to help you transact with your friends and contacts if you choose to connect your contact list information with your Account or if your Account profile is publicly available. If you establish an account connection between your device or a social media platform and your Account, we will use your contact list information (such as name, address, email address) to improve your experience when you use the Services.
• Personal data that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Statement.
• Personal Data about you from third-party sources – We obtain information from third-party sources such as, data providers, and credit bureaus, where permitted by law.
• Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

2. Why Do We Retain Personal Data?

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal data in accordance with this Privacy Statement.

The cookies we use have defined expiration times; unless you visit our Sites or use our Services within that time, the cookies are automatically disabled and retained data is deleted. Please consult our Statement on Cookies and Tracking Technologies for more information.

3. How Do We Process Personal Data?

We may Process your Personal Data for a variety of reasons that are justified under data protection laws in Sri Lanka.

• To operate the Sites and provide the Services, including to:
  • apply for a loan or check loan status
  • authenticate your access to an Account
  • communicate with you about your Account, the Sites, the Services, or loanxpay.com
  • perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes,
  • keep your Account and financial information up to date.

• To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.
• To manage risk and protect the Sites, the Services, and you from fraud by verifying your identity. loanxpay.com’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data, and Geolocation Information from our websites and mobile apps that offer loanxpay.com Services to help detect and prevent fraud and abuse of the Services.
• To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.
• For our legitimate interests, including to:
  • enforce the terms of our Sites and Services;
  • manage our everyday business needs, such as monitoring, analyzing;
  • manage risk, fraud, and abuse of loanxpay.com Services;
  • anonymize Personal data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services; and
  • conduct business-to-business marketing; and
  • provide personalized Services (also called interest-based marketing) offered by loanxpay.com on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Statement to provide a targeted display, feature, or offer to you on third-party websites.
• With your consent, including to:
  • To market to you about loanxpay.com products and Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor the marketing content and certain Services or Site experiences to better match your interests on loanxpay.com and other third-party websites.
  • To use cookies and other tracking technologies to provide a targeted display, feature, Service or offer to you and/or to work with other third parties such as merchants, advertising or analytics companies to provide these personalized services (also called interest-based marketing).
  • To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalised (also called interest-based marketing) content.
  • To respond to your requests, for example to contact you about a question you submitted to our customer service team.

You can withdraw your consent at any time and free of charge. Please refer to the section on “Your Privacy Choices” for more information on how to do that.

4. Authorization for Usage of Third-Party Data

Notwithstanding anything to the contrary in this Privacy Policy or the Terms and Conditions of the website, you acknowledge, consent, and agree that:

• Where you use this Website or services for and on behalf on any other person, whether being a member of your family, your friend or employee, you have their full and informed consent and authorization for such use; and Where you provide any information of on any other person, such as your family, friends or employees, you have their full and informed consent and you are authorized by such person to provide such personal information when using the Website or services.
• We assume with your permission that you have obtained proper authorization from the owner/s of such personal information and have informed the said person/s of the terms and conditions of this Privacy Policy or the Terms of Use. You hereby represent and warrant that such person, whether being a member of your family, your friend, or an employee, has also read and understands this Privacy Policy or the Terms and Conditions of the website or other service.
• You further acknowledge, confirm, represent, and warrant that such person (1) on whose behalf you are using this Website or services or (2) whose personal information you have provided to us have agreed to the use, processing, storage and/or disclosure of their personal information in accordance with this Privacy Policy or the Terms and Conditions of the website, and all applicable laws.

You acknowledge, consent and agree that Service Provider, its employees, or agents shall not be held liable for the collection, use, storage, processing, and disclosure of all such personal information provided by you under this paragraph.

5. Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement. We may share your Personal Data or other information for the following reasons:

• With other members of the Service Provider’s corporate family: We may share your Personal Data with members of the Service Provider’s family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Service Provider’s products, Services, and communications.
• With other companies that provide services via our platforms and to us: We share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.
• With other financial institutions: We share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer loanxpay.com-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.
• With the other parties, such as affiliates, agents and representatives, payment processing services, and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes affiliates, agents and representatives and non-financial institutions who might process your applications or repayments. The information might include:
  • Personal Data and Account information necessary to facilitate the transaction;
  • Personal Data to help other participant(s) resolve disputes and detect and prevent fraud;
• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for loanxpay.com’s business purposes or as permitted or required by law, including:
  • if we need to comply with a law, legal process or regulations;
  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to loanxpay.com or Service Provider’s corporate family;
  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • to protect the vital interests of a person;
  • with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
  • to protect our property, Services and legal rights;
  • to facilitate a purchase or sale of all or part of loanxpay.com’s business;
  • to help assess and manage risk and prevent fraud against us, and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals
  • to banking partners as required by card association rules for inclusion on their list of terminated merchants;
  • to credit reporting and collection agencies;
  • to companies that we plan to merge with or be acquired by; and
  • to support our audit, compliance, and corporate governance functions.
• With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.

In addition, loanxpay.com may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. No sale of personal information

Service Provider will not rent or sell your personal information to third parties.

7. How Do We Work with Other Services and Platforms?

A significant benefit and innovation of loanxpay.com’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection you authorise or enable between your Account and a non-loanxpay.com account, payment instrument, or platform that you lawfully control or own. When you authorise such a connection, loanxpay.com and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

• linking your Account to a social media account or social messaging service; or
• connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials;

If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that you authorised to have an account connection that will gain access to your Personal Data as part of the account connection. For example, Personal Data that loanxpay.com shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

8. Information from cookies and web beacons

Cookies are small text files created by a website that store information on your computer, such as your preferences when visiting that website. Similar to many websites, if you have enabled cookies in your browser, Service Provider, independently and through enabled third party tools and programs, collects certain technical information using cookies, such as the path of users to the Website, pages visited, originating IP address, browser type, browser language and the date and time of the user’s visit. This information helps Service Provider track trends and improve areas of the Website and Program, and are common analytics used by most websites. If you have disabled cookies, the Website may not work as it is intended because the Service Provider uses cookies when you sign in to keep track of your personal session.

Web beacons are tiny graphics with a unique identifier that are similar in function to cookies but, instead of being stored on your computer, are embedded invisibly on web pages and are about the size of the period at the end of this sentence. Web beacons are used to track the online movements of internet users. Service Provider uses them to better understand User interaction and engagement with the Website (including without limitation, in electronic Communications), such as by learning whether certain users have accessed the Website via links from other websites. Service Provider can use this information to tailor its audience for advertisements promoting Service Provider. You may set your browser preferences to opt out of the collection and use of this tracking information for ad targeting purposes.

Service Provider also uses cookies for remarketing, by placing a cookie in your browser to signal that you’ve visited the Website. This gives us the option to show you ads for Service Provider when you visit other websites that host advertisements. Service Provider supports the Do Not Track preference available on most internet browsers. The use of cookies by third parties on the Website is for the purpose of making the Website easier to use and to enable certain features of the Website and is not covered by this Privacy Policy. We do not have control over these cookies.

9. Electronic communications

From time to time you will receive disclosures, notices, documents and information based on your current loan status (“Communications”) from Service Provider (for example, confirmations of Loans obtained by you, confirmation of email address or password changes, or customer service inquiries regarding the status of or activity). By creating an account with Service Provider on the Website or other service, you agree that all Communications from Service Provider relating to your use of the Website or service and participation in the Program may be provided or made available to you electronically by mobile SMS, by e-mail or at the Website.

By registering on the Website or other service, you acknowledge that you can access the electronic Communications, and you consent to having all Communications provided or made available to you in electronic form and to obtain a loan utilizing the online service provided by Service Provider. We may also provide you with Communications through physical mail.

Assuring the privacy of all the contact details you have provided us while completing the loan application, with due approval from the users we will use them as modes of promoting our marketing campaigns. Nevertheless, these users will have the option to approve and disapprove the request.

10. What Privacy Choices Are Available To You?

You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

• Choices Relating to the Personal Data We Collect
  • Personal Data. You may decline to provide Personal Data when it is requested by loanxpay.com, but certain Services or all of the Services may be unavailable to you.
  • Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that loanxpay.com may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
• Choices Relating to Our Use of Your Personal Data
  • Online Tracking and Interest-Based Marketing. We work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party websites.
• Choices Relating to Account Connections
  • If you authorise an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.
• Choices Relating to Cookies
  • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.
  • You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
  • You can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page.
• Choices Relating to Your Registration and Account Information
  • If you have an Account, you may only be able to edit Personal Data by contacting us. contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.
• Choices Relating to Communication
  • Notices, Alerts and Updates from Us:
    • Marketing: We may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the Service Provider’s corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. For messages sent via push notifications, you may manage your preferences on your device. If you have any concerns regarding the marketing communications you receive from us, please contact us.
    • Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

11. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.

12. Can Children Use Our Services?

The Sites and Services are not directed to children under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

13. Links to other websites

If you follow any links which remove you from the Website or other service (for example, the independently operated Facebook, Twitter, Blogger, WordPress, Salesforce and any other websites), this Privacy Policy no longer applies – i.e., the privacy policies and practices of other websites and other parties are governed by their respective terms of use and privacy policies.

14. Security

Service Provider takes reasonable steps to maintain appropriate physical, technical information such as encrypting transmission of information using SSL and administrative security to help prevent loss, misuse and unauthorized access, disclosure and modification of personal information. While we take these reasonable efforts to safeguard your personal information, no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

15. Modifications; Interpretation

Service Provider may update or modify this Privacy Policy from time to time. If any changes are made, the Service Provider will reflect the date on which any such changes are made and posted by updating the “last updated” date at the top of the page. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. Please be sure to check this page periodically for changes.

16. Definitions

• Account means a loanxpay.com member account.
• Device Information means data that can be automatically collected from any device used to access the Site or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data.
• Geolocation Information means information that identifies, with reasonable specificity, your location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.
• loanxpay.com means the online platform operated by the Service Provider in Sri Lanka that connects borrowers and lenders and provides certain lending facilitation, management and other services. In this Privacy Statement, loanxpay.com is sometimes referred to as “we,” “us,” or “our,” depending on the context.
• Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. “Personal Data” can include, but is not limited to, name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport number).
• Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
• Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by the service provider.
• Sites means the websites, mobile apps, official social media platforms, or other online properties through which loanxpay.com offers the Services and which has posted or linked to this Privacy Statement.
• Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
• User means an individual who uses the Services or accesses the Sites.

17. Requests & Complaints

If you believe that any of your personal data may have been misused or abused or otherwise compromised, or if you wish to withdraw your consent for processing of your personal data, you may lodge your inquiries and complaints to the Service Provider in accordance with the contact details as outlined below and discuss such matter, together with your contact details for reference. All such complaints will be resolved within 30 (Thirty) calendar days.

Filing such complaints shall not affect the lawfulness of any processing carried out before you withdraw your consent.

For Complaints please e-mail – help@loanxpay.com