Sincere Loan Privacy Policy

Welcome to the Sincere Loan mobile application (hereinafter referred to as "the App" or "we"). We fully understand the importance of your personal information and are always committed to protecting your privacy. This Privacy Policy is intended to clearly explain how we collect, use, store, share, and protect your personal information, as well as the rights you enjoy as a data subject.

【Special Notice】Before applying for credit or making a withdrawal using Sincere Loan, please be sure to read and fully understand this Policy. Once you check "Agree" or continue to use our services, it means that you are clearly aware of and agree to all contents of this Policy.

I. How We Collect and Use Your Personal Information

In order to provide you with core services such as credit assessment, credit limit generation, and revolving withdrawals, we will collect the following information while you use the App, based on the principles of "legality, legitimacy, and necessity":

1.Basic identity and contact information: Your full name, Thai national ID Card information and photo, date of birth, gender, residential address, mobile phone number, and e-mail address. This is used to verify your true identity, determine application eligibility, and fulfill Anti-Money Laundering (AML) legal obligations.

2.Employment and income information: Your occupation, employer name, proof of monthly income, bank statements, or bank card information. This is used to assess your repayment ability and calculate your maximum approved limit.

3.Device and log information: Your device model, operating system version, unique device identifiers (such as IMEI/UUID), IP address, and app crash logs. This is used for risk control and anti-fraud, identification of malicious multi-account fraud, and system security.

4.SMS information: With your explicit authorization, we collect SMS data on your device, but only monitor finance-related SMS messages (including sender name, transaction description, and amount). This is used to confirm your risk level and credit limit, help prevent fraud, and verify the security of your account via SMS.

4.Location information: With your explicit authorization, we collect location-related information about your device (such as location method, location time, longitude, latitude, location, and location area code). This is used to confirm your credit rating, enhance the security of your account through location information, and immediately notify you upon detection of any anomaly.

5.App list information: With your explicit authorization, we collect the list of apps installed on your device for review purposes. We use it for review only, and we will keep your data secure.

II. Core Product Logic and Specific Data Processing Rules

Sincere Loan features a unique revolving credit mechanism, with data processing rules as follows:

1.One-time credit approval, revolving assessment: The App provides one-time credit approval. Within the credit limit approved by the Platform, you are entitled to make multiple withdrawals. After you repay on time, the limit will be automatically restored, and subsequent withdrawals within the limit do not require re-submission of the initial loan application.

2.Continuous risk control during the silent period: To deliver the convenient experience of "automatic limit restoration after repayment, with no need to re-apply," during the silent period after you have been granted credit but before you actually make a withdrawal, we will still, within the scope permitted by laws and regulations, conduct minimal ongoing maintenance and dynamic risk monitoring of your credit data and account security status in the background.

3.No charges before withdrawal: We solemnly promise that after you have been granted a credit limit, before you actually initiate a withdrawal instruction and before the funds arrive in your designated bank account, we will never charge any interest or management fees. During this period, our processing of your financial data is limited to maintaining the security of the limit and will not trigger any billing- or collection-related data processing procedures.

III. App Permission Access and Data Collection Statement

To ensure transparency regarding the information collection described above, we hereby itemize the sensitive permissions that the App may invoke during operation and their collection rules. All permissions follow the principle of "minimum necessity," are triggered only in the corresponding functional scenarios, and may be enabled or disabled by you at any time in the system settings:

1.Location permission: We need your device's location authorization to collect location information, including location-related information such as your device's location method, location time, longitude, latitude, location, and location area code. This information will be used to confirm your credit rating and enhance the security of your account through location information. Once an anomaly is detected, we will notify you immediately.

2.Phone (device) permission: This permits the collection and monitoring of specific information about your device, including your device's name, model, region and language settings, device identification code, hardware and software information, status, usage habits, IMEI and serial number, and other unique device identifiers, in order to uniquely identify the device, ensure that unauthorized devices cannot act on your behalf, and prevent any form of fraud.

3.SMS: We collect all SMS data but only monitor finance-related SMS messages, including sender name, transaction description, and amount, in order to confirm your risk level and credit limit and to help prevent fraud. In addition, we require you to send an SMS message to determine the security of your account.

3.App list permission: Sincere Loan needs to access the list of apps installed on your device for review purposes. We use it for review only, and we will keep your data secure.

4.Other basic permissions: Permissions such as camera (taking ID card photos) and storage (caching necessary data) are invoked only when the corresponding functions are used, and are not used for any purpose beyond the scope described in this Policy.

5.Permission management: All of the above permissions are managed by the system's authorization management. You may view and withdraw authorizations at any time in your device's "Settings — App Management — Sincere Loan — Permission Management." Withdrawing SMS, device, location, or app list authorization will not render the basic functions of the App unusable, but may affect the integrity of credit assessment and revolving withdrawal services.

6.No-forced-collection commitment: The App will not collect SMS, device information, location data, or app list data beyond the purposes and scope stated in this Policy; will not use the above data for any purpose not stated in this Policy; and, except where required by law or under the sharing circumstances disclosed in this Policy, will not provide the above data to any third party.

IV. How We Share, Transfer, and Publicly Disclose Your Personal Information

1.Sharing: We will not share your personal information with any company, organization, or individual outside this App, unless we obtain your explicit consent or under the following statutory circumstances: cooperation with the lawful and compliant review of judicial authorities or government regulators (such as the Bank of Thailand and the Anti-Money Laundering Office).

○ Verifying your credit status with lawful third-party financial institutions and credit bureaus.

2.Transfer and public disclosure: We will not transfer your personal information to any third party or publicly disclose it, except for the realization of debt assignment (e.g., lawful debt recovery in the event of serious overdue payment by a user) or with your separate explicit authorization.

V. Storage and Cross-Border Transfer of Personal Information

1.Storage period: We retain your personal information only for the shortest period necessary to provide you with services, or within the statutory retention period stipulated by relevant Thai laws (such as the Anti-Money Laundering Act and the Accounting Act).

2.Cross-border transfer: Given that some of our technical servers or affiliated service teams may be located overseas, your personal information may be transferred outside Thailand for secure storage or processing. We will strictly apply technical measures such as encryption and de-identification to ensure that the overseas data recipient has data protection capabilities no lower than those required by Thailand's Personal Data Protection Act (PDPA).

VI. Data Security Measures

We adopt security technologies and management systems that meet financial-industry standards to protect your data:

1.SSL/TLS encryption technology is used to secure data transmission between the client and the server.

2.Sensitive personal information such as your ID card information and bank account details is stored in de-identified or encrypted form.

3.Internal staff data access privileges are strictly limited, and security audits are conducted regularly.

VII. Your Rights as a Data Subject (Under Thai PDPA Law)

Under Thailand's Personal Data Protection Act (PDPA), you have the following lawful rights with respect to your personal information:

1.Right to be informed and right of access: You have the right to inquire about and access a copy of the personal information we hold about you.

2.Right to rectification: If you find that your personal information is inaccurate or has changed, you have the right to correct it within the App or by contacting customer service.

3.Right to withdraw consent: You have the right to withdraw the authorization you previously gave us for data collection. (Please note: withdrawing certain consents required for core credit approval may prevent you from continuing to use the revolving withdrawal service.)

4.Right to erasure: Upon completion of the service contract, expiration of the statutory period, and where no outstanding debts are involved, you have the right to request that we delete or destroy your personal information.

VIII. Protection of Minors' Privacy

Our services are available only to Thai citizens who are at least 20 years of age and have full civil capacity. We do not intentionally collect any personal information from minors under 20 years of age. If we discover that a minor has registered an account without the consent of a guardian, we will immediately cancel that account and delete the related data.

IX. Updates to This Privacy Policy

We may revise this Privacy Policy from time to time in response to product feature adjustments or changes in Thai laws and regulations. When material changes are made to this Policy, we will present the updated terms to you within the App by means of pop-ups, announcements, or other methods.

X. How to Contact Us

If you have any questions, comments, or complaints regarding this Privacy Policy or the security of your personal information, or if you wish to exercise your rights as a data subject under the PDPA, please contact our Data Protection Officer (DPO) through the following official channels:

●Developer/Company name: PT DIVANA TIRTA INTERNUSA

●Customer service e-mail: builder@renovasikutech.com

●Customer service hotline: +6285196509880

●Office address: Graha Induk KUD 1st Floor, Jl. Warung Buncit Raya No. 20, Kota Administrasi Jakarta Selatan - 12510