Privacy Policy

Welcome to the AAF Gold Loan App ("App"), operated by Asia Asset Finance PLC ("AAF", "we", "us", or "our").

AAF respects your privacy and is committed to protecting the personal information entrusted to us when you use the AAF Gold Loan App.

This Privacy Policy explains how we collect, use, process, store, disclose, and protect your personal information when you use the App and related services.

By using the App, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein, subject to applicable laws and regulations.

This Privacy Policy applies to information collected through:

• The AAF Gold Loan mobile application.
• AAF's related digital services.
• Gold loan applications submitted through the App.
• Communications between customers and AAF relating to the App or gold loan services.
• Supporting systems and services connected to the App.

This Privacy Policy does not necessarily apply to third-party websites, applications, or services that may be accessed through links within the App. Such third parties may have their own privacy policies.

Depending on how you use the App, we may collect the following categories of information.

Personal Information

We may collect:

• Full name
• National Identity Card (NIC) number or other identification number
• Date of birth
• Gender, where required
• Residential address
• Email address
• Mobile telephone number
• Customer identification information
• Customer account information

Gold Loan Information

When you submit a gold loan application, we may collect:

• Requested loan amount
• Gold weight in grams
• Gold purity/carat
• Gold type
• Jewellery type
• Jewellery description
• Estimated gold value
• Loan-to-value information
• Proposed repayment amount
• Selected installment plan
• Loan application status
• Unique gold transaction reference number

Jewellery and Jeweller Information

Where applicable, the App may collect:

• Jewellery shop name
• Jewellery shop address
• Jewellery shop location
• Jeweller registration or reference information
• Jeweller grade/tier
• Jewellery photographs
• Gold item photographs
• Valuation-related information
• Transaction details associated with the jewellery

Identification and Supporting Documents

To facilitate customer verification and loan processing, we may collect documents such as:

• NIC or other identification documents
• Proof of address
• Customer photographs
• Supporting loan documents
• Jewellery-related documents
• Valuation documents
• Other information reasonably required for processing the loan application

Location Information

With your permission, the App may collect location information for purposes such as:

• Identifying the location of a jewellery shop.
• Verifying jewellery shop information.
• Supporting branch or field operations.
• Improving the accuracy of location-related information associated with a transaction.

The App will request the relevant device permission where location access is required.

Device and Technical Information

We may automatically collect limited technical information, including:

• Device model
• Operating system and version
• App version
• Unique device or installation identifiers
• IP address
• Network information
• Log information
• Error and crash information
• Security-related information

This information may be used to maintain the security, stability, and performance of the App.

AAF may use your information for the following purposes:

Gold Loan Processing

• Register and identify customers.
• Process gold loan applications.
• Verify customer information.
• Assess loan eligibility.
• Evaluate gold and jewellery information.
• Facilitate loan approval workflows.
• Generate loan and transaction references.
• Manage approved transactions.

Customer Communication

We may use your contact information to:

• Send application status notifications.
• Send OTPs and authentication messages.
• Send transaction confirmations.
• Provide loan-related notifications.
• Respond to customer enquiries.
• Communicate important service information.

Security and Fraud Prevention

Information may be used to:

• Detect suspicious activities.
• Prevent fraud and unauthorized transactions.
• Verify customer identity.
• Protect customer accounts.
• Protect AAF systems and infrastructure.

Operational Purposes

We may use information for:

• Customer service.
• Internal administration.
• Transaction reconciliation.
• Reporting.
• System monitoring.
• Service improvement.
• Troubleshooting.

Legal and Regulatory Requirements

AAF may process and retain information where necessary to:

• Comply with applicable laws and regulations.
• Meet regulatory obligations.
• Respond to lawful requests from regulatory or governmental authorities.
• Maintain appropriate records.
• Support audits and investigations.

Information submitted through the App may be reviewed and processed by AAF's authorized personnel for the purpose of assessing and approving gold loan applications.

The information may include customer identification details, financial information, gold characteristics, jewellery information, transaction history, and other information required under AAF's lending policies.

The submission of an application does not guarantee loan approval.

AAF may approve, reject, request additional information, or refer an application for further review based on applicable eligibility criteria and internal policies.

AAF will not sell your personal information to third parties.

We may disclose or provide access to personal information where reasonably necessary for the purposes described in this Privacy Policy.

This may include:

Authorized AAF Personnel

Relevant employees and authorized personnel may access information necessary to process and manage gold loan applications.

Service Providers

AAF may use trusted third-party service providers for services such as:

• Cloud hosting
• Application hosting
• SMS and OTP delivery
• Email services
• Maps and location services
• Identity verification
• Payment processing
• Technology support
• Application monitoring
• Security services

Such service providers may process information only for the purposes for which they have been engaged and subject to appropriate contractual and security requirements.

Regulatory and Government Authorities

Information may be disclosed where required or permitted by applicable law, regulation, court order, or lawful governmental request.

Professional Advisors

Information may be disclosed where reasonably necessary to auditors, legal advisors, consultants, or other professional advisors, subject to appropriate confidentiality obligations.

The App may use third-party technologies and services to provide certain functionality.

Depending on the final implementation, these may include:

• Google Maps and related location services
• Firebase services
• SMS/OTP providers
• Cloud infrastructure providers
• Analytics or application monitoring services
• Security and fraud-prevention services

Third-party services may process certain technical or personal information in accordance with their applicable terms and privacy policies.

AAF will configure and use such services in accordance with applicable privacy and security requirements.

The App may request access to your device location when location functionality is required.

For example, location information may be used to identify or record the location of a jewellery shop.

You can control location permissions through your device settings. However, disabling location access may prevent certain features of the App from functioning correctly.

The App may request access to your device camera to allow you to capture:

• Customer photographs.
• Identification documents.
• Jewellery photographs.
• Supporting documents.
• Other information required for the gold loan application.

Camera access will only be used for purposes associated with the relevant App functionality.

AAF takes reasonable technical and organizational measures to protect personal information against:

• Unauthorized access.
• Unauthorized disclosure.
• Loss.
• Misuse.
• Alteration.
• Destruction.

Security measures may include:

• Encryption of data in transit.
• Encryption of sensitive information where appropriate.
• Secure authentication.
• Role-based access controls.
• Access logging and monitoring.
• Secure API communication.
• System monitoring.
• Backup and recovery mechanisms.
• Security testing and vulnerability management.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

AAF will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:

• Processing and managing gold loan applications.
• Managing customer relationships.
• Meeting legal and regulatory requirements.
• Maintaining financial and transaction records.
• Resolving disputes.
• Preventing fraud.
• Supporting audits and investigations.

Certain information may therefore need to be retained for a specified period even after a customer stops using the App or requests account deletion where applicable.

When personal information is no longer required, AAF will take reasonable steps to securely delete, anonymize, or otherwise dispose of the information in accordance with applicable requirements.

Where the App provides customer account creation, customers may request deletion of their account and associated personal information through the mechanism provided within the App or by contacting AAF using the contact details provided below.

Account deletion requests may be subject to verification.

Please note that certain information may need to be retained where required by law, regulation, accounting requirements, fraud prevention requirements, contractual obligations, or legitimate legal purposes.

Where information is required to be retained, AAF will continue to protect it in accordance with applicable privacy and security requirements.

Subject to applicable laws and regulations, you may have rights relating to your personal information, including rights to:

• Request access to personal information held about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal information where legally permitted.
• Request information regarding how your personal information is processed.
• Withdraw consent where processing is based on consent, subject to applicable limitations.
• Raise concerns regarding the handling of your personal information.

Requests may be subject to identity verification and applicable legal or regulatory requirements.

Where AAF relies on your consent to collect or process personal information, you may withdraw that consent by contacting AAF or using the relevant functionality provided within the App.

Withdrawal of consent may affect AAF's ability to provide certain services or process certain applications where the information is necessary for those services.

Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

The AAF Gold Loan App is intended for individuals who are legally eligible to use the financial services provided by AAF.

The App is not intended for children.

AAF does not knowingly collect personal information from children where such collection is prohibited by applicable law.

The App and related online services may use cookies, SDKs, log files, device identifiers, or similar technologies where necessary to:

• Maintain application functionality.
• Improve security.
• Monitor application performance.
• Identify errors.
• Understand service usage.
• Improve the user experience.

Where required, AAF will obtain appropriate consent for technologies that require consent under applicable law.

AAF may update this Privacy Policy from time to time to reflect:

• Changes to the App.
• Changes to our services.
• Changes to applicable laws or regulations.
• Changes to technology or security practices.

When material changes are made, AAF may notify users through the App, website, email, or other appropriate communication channels.

The updated Privacy Policy will include a revised "Last Updated" date.

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy or your personal information, please contact:

This Privacy Policy shall be interpreted and applied in accordance with the applicable laws and regulations of Sri Lanka.

Nothing in this Privacy Policy limits any rights available to individuals under applicable data protection, privacy, consumer protection, financial services, or other applicable legislation.

By using the AAF Gold Loan App, you acknowledge that you have read and understood this Privacy Policy and that your personal information may be processed in accordance with this Privacy Policy and applicable law.