The website www.bennefin.com is owned and operated by Benne Fin BSC Closed (we, us, or our). We are a company incorporated in the Kingdom of Bahrain (Bahrain) and is regulated by the Central Bank of Bahrain (CBB).

In accordance with this Cookie, Privacy and Security Policy (Policy) and Terms of Service, we will process personal data. The data applies to which we collect from users, customers, and visitors of the Site and the Platform (you or your). It may also include the data that you provide to us and will be processed by us. This privacy statement is applicable to our website, as well as any associated mobile applications and subdomains (collectively, the Site).

By continuing to use this Site, you confirm that you have read, understood and agree to be compliant with this Policy and that you grand us your consent to collect and process your personal information as set out in this Policy. If you do not accept the terms of this Policy, then you must halt using or accessing this Site.

1.0 Who are we
BenneFin (Benne Fin BSC Closed and its and their parents, subsidiaries, affiliates, representatives, employees, agents, consultants, and directors—collectively, called BenneFin, we or us) is Peer to Peer Debt crowd funding platform for funding SMEs registered in Kingdom of Bahrain.

2.0 Information Collection
In order for you to create an account on BenneFin and use our Services, we need to collect and process certain information. We will collect personal information about you via a number of different means including:

• when you visit and/or use the Site
• while you submit it to us in writing, by email, phone or any other means or when you interact with us
• during transactions on the Site or in connection with the services provided to you or requested by you in writing, by email, phone or any other means or when you interact with us
• Credit reference companies and other third-party organizations, who may verify the data by cross-referencing it with other public and private databases, fraud prevention organizations, and/or publicly accessible sources.

We will collect personal information about you including:

• Personal details such as but not limited to name, job, Identity document details, contact information, and address details, transactions details and bank account details.
• Technical information relating to your use of the Site
• From Credit reference agencies on the company and the key stakeholders.
• In case, you submit an application on our platform or give us information about someone else, you confirm that you have informed that person of the purposes (as mentioned above) for which their information will be used and they have consented to the use of their information for these purposes.
• We might also gather anonymous information about Site users

By providing us with any personal information, you are agreeing to the use of your personal information as described in this Policy. If you do not want us to use your personal information for any of these purposes, please do not provide us with your personal information

3.0 Using the information

1. AML/KYC/On Boarding on the platform and as a user: to fulfil our regulatory compliance duties, such as ‘Know Your Client’ documentation; to confirm and verify the party’s identity (including through the use of credit reference agencies); to adhere to our internal compliance policies and procedures.
2. Credit decisions: analyzing trends in criteria and decision-making, doing financial due diligence and evaluating credit worthiness.
3. Products and services- communication, marketing, delivery: to managing relationships and related services; communicating with the party in relation to our services via any means (including via email, telephone, text message, social media, post or in person); to administer and protect our business and website including troubleshooting data analysis and system testing; to deliver content and advertising to party; to measure and analyze the effectiveness of the advertising we serve; to monitor trends so that we can improve the site; operation and management of our website; providing content; displaying advertising and other information.
4. Operations: management of our communications systems; operation of IT security; IT security audits: to facilitate Sales, Finance, corporate audit and vendor management
5. Research and Investigation: conducting market or customer satisfaction research and gathering feedback for the purposes of obtaining inputs on our products and services; Detecting, identifying and preventing breaches of policy, and criminal violations, in accordance with applicable law.
6. Legal and Regulatory compliance and proceedings: Compliance with our legal and regulatory obligations under applicable law and establishing, exercising and defending legal rights.

4.0 Disclosure and Transfer of Information
We may disclose Personal Data for legitimate business purposes (including providing services to the party), in accordance with the PDPL. In addition, we may disclose party’s Personal Data to:

• the party and its representatives;
• credit reference agencies;
• anti-fraud services;
• Governmental, legal, regulatory, or similar authorities, regulators, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, financial advisors, lawyers and other outside professional advisors to BenneFin, subject to binding contractual obligations of confidentiality;
• debt-collection agencies;
• data aggregation services;
• accreditation bodies;
• third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements guidelines.
• any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent
• necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
• If we engage a third-party Data Processor to process the Personal Data, the Data Processor will be subject to binding contractual obligations to:
• only Process the Personal Data in accordance with our prior written instructions; and
• use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

5.0 Legal compliance
In order to fulfill our legal obligations, such as those pertaining to fraud prevention and anti-money laundering, we might have to disclose your personal information to third parties. This would also happen when we:

• verify the information provided in applications for financings or other facilities;
• administer financings and financing accounts or facilities (through our licensed third parties, indirectly); and
• recover debts.

We will document any incorrect or erroneous information you provide, and we may be required to provide the information to fraud prevention organizations and/or local law enforcement if we believe you are trying to commit identity fraud. The information that fraud prevention agencies have recorded may be accessed and used by us and other organizations from other nations.

6.0 Use of Cookies
A cookie is a small file that is placed on the device when the party visit a website. It records information about the device, the browser and, in some cases, the preferences and browsing habits. We may process the Personal Data through cookie technology. We may use cookies and / or other tracking technology to distinguish between users and to remember your preferences. This helps us to provide you with a good experience when you use our sites and also allows us to improve our Sites.

We use Strictly necessary cookies, Analytical cookies, Functionality cookies and Targeting cookies. If you want to reject any of the cookies that we use, then you will need to change your website browser settings.

7.0 Security
We take appropriate technical and organisational measures to safeguard the personal information that you provide to us. We accept no liability if communications or other personal information are intercepted by third parties, delayed or incorrectly delivered or not delivered.

You are responsible for keeping the password provided to you as confidential. You may not to share these details with anyone and you need to inform us if you believe it has been compromised.

8.0 Legal rights
You may have various rights regarding the Processing of Personal Data, including:

• the right to request access to your Personal Data, together with information regarding the nature, Processing and disclosure of your Personal Data;
• the right to request rectification of any errors in your Personal Data;
• the right to request, on legitimate grounds:

1. erasure of your Personal Data; or
2. restriction of Processing of your Personal Data; and

• where we Process your Personal Data on the basis of your consent, the right to withdraw that consent on legitimate grounds.
• As appropriate, the rectification, erasure or blocking of Personal Data if the Processing of data does not comply with the provisions of the Personal Data Protection Law (hereinafter referred to as “PDPL”).
• the right to object, on grounds relating to their particular situation, to the Processing of Personal Data by us or on our behalf; and the right to object to the Processing of Personal Data by us or on our behalf for direct marketing purposes.

9.0 Changes to this Privacy Policy
We may at our absolute discretion update this Privacy Policy from time to time. Changes are binding on users of the Site and will take effect immediately on posting of the revised policy on the Site. Please do review the Privacy Policy regularly for such updates.

10.0 Contacting us
In case you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by BenneFin, they may contact on Email: customer.support@bennefin.com