Privacy Policy

1. Introduction

This Privacy Policy applies to how L2O B.S.C. (closed) (“L2O”, “we”, “us” and “our”), a financing company licensed by the Central Bank of Bahrain (CBB) as a Type 3 Financing Company under CBB Rulebook Volume 5, collects, processes, stores, protects and discloses your personal data. By using email, WhatsApp Messenger, visiting our offices, submitting an application through any channel, you agree to the terms outlined below and consent to the use of your personal data in accordance with applicable laws, including Law No. 30 of 2018 promulgating the Personal Data Protection Law (the “Personal Data Protection Law”) and its implementing regulations.

2. Information We Collect

In order for you to utilize the financing services offered by us, we need to collect and process personal and financial information, such as the following:

• Contact Information:including name, maiden name and surname, title, home address, telephone numbers, and personal email address(es);
• Identity Information:including date and place of birth, citizenship, country of residence, government-issued documentation (for example, national identification number (CPR), driving license information), gender, civil status, beneficiaries and dependents;
• Employment Information;
• Financial Information:including bank account details, payroll records, financial history and activity, income information (i.e. source and monthly average), details that are passed via the Information Government Authority (“IGA”) or BENEFIT Company;
• Credit Information:including credit reports obtained from the Bahrain Credit Reference Bureau (known as Awan) or any licensed credit bureau;
• Voice or Image Recordings:where applicable, for identity verification purposes during customer due diligence.

We may also request the submission of certain documents identifying the information mentioned above.

3. How Information Is Collected

We collect personal data from the following sources:

• Personal data received and collected via WhatsApp, email, or physical;
• Personal data we receive directly and voluntarily from you;
• Personal data we obtain from third parties such as the Benefit Credit Reference Bureau, IGA and any third party financial service provider appointed by us;
• Personal data collected from publicly available sources, such as any information available online.

4. How We Use Your Information

We collect and use your information for the following purposes:

• To provide our financing services to you and allow you to apply for and manage your financing;
• To assess customers’ creditworthiness to provide financing services;
• To collect due and outstanding debt;
• To improve our services and resolve customer issues;
• To comply with legal and regulatory requirements of the Central Bank of Bahrain;
• To comply with laws that require us to verify the identity of our customers (KYC – Know Your Customer);
• To detect and prevent fraud or other financial crime;
• For customer onboarding and registration, screening customer name, account recovery and identity verification;
• For personalized and enhanced customer experiences;
• To pass to a bank or financial institution where required for financing processing purposes.

5. Document and Identity Verification

Additionally, we use facial image verification (where applicable) and identity document scanning as part of our regulatory requirements during onboarding to confirm your identification documents. This may include comparing a photograph you provide with the photograph found in your official identification documents (CPR or passport) to verify that you are the legitimate user.

Where such verification is conducted, the data used for this verification process is handled in accordance with the Personal Data Protection Law and is not shared with unauthorized third parties.

6. Data Storage and Sharing

Any information collected will be stored for a period of time necessary to provide you with the services. We may also retain the information for a longer period, but in no case shall such period exceed any maximum timeframe required by the relevant regulations or laws of the Kingdom of Bahrain (including CBB Rulebook Volume 5 retention requirements). Your data remains confidential and secure within our systems. Additionally, your personal information will not be shared with any third party except as provided in this Privacy Policy or unless required by any governmental, legal or regulatory authority.

We may share your personal data with:

1. Government authorities (including the Central Bank of Bahrain and the Personal Data Protection Authority);
2. Companies within our corporate group and our affiliates;
3. Any bank or licensed third party service provider for the purpose of providing our financing services to you;
4. Third party service providers who support the provision of our services, including lawyers and legal consultants, auditors, IT support services, debt collection partners, and other professional service providers;
5. Credit reference agencies, including the Bahrain Credit Reference Bureau;
6. A third party who may acquire our business and/or assets, or a portion thereof;
7. Select third parties who may wish to market their products or services to you (only where you have provided your consent); and
8. Any third party where we consider that it is necessary to protect, defend or enforce our rights under any agreement governing our relationship with you.

When applicable, we will implement appropriate measures to ensure that your personal data remains protected and secure when it is transferred outside of Bahrain, in accordance with applicable laws.

7. Data Security

We implement robust security measures to protect your data from unauthorized access, alteration, or disclosure, in compliance with the Personal Data Protection Law and CBB requirements.

8. Withdrawal of Consent

You have the right to withdraw your consent to our use of your personal data by contacting us at any time. However, as such data is integral to us providing you with our financing services, any consent withdrawal will be deemed as a request for termination of the services, and accordingly subsequent consequences (including repayment of any outstanding financing) shall be applied.

9. Right of Access, Correction, Erasure and Objection

By contacting us, you may:

1. Request access to your personal data in order to receive a copy of the personal data we hold about you;
2. Request correction of your personal data where it contains any incomplete, inaccurate or outdated information about you;
3. Request the erasure of your personal data (subject to legal retention obligations under CBB rules);
4. Object to processing causing material or moral harm.

We will review your request and respond within the appropriate timeframes in accordance with the Personal Data Protection Law.

10. Changes to this Privacy Policy

We reserve the right to periodically update or alter this Privacy Policy. In case of significant modifications, we will provide notification through our website or via email. Your continued utilization of L2O’s services after these changes denotes your acceptance of the revised Privacy Policy.