1. Introduction

Better and its subsidiaries (collectively, “Better,” “we,” “us,” or “our”) respect your privacy and are committed to protecting it. This Privacy Notice explains how we collect, use, disclose, and otherwise process your personal information and employment information in connection with:

• your use of the Better official mobile application (the “App”) and any related platforms we operate (collectively, the “Platforms”);
• your application for, and use of, our financial products and services (collectively, the “Services”).

This Privacy Notice applies to all individuals who interact with Better in the capacities described above, including prospective, current, and former customers, employees, and applicants (referred to in this Privacy Notice as “you” or “your”). By accessing the Better Myanmar Mobile Application or Better Websites, you acknowledge that you have read and understood this Privacy Notice.

Terms not otherwise defined in this Privacy Notice have the meaning given to them in our Terms and Conditions. 

We may update this Privacy Notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated notice within the App, together with the date it was last revised. We encourage you to review this Privacy Notice periodically.

If you have any questions, concerns, or complaints regarding this Privacy Notice or our handling of your personal information, please contact us using the details provided in the “Contact Us” section of this Privacy Notice.

2. Personal Information We Collect and How We Use It

2.1 Purpose of Collection

We collect and store your personal and financial information for the following principal purposes:

• to process your loan application for our Services and make eligibility and credit decisions;
• to process payments and enable you to reserve and use our Services;
• to open, administer, and maintain your account with us;
• to respond to your inquiries, requests, and complaints;
• to verify your identity and comply with our legal and regulatory obligations, including know-your-customer (KYC) and anti-money laundering (AML) requirements; and
• to improve, develop, and communicate with you about our products and Services.

2.2 Information You Provide to Us

Better collects personal information that you voluntarily submit to us, which may include:

• identification and contact details, such as your Name, Date of Birth, NRC, Email Address, Current Address and Phone Number;
• employment information, such as your employer, job title, income, and length of employment (if applicable);
• copies or photographs of supporting documents required for our products or Services, such as your (NRC), ID Selfie, Household List, Proof of Address, Proof of Income, Company Recommendation Letter, E-Signature, Guarantor Information (Name, NRC, Employment Status, Current Address) and
• any other information you provide through an application form, email, text or similar message, telephone call, or other means of communication with us.

Your telephone calls and other communications with us are generally recorded or monitored for quality assurance, training, security, and dispute-resolution purposes. By communicating with us through these channels, you consent to receiving information from us through such methods and to the recording or monitoring of your calls and communications with Better.

We use the information described in this section to evaluate and process your application, provide our Services, communicate with you, and, from time to time, send you marketing or other promotional communications, where permitted by law and subject to your preferences.

2.3 Information We Collect When You Use Our Services

If you join Better or use our Services, we also collect information relating to your use of the App and our Services, including your application details, personal information, employment information (where you are an employee), and required supporting documents (such as your NRC, household registration, proof of address, ID Selfie, company recommendation letter, and related documents).

We use this information to:

• provide and optimize our Services for you, including offering financial products tailored to your needs;
• respond to your inquiries and provide customer support;
• provide, maintain, and improve our products and Services;
• personalize your experience with Better, including by understanding your preferences; and
• provide you with personalized content and offers.

2.4 Verification and Disclosure of Your Information

By submitting information to Better, you authorize us to investigate, verify, and disclose the information you have provided, including but not limited to your personal information, employment information, titles, deeds, and any other documents relevant to your personal or employment details. We may share and verify this information with our associated businesses and companies, representatives, officers, agents, and affiliates, solely for the purposes described in this Privacy Policy and in accordance with applicable law.

3. Automatic Information Collection

When you visit our Sites, use our Services, read our emails, or otherwise interact with us through a mobile device, we and our third-party partners automatically collect information about how you access and use the Sites and information about the device you use. We typically collect this information through cookies, flash objects, web beacons, embedded scripts, and similar technologies (collectively, “tracking technologies”), and we may engage third-party services to help us do so. Information collected automatically may be combined with other personal information and employment information we collect directly from you or from other sources.

3.1 Device and Usage Information

When you use our Sites, our servers automatically log certain information about your use of the application, such as your IP address, browser type, operating system, browser language, and service provider. We also collect information about your activity on our Sites, such as the pages you visit and the advertisements or links you click. We use this information, where we have a legitimate interest in doing so, to:

• improve our Services and develop new services based on how our application is used;
• identify products and marketing that may be of interest to you;
• personalize our Services to you;
• carry out statistical analysis and research to better understand our users and the products and services they want; and
• adapt our Services to the technical capabilities of our users and identify issues affecting the website or user experience.

3.2 IP Addresses and Other Automatically Collected Information

We may collect your IP address when you visit our Sites to help diagnose system problems, for system administration, to report aggregated information to our business partners, and to audit use of our Sites. In selected circumstances, we may use IP addresses to help identify you in order to protect our Services, Sites, users, or others. We also collect your browser type, Internet Service Provider (ISP), referring/exit pages, pages viewed, operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Sites.

3.3 Session Replay

When you visit our Sites, we may record information about your browsing session, including the pages you visited and any forms you completed. We review this information to identify technical issues and to improve the user interface of our Sites. Where we engage a third party to provide this service, this information will be shared with that third party for this purpose.

For more information about our use of cookies and other tracking technologies for advertising purposes, and how you may control the use of your information for these purposes, please see “Advertising and Personalized Content” below.

4. Personal Information Storage and Cross-Border Transfer

Better maintains servers within the Republic of the Union of Myanmar. Please note that the laws governing the processing of personal information in Myanmar may differ from those of your home country. By joining Better and using our Services, you consent to the transfer of your personal and financial information outside of your home country, as applicable, for the purposes described in this Privacy Policy. Where we transfer personal information across borders, we take reasonable steps to ensure it continues to be protected in a manner consistent with this Privacy Policy.

5. Disclosure of Your Personal Information

We share personal information with third parties only in limited circumstances, to fulfill a transaction you have requested, to offer you personalized services, or as otherwise permitted by law and consistent with the purposes for which the information was collected. For example, we may disclose your personal information to:

• contractors, advisors, consultants, and service providers acting on our behalf or under our instructions, for purposes relating to the provision, operation, maintenance, administration, promotion, improvement, and oversight of our Services, Sites, and advertising, or to fulfill your requests for information or service;
• our affiliated companies, including our parent company, subsidiaries, and other related entities, for business purposes such as internal management and administration; and
• a successor entity, in connection with a corporate transaction, proceeding, or reorganization (for example, if Better’s ownership or business changes as a result of a merger, acquisition, or transfer to another company).

We may also disclose your personal information, including location information, where required to do so:

• in response to legal process (such as a court order, search warrant, or subpoena) or a request from a law enforcement or regulatory authority;
• where we believe in good faith that our Application and Services have been used in violation of our policies, applicable law, or in connection with the commission of a crime;
• where we believe in good faith that disclosure is necessary to address an emergency that poses a threat to the safety of you or another person; or
• where necessary to protect the rights or property of Better or third parties.

6. Advertising, Cookies, and Similar Technologies

6.1 Advertising and Personalized Content

We use personal information to provide you with customized, personalized content and information, and to inform our marketing and advertising efforts, which may include sending you marketing or advertising communications by email, SMS, or in-app push notifications. If you do not wish to receive promotional communications from us, please follow the unsubscribe or notification opt-out instructions provided through the relevant channel.

6.2 Our Use of Cookies

Better uses cookies, flash objects, and other tracking technologies placed in the browser on your computer or mobile device to help recognize you on our Sites and to improve your user experience. We use both session cookies, which expire when you close your browser and are used to maintain session state and user identity, and persistent cookies, which remain on your device for an extended period and help us remember your preferences and improve your experience.

We, and our third-party partners, use information collected through cookies and tracking technologies to:

• remember information so you do not need to re-enter it during your visit, or on your next visit to our Services;
• provide and monitor the effectiveness of our Services;
• monitor aggregate metrics, such as total visitors, usage, and demographic patterns on our Services;
• diagnose and fix technical problems;
• detect and prevent fraud or misuse; and
• plan for, enhance, modify, or upgrade our Services.

6.3 Your Cookie Choices

If you would prefer not to accept cookies, most browsers will allow you to (i) change your browser settings to notify you when you receive a cookie so that you may choose whether to accept it, (ii) disable existing cookies, or (iii) set your browser to automatically reject cookies. You can control flash cookies through the Macromedia Flash application on your computer, or via the Macromedia Flash Player website, which allows you to view, modify, and delete flash cookies. If you reject browser or flash cookies, some areas of our Sites may not function properly. Depending on your device and operating system, you may not be able to delete or block all tracking technologies. You may also be able to adjust your email settings to prevent automatic downloading of images that may contain technologies allowing us to know whether you have opened or interacted with our emails.

6.4 Online Advertising and Third-Party Ad Networks

Better uses third-party ad network providers to serve targeted advertisements based on your browsing history. These providers use cookies or similar technologies to collect information about your use of our Sites, including our mobile apps, over time so that they may display advertisements on our Services, on other websites, apps, or services you use, and on other devices. We may share a common account identifier with our third-party advertising partners to help identify you across devices. We and our partners use this information to make the advertisements you see more relevant to your interests and to provide related services such as reporting, attribution, analytics, and market research.

The use of cookies, web beacons, or similar technologies by content and ad network providers is governed by their own privacy policies, not this Privacy Policy.

Opting out of interest-based advertising through the NAI's or DAA's online resources will only opt out the browser or device used to do so; you must repeat the opt-out on each browser or device you use, and these choices may not affect advertising that is not cookie-based. Some opt-outs may not be effective unless your browser accepts cookies, and you may need to opt out again if you delete cookies, change browser settings, or switch browsers, computers, or operating systems.

You may also limit mobile interest-based advertising through your device settings by selecting “Limit Ad Tracking” (iOS) or “Opt out of Ads Personalization” (Android). You may opt out of some, but not all, interest-based ads served by mobile ad networks by visiting App Choices and downloading the relevant app, and you may limit the use of location data for advertising purposes through your device’s location settings. We are not responsible for the effectiveness of, or compliance with, any third party’s opt-out options or programs, or the accuracy of their related statements.

Opting out of interest-based advertising does not mean you will no longer see advertisements from us or on our Services. In addition, third parties may continue to use cookies to collect information about your use of our Services for analytics, fraud prevention, and other non-advertising purposes.

6.5 Analytics, In-App Tools, and Advertising Technologies

We use Google Analytics and may also use other analytics, measurement, and in-app engagement tools, including CleverTap and Amplitude, to help us understand how users interact with our Sites, App, and Services. These tools may collect or process information such as device identifiers, user identifiers, app events, feature usage, session activity, interaction data, crash or performance data, and other technical or usage information. We use this information to measure and improve the performance of our Services, analyze user behavior, personalize content and experiences, troubleshoot issues, conduct research and reporting, and support product development and business analytics.

We may share or make available limited information, such as unique identifiers, hashed contact information, device information, or usage events, with these service providers to enable analytics, measurement, attribution, audience segmentation, personalization, in-app messaging, push notifications, campaign management, and related services. These providers process information in accordance with their own privacy policies and our instructions, where applicable. We may also use certain display advertising and advanced analytics features, including remarketing, impression reporting, demographics and interest reporting, and similar features, to inform, optimize, and display advertisements or personalized content based on your interactions with our Services.

Where available, you may control certain analytics, advertising, or notification preferences through your device settings, App settings, or the opt-out tools provided by the relevant service providers. However, disabling certain permissions or tracking technologies may affect the availability or functionality of some features of our App or Services.

6.6 Social Media Advertising and Social Sharing Features

We may use advertising platforms provided by Facebook, Viber, and other social media platforms to promote interest-based advertisements to you, determine which advertisements not to show you, and measure engagement with those advertisements. We may do this using web tracking tools or by sharing certain information, such as hashed email lists, with these platforms. These advertisements are governed by the privacy policies of the relevant social media companies. If you do not want to receive targeted advertisements on your social networks, you may be able to adjust your advertising preferences in your account settings on those platforms; for example, you can review Facebook’s advertising and privacy practices. We may use similar advertising programs on other social media platforms.

We may also use in-app engagement, attribution, analytics, and communication tools to support user segmentation, journey analysis, product usage analysis, campaign performance measurement, in-app messaging, push notifications, and similar functions. These tools help us understand how users engage with our App and Services, deliver relevant communications, improve user experience, and evaluate the effectiveness of our product, marketing, and engagement activities.

6.7 Do Not Track Signals

Some browsers support a “Do Not Track” feature, which signals to websites that you do not wish to be tracked across the different sites you visit. Our Sites do not currently respond to Do Not Track signals. If you block or reject cookies, not all tracking described in this section will stop.

7. Links to Third-Party Services

Our Sites may include links to other websites or mobile applications whose privacy practices may differ from ours. We are not responsible for the personal information practices of third-party websites, applications, or other third parties. We encourage you to review the privacy policies of any website or application you use.

8. Review and Correction of Your Personal Information

Better is committed to providing you with reasonable and practical access to your personal information so that you may identify any inaccuracies. Upon request, we may confirm whether we hold any personal information about you. Subject to applicable law, you may have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. 

9. Changes to This Privacy Notice

We may update this Privacy Notice from time to time, and we encourage you to review it periodically. We will notify you of material changes through our website, the App, or other reasonable means, and any amended terms will take effect as of the date the amended notice is posted. When we make changes, we will update the “Last Updated” date at the top of this Privacy Notice. Your continued use of Better’s Services following any such update will constitute your acceptance of the revised Privacy Notice.

10. Contact Us

If you have questions about this Privacy Notice or our handling of your personal information, please contact us during office hours at hello@better.com.mm or hotline at 09 949 238 837.