<![CDATA[Abstract. General Background: The growth of online lending services has created new challenges in personal data protection, particularly during debt collection. Specific Background: Personal data obtained through online lending applications may be used to contact third parties who have no legal relationship with the loan agreement. Knowledge Gap: Previous studies have largely focused on debtors and have not systematically examined non-emergency contacts as third parties whose privacy rights may be violated during online lending collection practices. Aims: This study analyzes the forms and methods of personal data misuse involving non-emergency contacts and examines the legal responsibility of online lending application providers for such misuse. Results: Using normative legal research with statutory and conceptual approaches, the study identifies contact injection, spamming and blast messages, robocalls, and false claims that third parties are guarantors as forms of personal data misuse. These practices violate personal data protection principles and third-party privacy rights. Online lending providers may bear administrative, civil, and criminal liability under the Personal Data Protection Law, Electronic Information and Transactions Law, Financial Services Authority regulations, and the AFPI Code of Conduct. Novelty: The study places non-emergency contacts as third-party legal subjects whose personal data and privacy rights require specific legal protection in online lending collection practices. Implications: The findings highlight the need for stronger supervision, compliance with personal data protection principles, and ethical debt collection practices to protect third-party privacy rights. Key Findings Highlights Non-emergency contacts can become secondary victims of collection practices. Multiple collection methods involve unauthorized third-party data processing. Providers may face administrative, civil, and criminal liability. Keywords : Online Lending, Personal Data Protection, Third Parties, Legal Responsibility, Debt Collection]]>
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