<![CDATA[The development of electronic lending services has increased the use of personal data in the financing process, including the use of third-party telephone numbers as emergency contacts. In practice, the inclusion of these telephone numbers is often done without the consent of the data owner and has the potential to cause losses when electronic credit providers use these numbers for collection purposes. This situation raises issues regarding legal protection for third parties outside the contractual relationship and the basis for the provider’s legal liability for processing personal data without consent. This study aims to analyze the legal status of third parties whose telephone numbers are used as emergency contacts without consent and examine the basis for the legal liability of electronic credit providers for the losses incurred. The study uses a normative legal research method with a statutory approach, a conceptual approach, and a case approach. Legal materials are analyzed qualitatively using a descriptive-analytical method. The results indicate that third parties do not have a contractual legal relationship with the provider or the debtor and therefore cannot be burdened with legal consequences arising from electronic credit agreements. Legal protection for third parties stems from the personal data protection regime, the obligations of electronic system providers, and the protection of the right to privacy. This study also found that electronic credit providers can be held liable under the doctrine of unlawful acts if they continue to process personal data without a valid legal basis and such actions cause losses that have a causal relationship with the data processing activity. The contribution of this study lies in the preparation of a normative analytical framework that integrates the principle of consent in protecting personal data, the obligations of electronic system providers, and elements of unlawful acts as a basis for determining the provider’s liability for the use of third-party telephone numbers as emergency contacts without consent.]]>
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