- Personal information which we collect
- The use of personal information which we collect
- Sharing of personal information which we collect
- Retention of personal information
- Access and correction of personal information
- Where we store your personal information
- Security of your personal information
- Acknowledgment and Consent
- Marketing and promotional material
- Anonymous data
- Third-party platforms
- How to contact us
1. Personal information which we collect
We collect information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains (“Personal Information”). Personal Information includes, but not limited to, name, address, date of birth, occupation, phone number, e-mail address, bank account and credit card details, gender, identification (including KTP, SIM or passport) or another government-issued identifier, photo, nationality, phone number of our users, financial related information, biometric information (including but not limited to facial recognition). Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with Personal Information, then that information Is also Personal Information. The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register or use the Application when you contact our customer services, or you otherwise provide Personal Information to us). We may collect information in various forms and purposes (including purposes permitted under applicable law).
Information obtained for you or from your mobile device directly
- When you register and create an account with us using the Application you have to provide us certain Personal Information, including your name, physical address, e-mail address, and your phone number.
- When you use the Application, you have to provide us with relevant information as may reasonably be required by us in order for the application to work, for example:
- If you are using the application as a user, you will need to provide us with information as to the type of services you seek
- If you utilize and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility provided by us, if you are the payer or the sender, you will provide us the information relating to the utilization, payment or transfer, including but not limited to the transfer and/or payment receiver details, the amount of payment paid, the type or payment or account used, the name of the issuer of that payment or account, the name of the holder for that account, the identification number of that account, the verification code of that account, as applicable.
- If you intend to apply as registered or verified account holder of the electronic money facility provided by us, you will provide to us the required information including but not limited to your full name, your identity card numbers, type of identity card you use for registration, address, gender, place, and date of birth, occupation, tax details, nationality and/or biometric data.
Information collected whenever you use the application or visit our website
- Whenever you use the Application or visit our website, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model and operating system of the device that you use to access the Application or our website.
- Whenever you user the Application through your mobile device, we will track and collect your geo-location information in real-time. In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your mobile device to enable us to give you a better experience in using the Application. You can always choose to disable the geo-location tracking information on your mobile device temporarily. However, this can affect the functionalities available on the application.
- If you utilize and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility provided by us, we may collect certain information related to your source of fund for top-up (including bank account details), account details of withdrawal receiver, transaction history (including receiver details), bill details, invoice details and phone number details.
- If you utilize virtual account provided by us to receive electronic money and/or electronic wallet payment from payer, whether you are user or merchant, we may collect certain information related to your utilization including but not limited to service transacted, amount collected from every transaction, withdrawal or settlement history.
Information collected from third parties
We may also collect your Personal Information from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, who collect your Personal Information and/or perform functions on or behalf, or whom we collaborate with). In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be). Specifically, when you register for an account through the Application, we may collect certain financial information and financial history of yours (including but not limited to account transaction history, account details, account status and states) from any other third parties.
Information about third parties you provide to us
You may provide us with Personal Information relating to other third-party individuals (including personal information relating to your spouse, family members, friends or other individuals). You will, of course, need their consent to do so – see “Acknowledgement and Consent” below, for further information.
2. The use of personal information which we collect
We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by applicable law (“Purposes”):
- Where you are a user, we may use your Personal Information:
- To identify you and to register you as a user and to administer, verify, deactivate, or manage your account as such;
- To facilitate or enable any verification as we may in our discretion consider necessary before the service provider provide you with the services or before we register as a user, including performing Know Your Customer (KYC) and credit scoring;
- To enable service providers to provide you with such of the services as you have requested;
- To process and facilitate orders and payment transactions made by you, including where applicable, transactions made through any account available over the Application;
- To notify you of any transaction or activities that occurred within the Application or other system linked to our Application;
- To facilitate account and/or wallet linking, if you initiate account and/or wallet linking feature between your account or wallet and third party platform;
- To communicate with you and to send you information in connection with the use of the Application;
- To notify you of any updates to the Application or changes to the services available;
- To process and respond to enquiries and feedback received from you;
- To maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a user;
- To monitor and analyze user activities, behavior, and demographic data including trends and usage of the various services available on the Application;
- To process and manage your reward points;
- To offer or provide services from our affiliates or partners; and
- To send you direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions.
- Where you are a service provider, we may use your Personal information:
- To identify you and register you as a service provider and to administer, manage or verify your account as such;
- To facilitate or enable any verification as we may in our discretion necessary before we register you as a service provider, including for KYC and credit scoring;
- To enable you to provide services to users;
- To process, facilitate, and complete payments due to you related to any services you have provided;
- To communicate with you and send you information in relation to the provision of your services, including to relay user orders to you and to facilitate your acceptance of such orders of services;
- To provide you with notification and updates on the Application or changes to the manner in which services are to be provided;
- To provide you with a report in relation to the services that you have provided;
- To process and respond to feedback from users on the services which you have provided;
- To maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a service provider;
- To monitor and analyze user activities, behavior, and demographic data including trends and service provider responsiveness for the various services available on the Application;
- To process and manage your reward points;
- To offer or provide services from our affiliates or partners;
- To send you direct or targeted marketing communications, advertisement, promos, surveys and information on special offers or promotions.
- Whether you are a user or a service provider or otherwise provide Personal Information to us, we may also use your personal information more generally for the following purpose:
- To undertake associated business processes and functions;
- To monitor usage of the Application and administer, support and improve the performance efficiency, growth, user experience and the functions of the Application;
- To provide assistance in relation to and to resolve any technical difficulties or operational problems with the Application or the services;
- To generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and collaboration;
- To prevent, detect, and investigate any prohibited, illegal, unauthorized or fraudulent activities;
- To facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us and/or any of our affiliates; and
- To enable us to comply with our obligations under any applicable law, including but not limited to responding to regulatory enquiries, investigations or directives, complying with regulatory filing, reporting and licensing requirements, and conducting audit checks, due diligence and investigations.
3. Sharing of personal information which we collect
We may disclose to, allow access to or share with affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by applicable law:
- Where you are a user, for the purpose of enabling a service provider, to perform or deliver a service;
- Where you are a service provider, for the purpose of enabling a user to request or receive a service from you;
- Where required or authorized by applicable law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing and reporting, and licensing requirements), for the purpose so specified in that applicable law;
- Where instructed, requested, required or authorized by the government authorities, for the purpose as specified in the government policy, regulations or applicable law;
- Where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the services, for the purposes of that legal proceeding;
- In relation to any verification as we or other third party may consider necessary before the service provider provide you with the services or we register you as a user, including for KYC and credit scoring;
- Where we enable our services in third parties’ platform, (i) to assist us in obtaining your personal information and/or (ii) to register you or allow you to use our services from such platforms;
- In an emergency concerning your safety (whether you are a user or a service provider) for the purpose of dealing with that emergency;
- In connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such transaction (even if the transaction is eventually not proceeded with);
- In connection with insurance claim, we will share your personal information for the purpose of processing the insurance claim to the insurance company that we engage or have collaboration with;
- To third parties (including our agents, vendors, suppliers, contractors, partners, and any others who provide services to us or you perform functions on our behalf, or whom we enter into commercial collaboration with) for or in connection with the purposes for which such third parties are engaged, to perform certain disclosure to the relevant third parties which are technically required to process your transaction or for the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or connect with your account, or conducting other activities including marketing, research, analysis and product development; and
- Where it is not necessary for the personal information to be associated with you, we will use reasonable endeavors to remove the means by which the personal information can be associated with you as an individual before disclosing or sharing such information.
- We will not sell or lease your personal information.
4. Retention of personal information
Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or authorized by Applicable Law. We shall cease to retain personal information, or remove the means by which the personal information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of personal information and retention is no longer necessary for legal or business purposes.
Please note that there is still the possibility that some of your personal information might be retained by the other party, including by the government institutions in some manner. In the event we share your personal information to the authorized government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that the retention of your personal information by the relevant institutions will follow their respective policy on data retention. Information relayed through communications between users, service providers made other than through the use of the Application (such as by telephone calls, SMS, mobile messaging or other method of communication and collection of your personal information by our agent) may also be retained by some means. We do not encourage the retention of personal information by such means and we have no responsibility to you for the same. We shall not be liable for any such retention of your personal information. You agree to indemnify, defend and release us our officers, directors, employees, agents, partners, suppliers, contractors and Affiliates from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorized retention of your personal information.
5. Access and correction of personal information
Subject to the applicable law, you ay request us for access to and/or the correction of your personal information in our possession and control, by contacting us at the details provided below.
We reserve the right to refuse your request for access to, or to correct, some or all of your personal information in our possession or control if permitted or required under any applicable law. This may include circumstances where the personal information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.
6. Where we store your personal information
- Your personal information may also be stored or processed outside of your origin country by our third-party service providers, vendors, suppliers, partners, contractors or Affiliates.
7. Security of your personal information
Confidentiality of your personal information is of utmost importance to us. We will use all reasonable efforts to protect and secure your personal information against access, collection, use or disclosure by unauthorized persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, you acknowledge that we cannot guarantee the integrity and accuracy of any personal information which you transmit over the Internet, nor guarantee that such personal information would not be intercepted, accessed, disclosed altered or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for keeping your account details confidential and you must not share your account details, including your password and One Time Password (OTP), with anyone ad you must always maintain and be fully responsible for the security of the device that you use.
9. Acknowledgement and Consent
In circumstances where you provide us with personal information relating to other individuals (such as personal information relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her personal information by us.
You may withdraw your consent to any or all collection, use or disclosure of your personal information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information via any “opt-out” or “unsubscribe” facility contained in our messages to you. Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the application or services. A withdrawal of consent by you may result in the termination of your account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your personal information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.
10. Marketing and promotional material
We and our partners may send you direct marketing, advertisement, and promotional communications via push-notification app, message in application, post, telephone call, short messaging service (SMS), chat platform, social media, and e-mail (“Marketing Materials”). If you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us. You may opt out from receiving such marketing communications at any time by clicking on any “unsubscribe” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you opt out, we may still send you non-promotional messages, such as information about your account.
11. Anonymous data
We may create, use, license or disclose personal information provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that has been combined with similar data such that the original data form a part of a larger data set.
12. Third party platforms
The application, website and marketing materials may contain links to websites that are operated by third parties. We do not control not accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties.
Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your personal information.
When you are using our application and enable the fingerprints and/or facial recognition features in your mobile device for authentication purposes, please note that we do not store such biometric data. Unless otherwise notified to you, such data is stored in your mobile device and may also be stored by third parties, such as your device’s manufacturer. You agree and acknowledge that we are not responsible for any unauthorized access or loss towards such biometric data which is stored in your mobile device.
13. How to contact us
For other questions or complaints, you can contact us via e-mail, telephone, WhatsApp, or at the following contacts:
E-mail: email@example.com Customer Service: +62 822-9944-2342 (WhatsApp)