Privacy Policy

The existence of this Privacy Policy is part of PT. Akulalu Silvrr Indonesia (“Akulaku” or “We”) in order to protect users’ privacy and personal data. To provide the best service to you and protect your interests, we will only collect your information that we need. We will not process, analyze, store or share your information with third parties without your consent unless this has been regulated based on the legal provisions in force under the jurisdiction of the Republic of Indonesia (“Applicable Law“).

We ensure compliance with this Privacy Policy by Us, Our employees, Our Affiliates and external services that work or perform services for Us. For this purpose, We have taken the necessary actions based on the provisions of Applicable Law.

In using our services and/or products, you must read and agree to the “Terms and Conditions for Using the Akulaku Application” which is an integral part of this Privacy Policy.

The Privacy Policy can be changed or updated from time to time and you are advised to always read and check the Privacy Policy carefully from time to time. We will always notify you in advance regarding any changes to this Privacy Policy via email registered on the Akulaku Application or in other reasonable ways, including uploading notifications of these changes on the Akulaku Application. However, changes can take effect immediately without prior notification if prior notification is deemed impossible, for the User or legally required. By continuing to access and use the services available in the Akulaku Application, you are deemed to agree to changes to the Privacy Policy from time to time.

1.How We collect your data

1.1 Personal data that you voluntarily provide us

We will collect, store and process information that you voluntarily provide to us during registration and use of our application in connection with the following matters:

a.Fill in registration information including but not limited to name, address, telephone number, mobile number, email address, date of birth, occupation, financial records, list of installed applications, financial details and history, and any personal data contained in correspondence between you and Us via email, telephone or physical mail correspondence, as well as other information that we may require from time to time;

b.Biometric data (via voice files, facial features, or other body) provided when you upload the biometric data to Akulaku,When you consent to Akulaku’s use of your biometric data, Akulaku (or service providers, such as technology vendors, working on our behalf) collects face scan information—face geometry information and related information—necessary to accomplish the purposes stated in this Policy, at points of collection Akulaku does not collect, use, store, or disclose your biometric data without your consent;

c.Data that you provide when making transactions and/or using the Akulaku Credit Program services available in the Akulaku Application;

d.Data that you provide through platforms, applications or other third parties, based on your consent on the relevant platform or application to the extent permitted by the provisions of Applicable Law;

e.Information contained in the correspondence between you and us via email or physical mail correspondence.

f.Information that you provide when submitting criticism and suggestions or complaints to Akulaku;

g.The information contained in your decision with consent if you decide to register with our services or products

h.Your review or opinion on our services and products; and

i.All data and or information that you provide to us voluntarily from time to time.

If the user objects and does not want to share the above personal information/data, the user can opt out or choose not to give consent to share personal information/data. Users can contact the Akulaku call center at any time as explained in point 8 below, if they want to change the agreement to use the user’s personal data.

1.2 Personal data that We collect automatically.

Apart from the data that you send to us voluntarily, we will also collect your data through the use of cookies or other similar tracking technologies on the device you use (“Information“), to the extent permitted by the provisions of Applicable Law, Google Play Store and App policies. Store (“Developer Policy”). For the avoidance of doubt, We will display disclosures and obtain your authorization before We collect Information, if such disclosure and authorization are required by the Developer Policy.

Information will contain information including but not limited to:

• geographic location
• IP address
• domain name
• contact list
• list of downloaded apps
• the frequency of use of the downloaded application
• operating systems and platforms
• IMEI(International Mobile Equipment Identity)
• the brand of the device used
• the type of device used
• Network connection type
• Mobile Ad ID
• requested object
• Biometric Data
• other information contained in the Information

Information stored on your device will be sent automatically to our website, application or data center. Therefore, if you want to deactivate your information or delete your information that we collect automatically, you can do this by clearing cookies on your device where you have full control and rights over cookies or you can delete the Akulaku application.

1.3 Personal data that we collect based on your consent through third party applications (such as Facebook or Google).

In order to improve your experience in using the Akulaku Application, you can register through your social media accounts or third party applications, including but not limited to Facebook and Google (“Social Media Accounts“), or you can connect your Social Media Account with your account. on the Akulaku Application. Based on your consent and also the privacy policy of the Social Media Account manager, through your Social Media Account, we can collect the following data including but not limited to:

• User id
• Name
• Photograph
• Access token or similar identification and authentication technology used by the manager of your Social Media Account
• All data and or information that you provide to us voluntarily from time to time.

Based on this privacy policy, we will use, process and protect all data and information that we collect through your Social Media Account. In the event that you object to the data and or information that we have collected through your Social Media Account, or you intend to ask us to delete the data, you can contact us in the manner described in point 8 below. However, please note that certain features may no longer be used by you in connection with deleting the data.

By downloading or using the Akulaku Application, you hereby give consent to Akulaku to access the information as mentioned above, without requiring a separate approval from you.

Apart from the things mentioned above, we may also collect other information about you, your device or your use of our website or application with your consent (if required by applicable law).

2.How We use Your data

As a trading platform application company that facilitates legal online trading activities and complies with Applicable Laws, Akulaku has an interest in providing the best service and increasing the efficiency of its application. Therefore, we will use and process your personal data including but not limited to:

• the purpose of data verification and/or identification as a fulfillment of Akulaku’s risk management requirements
• transactional interests including but not limited to purchasing, paying, delivering financial products or services, finance and or other financial-related products;
• complying with Applicable Laws, guidelines and regulations governing treatment in the respected country;
• facilitating you to obtain financial products through our Affiliates or Partners (as defined below) who operate lawfully under Applicable Law, where they can carry out analysis to understand your financial needs and requirements with the aim of providing financial products that suit your needs You;
• the interest in verifying your data through third party services including but not limited to verification through a system provided by the Directorate General of Population and Civil Registration through our Affiliate or Partner system, in connection with the financial product requested by you;
• as preference data for us, in creating relevant promotional content and marketing materials;
• make improvements to our services and products to ensure that the content presented is appropriate and efficient for you
• generate statistical and research data for internal reporting and as required by Applicable Law and/or record keeping requirements
• software updates and/or other updates and support that may be required from time to time to ensure the smooth use of the Akulaku Application
• store, maintain, back up (whether for disaster recovery or otherwise) the user’s personal data, whether within or outside the user’s jurisdiction; and
• all actions that aim to provide services, marketing, advertising, operational interests, business development along with due diligence to the extent permitted by applicable legal provisions.
• specifically related to biometric data (including but not limited to face geometry information and related information), our biometric system is used for identification purposes through user characteristics for the identity verification process using data attached to the user so that identity verification can only be carried out by people with the exact same profile because biometric records are unique and cannot be transferred.
• We need this to reduce the occurrence of access by parties other than the users themselves as a fulfillment of Akulaku’s risk management requirements for the use of Akulaku services and services from third parties including but not limited to services provided through our Affiliate or Partner system, in connection with the financial product requested by You.Furthermore, biometric data is also required to support the requirements of implementing applicable laws and regulations (including but not limited to regulations of relevant authorities regarding the implementation of anti-money laundering and prevention of terrorism financing programs in the financial services sector).

If you decide to get financial products from our Affiliates or Partners through our application, then, we will use this data to initiate and maintain correspondence with you via electronic mail (email), SMS (short message service), registered mail, telephone calls and other channels as permitted by Applicable Law.

Apart from the points mentioned above, we may also use your personal data to protect and prevent fraud, claims and other obligations to comply with Applicable Laws if necessary. In this situation, We reserve the right to freeze, disable or take appropriate action against Your account in accordance with Applicable Law

In the event that the user no longer uses the Akulaku application or is no longer registered as an Akulaku user, we will store the personal data as mentioned above (including but not limited to biometric data, especially, face geometry information and related information) with a maximum retention period of 10 (ten) years or shorter in accordance with regulatory orders. applicable laws (including but not limited to laws on personal data protection). During the retention period, we will not share your personal data (including but not limited to biometric data) to any third party in a way that violates the law.

3.With whom We may share Your data

To protect your privacy, we will not sell, rent or disclose your information to any third party without your consent. However, in order to facilitate you to get better services and or products as well as to fulfill our operational needs, we may share your personal data with the following third parties:

a. Our Affiliated Companies. We may share your data with parent companies, subsidiaries, joint ventures and other entities under our direct and or indirect control (“Affiliates”), as long as permitted by the provisions of Applicable Law from time to time, including but not limited to data center owned by us, namely at https://r.akulaku.net. In this regard, we will use our best efforts to get these other entities to respect this Privacy Policy;

b. Our Partner Companies. We may share your data with third-party companies that work with us (“Partners“) based on the financial products that you requested through our platform as long as permitted by the provisions of Applicable Law from time to time. In this regard, we will use our best efforts to get these partners to respect this Privacy Policy;

c. Third Party Service Providers that we have appointed to act on our behalf in providing services and ensuring that our functions and services can run properly and efficiently. For the avoidance of doubt, we will not allow Third Party Service Providers to use your personal data for other purposes;

d. IT system management providers that we use who act on our behalf, to manage IT systems that may contain personal data;

e. The payment system provider that we appoint will operate the system based on the provisions of the Applicable Law;

f. To our advisers and insurance companies, in the event of a claim;

g. Government agencies, stock exchange agencies or representatives, or to respond to requests from law enforcement authorities under Applicable Law.

h. For the purpose of merger, sale, restructuring or transfer of assets, We may transfer Your data to Our Affiliates, successors or new owners. For the avoidance of doubt, these measures may only be applied as permitted under the provisions of Applicable Law. In connection with this, we will use our best efforts to get these parties as mentioned to respect this Privacy Policy; and

i. other third parties in order to achieve the purpose of using data and information as stated in point 2 above.

To the extent permitted and in accordance with the provisions of Applicable Law, We may transfer Your data and or information outside the registered jurisdiction to achieve operational purposes as regulated in this Privacy Policy.

4.Security of your data

In maintaining the security of your data, we use an electronic system that is equipped with an adequate level of security, required by applicable law and we will update the security level from time to time. However, please note that although we always take the best possible steps to protect your personal data, no website, internet transmission, computer system or wireless connection is completely secure.

5.Sites provided by third parties

In using our platform, you may find links that will take you to other sites that are owned by third parties, whether they are affiliate sites, partners or other sites, where this Privacy Policy does not apply to the site resulting from the link. Please read the Privacy Policy provided by these third parties carefully considering that we do not have any responsibility for the Privacy Policy.

6.Your rights as the owner of the data

For all data that you provide to us voluntarily, and which we collect automatically as explained in point 1 above, you have the right to:

a. The right to obtain information. You have the right to obtain information by asking us about your data that we store from time to time. This information includes, among other things, your data that we store, lists of names of third parties who receive your data from us, lists of names of third parties who provide your data to us, if we get your data from other third parties

b. Right to correct. You have the right to update or change your data stored with us.

c. Right to deletion. You have the right to partially or completely delete your data stored with us from time to time, on the following basis:

• You withdraw Your consent to be a user on Our platform;
• Your data has been used unlawfully; and
• Other things that you think have violated your rights.

d. The right to make a complaint to the authorities. You have the right to make a complaint to the relevant authorities, in this case, the complaint is addressed to the Directorate General of Consumer Protection and Commerce, Ministry of Trade of the Republic of Indonesia, Consumer Complaint Service through the following channels:

via direct visits

Gedung I Lantai 3, Jalan M.I. Ridwan Rais No. 5, Jakarta Pusat 10110

via whatsapp contact number:

0853-1111-1010

via e-mail:

Pengaduan.konsumen@kemendag.go.id

In connection with your request to obtain information, correct and delete data, we will verify the authenticity of your identity before we process the request. Furthermore, we have the right to stop our services to you either in part or in whole after deleting your data on our platform.

You can exercise your rights to obtain information, correct and delete data by contacting us in the manner described in point 8 below.

7. Consent you give

By registering as a user on our platform, you acknowledge that you have read and understood this Privacy Policy and the Terms and Conditions for Using the Akulaku Application, therefore you agree to all the provisions of this Privacy Policy.

8. How to contact Us

In accordance with the Privacy Policy above, We are committed to fulfilling any requests or concerns that You may face regarding Your personal data. If you wish to withdraw your consent, delete, request access to, or modify the information you have provided to us, please contact us at:

PT Akulaku Silvrr Indonesia

Direktorat Jenderal Perlindungan Konsumen dan Tertib Niaga Kementerian Perdagangan Republik Indonesia

Email: cs.id@akulaku.com

Call Center: 1500920

In terms of the identity verification process for the purpose of the Akulaku credit application, your personal data in the form of demographic and/or biometric data will be checked for suitability, by PT Indonesia Digital Identity (VIDA) as our partner, with the data recorded in the agency system entitled to issue the identity. If your personal data is verified for suitability, then VIDA as a certified Electronic Certification Provider by Kominfo, will issue an electronic certificate as proof that your personal data has been verified and is in accordance with the data recorded in the agency system entitled to issue the identity. VIDA’s Electronic Certificate Policy and/or Certificate Practice Statement can be accessed via https://repo.vida.id