1. Personal data is data about an individual person that is identified or can be identified separately or combined with other information either directly or indirectly through electronic or nonelectronic systems.
2. PT Honest Financial Technologies ("Honest"/"we"/"us") understands that your personal data is important. What we can learn about you will help us in providing better services for you.
3. We will protect your data. This Privacy Policy ("Privacy Policy") describes how we protect the confidentiality of your personal data in accordance with the regulations related to personal data protection in Indonesia ("Law").
4. This Privacy Policy has been adapted to the provisions of applicable laws and regulations in Indonesia, including the provisions of the Otoritas Jasa Keuangan regulations and Bank Indonesia regulations.
5. Please read this Privacy Policy to understand how we collect, process and store your data.
6. This Privacy Policy is binding after you agree to it and/or you use Honest services and/or applications.
7. Personal data we collect
   ‍
   We collect the following information about you:

1. Personal information you provide when you use or make an application for our products or services, including your name, address, ID number, place and date of birth, email address, nationality, and biometrics;
2. Communication data, including your communication and marketing preferences;
3. Financial information, including card information, account information, transactions using our products, and all data related to our products and services;
4. Technical data and related information, including mobile networks, owned applications, operating systems, IP addresses, mobile phone technology, and other device data;
5. Usage data, including how you use our products and services;
6. Information we may access with your permission, including geolocation, GPS and camera photos;
7. Information from third parties that may assist us in providing products and services, fulfilling your rights and obligations to us and vice versa, or fulfilling applicable legal provisions; and/or
8. Other information we need with notice before we collect it.

8. When we collect your personal data
   ‍
   We collect your personal data when:

1. You give it to us;
2. You use our products and services;
3. You interact with us;
4. You give us permission to retrieve data for the purpose of the service; and/or
5. Necessary to fulfill your rights and obligations to us and vice versa or to comply with applicable law.

9. Sources of your personal data
   ‍
   We collect personal data from you. We may also collect your data from third parties including our partners, public domains, websites, cookies, behavior or location tracking tools, banking services, other financial services or other services.
10. What we do with your data
    
    We may use, transfer and/or disclose your data to:

1. Process your application for our products or services;
2. Check your credit or credit score or creditworthiness-related reports;
3. Provide, operate, and maintain our products and services, including fulfilling requests and communicating with you;
4. Developing, improving and designing our products and services;
5. Meet our internal operational and compliance requirements, including risk management, testing, audits and administrative matters;
6. Developing credit and risk scoring models;
7. Develop or maintain your credit history;
8. Assisting other financial institutions in conducting credit checks;
9. Administering, enforcing and fulfilling your rights and obligations with us and vice versa;
10. To protect or defend our (and our affiliates') legal rights, Intellectual Property Rights, privacy, security or property;
11. With your consent, marketing our products and services;
12. Comply with applicable laws and regulations against us or requests from or audits by authorities;
13. Provide materials, content or invitations to you;
14. Communicate with you, including providing certain notices or alerts;
15. Conduct research, analysis or surveys in relation to our services or products;
16. Prevent, investigate or report fraud, fraud or other illegal activities;
17. Carrying out corporate actions including but not limited to acquisitions, mergers, mergers or separations;
18. Other purposes related to the above; and/or
19. Other purposes with your consent.

11. Disclosure of Information to Third Parties
    ‍
    We maintain the confidentiality of the data we hold for the purposes set out in Section 8 above, however we may provide this data or information to other parties for the Purposes above. Such other parties include:

1. Affiliated or related entities, including our subsidiaries or parent companies;
2. Service providers, agents or contractors, including telecommunications companies, verification, KYC vendors, data analytics vendors, or cybersecurity vendors;
3. Financial institutions, payment system operators, payment infrastructure operators;
4. third-party financial institutions, insurance companies, credit card companies or merchants, securities and investment service providers;
5. Credit information management companies or institutions;
6. Collection agencies or collection service companies;
7. With your consent, the marketing agent;
8. The assignee of any or all of our business or assets relating to you;
9. Any third party that guarantees your obligations;
10. Providers of rewards, loyalty, co-branding, or privilege programs;
11. Authorized agencies inside or outside Indonesia; and/or
12. Purchasers or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets.

12. We may transfer your personal data outside Indonesia for the above Purposes in accordance with the laws and regulations applicable to personal data and those applicable to us.
13. We will stop storing your personal data by securely destroying it or remove the medium by which it can be linked to you through anonymization, as soon as possible after assuming that such storage no longer fulfills the purpose for which the personal data was collected and is no longer necessary for any legal or business purposes. However, Honest will not delete such Personal Data for the period for which Honest is required by law to retain it. Honest complies with the law in dealing with data breaches and security incidents, including where necessary, to notify you of them.
14. You have the right to submit your request to change, block, delete, or destroy your personal data at any time. We may grant such requests were permitted based on data retention obligations applicable to us and applicable regulations related to the protection of personal data.
15. You may withdraw your consent for the collection, use and/or disclosure of your personal data that we have or under our control by sending an email or making a phone call to our CustomerService at our email address and telephone number listed below in Clause 23 or our website from time to time, and we will process your request in accordance with this Privacy Policy and our obligations under applicable regulations.
16. The revocation of the permit as mentioned above can have an impact on certain legal consequences arising from the revocation. In this case, depending on the extent to which we withdraw your consent to process your personal data, we may not be able to continue to provide you with services, we may need to terminate the relationship and/or contract you have with us, and so on, as the case may be, which we will notify you.
17. This Privacy Policy continues to apply to you as long as:

1. You are registered as our user;
2. You still have any obligations, financial liabilities, debts or similar thing to us; and/or
3. You are still in the process of submitting our products or services and our assessment of them.

18. Cookies Policy
    
    Cookies help us understand and improve your browsing experience . Cookies are small data files on your device that capture your interaction with our Platform. Cookies are generally used to learn about your activity on our Platform and remember your preferences so that we can recognize you when you visit.
    ‍
    We may use several types of cookies:

1. We use necessary cookies to check whether you have cookies enabled in your settings so that temporary information can be transferred between different pages of our website and does not need to be entered repeatedly.
2. Functionality cookies help us recognize you each time you visit our website, so we can tailor content based on your preferences and other details
3. Analytical/performance cookies help us collect statistics, such as the number of new and repeat visits to our website. This information is used to understand how you use our website so that it is more intuitive.
4. Targeting/advertising cookies  record your visit to the website, your response to our online advertisements and the pages and links you visit so we know what you like.
5. Third-party cookies may be installed on your device by us or third parties on our behalf. These cookies may be managed by well-known advertising networks and external service providers, such as Google or Facebook. Your browser information is shared with such third parties (but does not include your personal information). Most of these cookies are analytical/performance or targeting/advertising cookies.

You can block cookies by changing the settings in your web browser. However, some features on our Platform may not be usable if cookies are blocked.

19. This Privacy Policy does not apply to third party websites located on or connected to our Platform, which have their own privacy policies. We are not responsible for the content of such third party websites.
20. We do not guarantee the security of personal data and/or other information you provide on third party websites, but we have implemented various measures to maintain the security of your personal data that we hold or control. Your personal data is protected by a secure network and can only be accessed by a few people who have special access to the system and are required to maintain the confidentiality of personal data.
    
    When you place an order or access personal data, we give you the option to use a secure server. All personal data or sensitive information you provide is encrypted into our database and only accessed for the above purposes.
21. You may decline any email or subscription offer from us by following the instructions we provide in such offer.
22. Our Services are not intended for use by children under the age of 17 (seventeen) years or in accordance with certain age restrictions applicable to the use of our products and/or services("Minors"). We do not collect or maintain any personal data or non-personally identifiable information from Minors and any part of our Platform, or any other Services is not directed toMinors. As a parent or legal guardian, please do not give permission for children in your care to hand over personal data to us. In the event that the personal data of a Minor under your care is disclosed to us, you hereby consent to the processing of such Minor's personal data and accept and agree to be bound by this Privacy Policy on behalf of such Minor. We will close any account used specifically by the Minor and will delete any personal data that we believe was submitted without the consent of the Minor's parent or legal guardian or otherwise comply with applicable law.
23. If it is found at any time that a provision of this Privacy Policy is invalid or becomes invalid, unenforceable or unenforceable in a particular jurisdiction, the validity, enforceability and enforceability of any other provision of this Privacy Policy, or such provision of the Privacy Policy in any other jurisdiction, will not be affected, interfered with or cancelled in any way. Our failure to enforce or enforce any right and provision under this Privacy Policy shall not constitute a waiver of any other right or provision or circumstance.
24. If you have any questions regarding your personal data or this Privacy Policy, you may contact us through our Customer Care which is available daily, 24/7, at 0800-1-101-101 (Indonesian domestic calls), +6221-50867077 (international calls) or via our WhatsApp at +6281119191101 or the contact details contained on our website from time to time. Our customer service officers are ready to answer your questions. Your conversation with Customer Care will be recorded. However, were serve the right to refuse or not process your request as long as permitted by law.
25. We reserve the right to change this Privacy Policy from time to time. You will be notified if there are changes in accordance with applicable laws.
26. This Privacy Policy and any non-contractual obligations arising out of or in connection with it are governed by the laws of the Republic of Indonesia.
27. This Privacy Policy is compiled and will be an integral part of the Terms and Conditions of use of the Honest application.
28. You have read this Privacy Policy to the end. You understand that by clicking "Agree" or any other button of the same nature, you confirm that you have read, have understood the clause of the agreement and confirm the understanding of the clause of the agreement and provide an electronic consent that has the same power as a wet signature.
29. This Privacy Policy has been adjusted in accordance with the personal data protection laws in Indonesia, the provisions of the Otoritas Jasa Keuangan and the provisions of Bank Indonesia in force as of the date of this Privacy Policy.