PRIVACY POLICY

Recent Update: 12/2021

This Privacy Policy is part of PT Akulaku Silvrr Indonesia’s (“Akulaku”, “we”, “us” or “our”) commitment in the framework of protecting user’s privacy and personal data. In order to provide you with our best service while protecting your interest, we will only collect your information that We require. We will not process, analyze, store or share your information to any third party without your consent unless required as governed under the prevailing laws within the jurisdiction of the Republic of Indonesia (“Applicable Laws”).

We ensure the compliance of this Privacy Policy by us, our employees, our affiliates and the external service providers that work or otherwise carry out services for us. For this purpose, we have taken proper measures in accordance with the Applicable Laws.

In utilizing our services and/or products, you shall read and accept the “Terms and Conditions of Akulaku Application” of Akulaku’s services, which is an integral part of this Privacy Policy.

This Privacy Policy may be amended or updated from time to time and you are advised to read and check the Privacy Policy from time to time. We will always notify you in advance of any changes to this Privacy Policy via email registered on the Akulaku Application or by other reasonable means, including uploading a notification of such changes on the Akulaku Application. However, changes may take effect immediately without prior notice 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 have agreed to the changes in the Privacy Policy from time to time.

 

1.How we collect your data

1.1  Personal data that you submit to us voluntarily.

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

a.  Filling in the registration information including but not limited to name, address, telephone number,mobile phone number,email address, date of birth, occupation, financial record, installed applications, financial detail and history, and any personal data contained within the correspondence between you and us through email, telephone or physical letter correspondence, as well as other information we may require from time to time;

b.  Biometric data (through voice file, facial or other bodily feature) provided at the time you upload the biometric data on Akulaku;

c.  The data you provided while performing transaction and/or using Akulaku Credit Program available in Akulaku Application; and

d.  The data you provided through any platform, application or any other third party, based on your consent on such related platform or application as long as permitted by the Applicable Laws;

e.  Any information contained in the correspondence between you and us through email or physical correspondence;

f.  The information you provided at the time you submit feedback or complaint to Akulaku;

g.  The information contained in your decision through your approval if you decide to apply for our services or product;

h.  Your review or opinion on our service or product; and

i.  All data and/or information you provided to us voluntarily from time to time.

If the user objects and wishes not to share the above personal information/data, user may opt out or choose not to give consent to share such personal information/data. User may, at any time, contact Akulaku call center as elaborated in point 8 below if they wish to change their consent as to the use of their personal data.

 

1.2  Personal data that we collect automatically.

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

The Information shall contain of the following information, including but not limited to:

The Information stored in your device will be transmitted automatically to our website, application, and data server. Therefore, if you wish to deactivate the Information or delete your information that we collect automatically, you can do so through cookies clearing in your devices which you have the full control and rights over or you can delete the Akulaku Application.

 

1.3  Personal data 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 account or a third party application, including but not limited to Facebook and Google (“Social Media Account”), or you can link your Social Media Account with your Account on the Akulaku Application. Based on your consent and also the privacy policy of the provider of such Social Media Account we may collect the following data through your Social Media Account, including but not limited to:

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 such data, you can contact us through the contact information elaborated in point 8 below. However, please note that certain features may no longer be used by you in connection with the deletion of such data.

By downloading or using the Akulaku Application, you hereby provide consent to Akulaku to access the abovementioned information, without the necessity of obtaining any separate consent from you.

Aside from the abovementioned, we can also collect other information pertaining to you, your device or your usage of our website or application with your consent (if required by the Applicable Laws).

 

2.How we use your data

As a lawful trading platform application company which facilitates online sale and purchase activity that is compliant to the Applicable Laws, Akulaku has an interest in providing the best of its services and improving the efficiency of its application. Hence, we will use and process your personal data including but not limited for the following purposes:

Should you decide to procure our Affiliate’s or Partner’s financial product through our application, subsequently, we will use the data to initiate and maintain correspondence with you via electronic mail (e-mail), SMS (short message service), registered mail, phone calls and other proper measures as permitted under the Applicable Law.

Aside from the abovementioned, we may also use your personal data to protect and prevent fraud, claims, and other liabilities to comply with the Applicable Law when necessary. In this situation, we shall be granted the right to freeze, deactivate, or to take any appropriate measures towards your account with respect to the Applicable Law.

 

3.Who we may share your personal data with

To protect your privacy, we will not sell, rent, lease or disclose your information to any third parties without your consent. However, under the framework of facilitating you with a better service and product and for our operational needs, we may share your personal data with the following third parties:

a.  Our Affiliated companies. We may share your data to our parent company, subsidiaries, joint ventures, and other entity under our direct or indirect control (“Affiliates”), as permitted under the Applicable Laws from time to time, including but not limited to our data center at https://r.akulaku.net.In this regard, we shall use our best endeavor to procure those other entities to honor this Privacy Policy;

b.  Our Partner companies. We may share your data to third party companies that cooperate with us (“Partners”) in accordance with the financial product you applied for from our platform as long as permitted under the Applicable Laws.In this regard, we we shall use our best endeavor to procure those Partners to honor this Privacy Policy;

c.  Third Party Services Provider who have been appointed by us to act on our behalf to perform services and to ensure our functions and services run properly and efficiently. For the avoidance of doubt, we will not authorize such third party services provider to use such data for any other purposes;

d.  IT system management provider that utilized by us, who act on behalf of us to manage the IT system which may contain personal data;

e.  The payment system provider that appointed by us that shall nevertheless performed under the Applicable Law;

f.  Our advisors and insurers should there be any claims;

g.  Government institution, stock exchange agency or representative, or to respond to a request from law enforcement authorities under the Applicable Laws; and

h.  For the purpose of merger, sale, restructuring or asset transfer, we may transfer your data to our Affiliates, successor or new owner. For the avoidance of doubt, this action can only be implemented as permitted under the Applicable Laws. In this regard, we shall use our best endeavor to procure the aforementioned parties to honor this Privacy Policy; and

i.  Other third parties for the purpose of data and information utilization as mentioned above on section 2.

As long as permitted and in accordance with the Applicable Laws, we may transfer your data and/or information outside of its registered jurisdiction to achieve the operational objective as governed under this Privacy Policy.

 

4.Your data security

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

 

5.Websites provided by Third Party

In using our platform, you may find links which may redirect you to other websites belonging to third parties, whether our Affiliates’, Partners’ or other websites, of which this Privacy Policy does not apply over. Kindly read the privacy policy as provided by such third-party websites thoroughly, considering we will not be liable in any way towards such privacy policies.

 

6.Your rights as data owner

With regard to all data that you have voluntarily provided to us, and which we collect automatically as described in point 1 above, you have the following rights:

a.  Right to obtain information. You have the right to obtain information by asking us about your data that we store from time to time. Such information includes, among others, your data that we store, a list of names of third parties who receive your data from us, a list of names of third parties who have provided your data to us, in the case that we have received your data from other third parties.

b.  Right to rectify. 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 which was stored with us from time to time, on the following basis:

i.  You withdraw your consent to become a user on our platform;

ii.  Your data has been used unlawfully; and

iii.  Other factors that you deem to have violated your rights.

d.  Right to file a complaint to the authorities. You have the right to file a complaint to the relevant authorities. In this case, the complaint shall be addressed to the Directorate General of Consumer Protection and Trade Order, Ministry of Trade of the Republic of Indonesia, Consumer Complaint Service with the following channels:

through direct visit: Building I 3rd Floor, Jalan M.I. Ridwan Rais No. 5, Central Jakarta 10110

via whatapps contact number: 0853-1111-1010

via E-mail: Pengaduan.konsumen@kemendag.go.id

In connection with your request for information, correcting and deleting data, we will verify the authenticity of your identity before we process the request. Furthermore, we reserve the right to stop our services to you either in part or in whole after the deletion of your data on our platform is carried out.

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

 

7.Your consent

By registering as a user under our platform, you acknowledge to have read and understand this Privacy Policy as well as the Terms and Conditions of Akulaku Application, and therefore agree to all provisions under this Privacy Policy.

 

8.How to contact us

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

In compliance with the Privacy Policy above, We are committed to attend any request or concerns you might have with regard to your personal data. If you wish to withdraw your consent, delete, request access to, or modify the information that you have provided to us, please contact us at:

PT Akulaku Silvrr Indonesia

Sahid Sudirman Center Lt.18, Jl. Jend. Sudirman No.86, RT.10/RW.11, Karet Tengsin, Tanah Abang, Kota Jakarta Selatan, Daerah Khusus Ibukota Jakarta 10250, Indonesia

Email: cs.id@akulaku.com

Call Center: 1500920