3. The Operator with the consent of each User (Lender and/or Borrower) accesses, obtains, stores, manages and/or uses the User's personal data ('Utilization of Data') on or in objects, electronic devices (including smartphone or cellular phone), hardware or software, electronic documents, applications or electronic systems belonging to the User or controlled by the User, by informing the relevant User of the purpose, limitations and mechanisms for the Utilization of Data before obtaining the intended consent.

4. Lenders who do not have knowledge and experience in lending and borrowing are recommended not use this service.

5. Borrower must consider the loan interest rate and other costs according to their ability to repay the loan.

6. Every fraud is record digitally in cyberspace and can be known by the wider public on social media.

7. User must read and understand this information before making a decision to become a Lender or Borrower.

8. The government, in this case the Financial Services Authority, is not responsible for any violation or non-compliance by User, whether Lender or Borrower (whether due to the User's intention or negligence) of the provisions of statutory regulations or agreements or engagements between the Operator and the Lender and/or Borrower.

9. Every lending and borrowing transaction and activity or implementation of an agreement regarding lending and borrowing between or involving the Organizer, Lender and/or Borrower must be carried out through an escrow account and virtual account as required under Financial Services Authority Regulation 10/POJK.05/2022 concerning Information Technology-Based Co-Funding Services (LPBBTI) and violation or non-compliance with these provisions is evidence that a legal violation has occurred by the Operator so that the Operator is obliged to bear the compensation suffered by each User as a direct result of the violation of the law mentioned above without reducing the rights Users who suffer losses according to the Civil Code.

10. User/borrower data submitted via Cairin application will be reported as well to the Fintech Data Center (FDC) or Pusdafil.

11. That the Lender is aware of and fully bears the risks of providing a loan;

12. That the Borrower is aware of the risk of losing assets or wealth due to payment default;

13. That the Borrower has known, considered and agreed to all applicable interest rates and fees in accordance with their ability to repay the loan;

14. That the Lender are required to learn basic knowledge regarding (LPBBTI) before providing loans;

15. That every fraud and illegal act is fully reported to the Financial Services Authority (OJK) and the wider public in accordance with applicable laws and regulations;

16. That the credit records of Borrower will be reported periodically to the Financial Services Authority for the purposes of the Fintech Lending Data Center which will be used jointly with national banking industry players and other financial industries;

17. That the Borrower has read and studied each term and condition.

Terms and Conditions of Site and Application Usage:

Welcome to Cairin. Thank you for visiting Cairin Site and/or Application. Before accessing and/or using the Services on the Cairin Site and/or Application, make sure you read carefully and carefully the Terms and Conditions of Use for the Cairin Site and Application (“Terms and Conditions”) on this page.

By clicking, accessing and/or using the Services on the Cairin Site and/or Application, you agree in writing that you have read, understood, accepted and agreed to these Terms and Conditions and agree to be legally bound by these Terms and Conditions and other documents related to the explanations contained in the Site and/or Application. If you do not agree to these Terms and Conditions, please DO NOT access and use the Services on the Cairin Site and Application.

We can change these Terms and Conditions at any time without prior notification. Decisions taken based on these Terms and Conditions are absolute and cannot be contested. We encourage you to frequently review these Terms and Conditions for updates. If you do not agree to the updated Terms and Conditions, you must stop accessing or using the Services. Otherwise, you will be deemed to have agreed and will be subject to the updated Terms and Conditions.

By accepting these Terms and Conditions, you agree that these Terms and Conditions are legally binding on you as if this agreement was signed and made in writing by you.

1. DEFINITION AND INTERPRETATION

In these Terms and Conditions, unless expressly stated otherwise, the following expressions have the following meanings:

“You” is every prospective Lender, prospective Borrower, Borrower, Lender or user who uses the Cairin Site and/or Application Services.

“Application” means the Cairin mobile application for Android and IOS applications operated and owned by us.

“Cookie” means a file used by Cairin servers to identify your computer.

“FAQ” means Frequently Asked Questions on the Cairin Site.

“Service” means the Information Technology-Based Co-Funding Services through the Site and Application that brings together Lender and Borrower which organized by Cairin.

“E-mail Service” means the e-mail service that we provide to you, which can be accessed by sending an e-mail to cs@cairin.id.

“Live Chat Services” means the live chat services we provide to you, which can be accessed through our Site.

“Telephone Service” means the telephone service that we provide to you, which can be accessed by calling 021 - 24163377.

“OJK” means the Financial Services Authority of the Republic of Indonesia.

“Lender” means a company, institution or individual who places funds on Cairin account and to be distributed as a loan to the Borrower through the Site and/or Application.

“Borrower” means an individual who is an Indonesian citizen.

“Force Majeure Event” is an event when a condition or event beyond the reasonable control of a party affects the general public in that party's country or territory, and which results in the party being unable to comply or perform its obligations in a timely manner under these Terms and Conditions. Such circumstances or events include industrial action or labor disputes, civil unrest, war or threat of war, criminal or terrorist acts, governmental acts or regulations, telecommunications or utility failures, power outages, fires, explosions, natural physical disasters, epidemics, quarantine restrictions, and non-functioning of public transportation.

“Site” means the website www.cairin.id, including all domains and sub-domains operated and owned by us.

“Cairin” or “We” means PT Idana Solusi Sejahtera which established under the laws of the Republic of Indonesia as a service provider.

2. GENERAL TERMS OF USE

2.1 The services contained in this Site and/or Application are intended for and used by:

(a) the individual user is at least 21 years old and has the legal capacity, rights, power and authority necessary to agree to these Terms and Conditions; And

(b) individual users who are Indonesian citizens. Cairin may based on certain considerations provide consent to those of you who are under 21 years of age.

2.2 You will use the Services available on the Site and/or Application only for lawful purposes and not contrary to the law.

2.3 All information, including but not limited to personal data that you provide is accurate and correct.

2.4 The loan limit via the Application can be made in the amount of IDR 100,000 (One Hundred Thousand Rupiah) to IDR 20,000,000 (Twenty Million Rupiah), however if the prospective Borrower meets certain requirements, we add a larger loan limit in accordance with other applicable terms and conditions, especially taking into account the funding facility limits which are adjusted to your ability to carry out transactions.

2.5 Cairin does not charge any fees in connection with applications made by prospective Borrower to apply for loans.

2.6 Cairin has the right to conduct due diligence on potential Borrower. While this process is going on, Cairin will contact relevant institutions, companies or individuals to seek information, verify and confirm information regarding prospective Borrower, including (but not limited to) historical legal and credit records. Prospective Borrower must provide permission and authority to Cairin to do these things.

3. MATTERS RELATED TO PERSONAL DATA

3.1 GENERAL

You hereby agree that Cairin can collect, store, process, disclose information, access, review, and/or use personal data (including sensitive personal information) about you, whether obtained through you or through other sources in accordance with the law, includes but is not limited to accessing the camera, location and microphone on your device.

We ensure that all personal data sent by you via the Site and/or Application is properly protected and encrypted, including but not limited to the use of available SSL/TLS technology.

Cairin agrees to keep all personal data confidential and not to use such personal data for any purpose other than to provide loan facilities. However, this does not apply to:

(i) preventing acts of fraud and/or matters relating to anti-money laundering and criminal acts of terrorism.

(ii) personal data that is generally known to the public and is not yet known through any violation of applicable law;

(iii) the personal data was obtained legally by Cairin without violating confidentiality from other sources;

(iv) the personal data is required to be disclosed by law, government or authorized institutions under existing regulations;

(v) the personal data is disclosed in the course of any litigation; or

(vi) people acting as attorneys, colleagues or any third party authorized by us in accordance with legal provisions.

(vii) matters that are required based on statutory regulations.

By using the Services and accessing the Site and/or Application, you understand and agree that all forms of communication from Cairin regarding the Services to you via the Site and/or Application will be provided electronically either by e-mail, telephone or published via the Site and/or Application.

You agree to receive all documents, notices and agreements electronically arising from the use of Services through the Site and/or Application, including for Services as Lender or Borrower. All approval from you to every electronic document, notification and agreement arising from the use of Services via the Site and/or Application is given by electronic signature and is fully responsible and binding on you as a user of Services via the Site and/or Application, both rights and obligations arising from the agreement.

4. ACCURACY OF PERSONAL DATA

4.1 You agree that by accessing the Site and/or Application and using the Services, you guarantee the authenticity and accuracy of the personal data that you provide through the Site and/or Application. The Personal Data you provide is true, accurate, complete, up-to-date and not misleading. For any falsification of documents or other criminal acts committed by you, Cairin can take legal action including processing the action to the competent authorities.

4.2 You understand that you have an obligation to always:

(a) update and inform Cairin of any personal data that undergoes changes, immediately after such changes; And

(b) safeguard your password and personal data;

4.3 If Cairin discovers, either immediately or at a later date, that the personal data you have provided to Cairin is untrue, suspected to be false and/or inaccurate, then Cairin has the right to block your access to the Site and Application. You will be fully responsible for any damage and loss that has arisen or will arise, both material and immaterial, due to any inaccuracies in the personal data that you provide.

5. COOKIES POLICY

This Site uses Cookies, which you must consent to the use of to enjoy the full use of this Site. The cookies we use will record which parts of the Site you visit and for how long. You have the right to refuse the use of Cookies by configuring your web browsing. Please note that such configuration may interfere with some functions of this Site.

6. MATTERS RELATED TO INTELLECTUAL PROPERTY

6.1 The intellectual property rights of this Site and/or Application, including, but not limited to, copyright, patent rights, including trademarks for and in the name of Cairin are fully owned by and become permanent assets of Cairin.

6.2 You are permitted to view and copy-print on paper the content provided on the Site and Application, however:

(a) all such copies are the intellectual property rights of Cairin and third parties to whom we have licensed; and

(b) You do not alter in any way the paper copies of the printed materials, including the removal of any copyright or other proprietary notices contained in the Site and/or Application.

6.3 You agree not to use any part of this Site and Application to:

(a) insert or intentionally or unintentionally transmit or distribute viruses, worms, trojan horses, time bombs, trap doors or other computer code, files or programs or make repeated requests designed to interrupt, damage or limit the functionality of the software, or computer hardware, or telecommunications equipment, or to reduce the quality of, interfere with the appearance of, or damage the functionality of this Site and Application;

(b) upload, post, e-mail or otherwise receive, or attach links to any content that facilitates data hacking;

(d) upload, e-mail, or post links to any content that violates the intellectual property rights of any third party;

(e) circumvent or attempt to circumvent, any security measures of the Site and Application;

(f) allow any third party to do any of the above;

(g) if you use content from this Site and Application but fail to comply with these requirements, then your right to use this Site and Application will immediately disappear;

(h) no links from other sites on this Site and Application may enter without our prior written permission. You have no right to name, modify, or redistribute the content of this Site and Application without our permission.

7. OTHER APPLICABLE DOCUMENTS

7.1 In addition to these Terms and Conditions, the following also applies to your use of the Services via the Cairin Site and Application:

(a) Loan Terms and Conditions; And

(b) Other agreements with Cairin that will govern your use of the Services.

7.2 If there is a conflict between these Terms and Conditions and any other agreement that applies to specific aspects of the Services, that other agreement applies in relation to the specific aspects of the Services to which that agreement applies.

8. CHANGES TO TERMS AND CONDITIONS

8.1 Cairin reserves the right to change the General Terms and Conditions at its own discretion from time to time. Any changes to these Terms and Conditions will apply immediately after Cairin includes them on the Site and/or Application.

8.2 You understand and agree that when you continue to use the Services through the Site and/or Application after changes to these Terms and Conditions are made, you are subject to and bound by the new Terms and Conditions.

9. SEPARATION

If any term or condition in these Terms and Conditions in whole or in part is declared to any extent to be invalid or unenforceable based on laws or legal regulations, that term or condition or part to that extent is deemed not to be part of the Terms and Conditions and the applicability of any other terms and conditions in the Terms and Conditions will not be affected. Cairin's failure to exercise or enforce any right or provision of these Terms and Conditions does not constitute a waiver of that right or provision in that or any other circumstances.

10. LIMITATION OF LIABILITY

10.1 Cairin or its employees are not responsible and have no right to provide compensation and if there is a violation of these Terms and Conditions, Loan Terms and Conditions, or other Agreements with Cairin that will regulate your use of the Services, which is caused by you.

10.2 You need to know that messages sent via an internet connection cannot be guaranteed to be completely secure and may be delayed, lost or changed. We are not responsible for messages that are lost, altered by third parties, or suppressed and we are not materially responsible to you or anyone else for damage or anything else in connection with messages sent by you to us or us to you via an internet connection.

11. FORCE MAJEURE EVENTS

Neither party shall be responsible for any failure to carry out its obligations under these Terms and Conditions if such failure is caused by a Force Majeure events. Always provided that if possible, the affected party will continue to carry out the obligation as soon as the Force Majeure event that caused the failure ceases or subsides.

12. INDEMNIFICATION

You agree to release, discharge and indemnify Cairin, its affiliates, shareholders, directors, commissioners, employees, subcontractors, suppliers, agents from and for all forms of demands, lawsuits, claims, losses, damages, including legal consultant fees, caused by your violation of these Terms and Conditions and other provisions stipulated by Cairin.

13. COLLECTION MECHANISM

Cairin has the right to take all necessary actions in accordance with applicable provisions, including in carrying out billing either internally at Cairin, together with the Lender, or appointing a competent third party to carry out collection activities for Borrower in accordance with applicable law if the Borrower failed to make payments on all of his obligations in connection with his loan application. You need to know that based on your written agreement to these Terms and Conditions, the collection of Borrower’s loan via the Cairin Application is carried out by the Cairin team on Monday to Sunday including national holidays from 08.00 – 20.00 local time at the billing address or domicile of Borrower as provided via the Cairin Application.

14. RISK MITIGATION

You need to know that the risk mitigation that Cairin can do when there is a default in a Borrower’s loan application is by:

(a) carry out risk analysis submitted by the Borrower;

(b) verify the identity and authenticity of the documents of prospective Borrower and prospective Lender;

(d) facilitate the transfer of funding risk; And

15. TERMINATION

You agree that in the event of a violation by you of the provisions of these Terms and Conditions or of applicable law, Cairin can unilaterally and without prior notification delete your account on the Site and Application, limit your access to the Site and Application, terminate Service to you. You agree that all losses, whether material or immaterial, arising from deletion of your account and/or restriction of access as referred to above are entirely your responsibility.

16. APPLICABLE LAW AND DISPUTE RESOLUTION

These Terms and Conditions and any other non-contractual obligations arising from or in connection with them are governed by the laws of the Republic of Indonesia.

You agree that any legal action or dispute that may arise in connection with the use of the Site and Application will be resolved and decided finally at the South Jakarta District Court.

17. CONTACT US

For further information, you can visit our FAQ page or contact us via telephone service at 021 - 24163377, live chat service or e-mail service at cs@cairin.id

This Privacy Policy has been made to protect and maintain the privacy and confidentiality of User on our Platform. We hope that User has read this Policy Privacy carefully before using the Services provided through the Platform. By clicking, accessing and/or using the Services on this Platform, User agree in written that have read, understand, accept, and agree to the written content in this Privacy Policy. If you do not agree to this Privacy Policy, please DO NOT access and use the Services on the Cairin Site and Application.

By accepting this Privacy Policy, you agree that this Privacy Policy is legally binding on you as if this agreement was signed and made in writing by you.

1. DEFINITION/INTERPRETATION

In this Privacy Policy, other than as specified elsewhere in this Privacy Policy, the following terms will have the definition, understanding, and interpretation as determined below:

“You” with grammatical variations and cognate expressions, refers to the Borrower, Lender or other people who use the Platform and/or Services are whether registered on Platforms or not.

“Personal Data” includes all data, remarks, information and documents, both electronic nor non-electronic besides Emergency Number, from or about User (whether Borrower or Lender, in accordance to the context) and/or User’s related party (including but not limited to family, colleagues, employees, companies or User’s service provider, if required) which accepted or accessed by Cairin from User, submitted, given or revealed by User for Cairin, according to the User agreement which concerned and stored and managed in connection with the provision of Services on the Platform and in the event of utilization of Services on Platforms by User.

“Payment Default” is the event where the Borrower has violated the payment terms of Loans, including interest, penalties and other financial obligations based on the Funding Agreement, for any reason, whether intentional or negligent, including, among other things, violating schedule and/or amount of Loan payments as regulated in the Funding Agreement or the change from time to time (if any).

“We” or “Cairin”, used according to the context, is known as PT Idana Solusi Sejahtera with the paltform called "Cairin”, which is a financial technology company which is licensed and supervised by the Financial Services Authority and carry out business activities of LPBBTI through Platform which is subject to all provisions of laws and regulations related to LPBBTI including but not limited to based on Financial Services Authority Regulation No. 10/POJK.05/2022 concerning Information Technology-Based Co-Funding Services (POJK 10) and other related derivative regulations to provide loans to Borrower. We or Cairin are included the employees and proxies from Cairin.

“Power of attorney” is granting of authority as intended in Article 1792 of the Code Civil Law (“Civil Code”) from Lender to Cairin to represent and act for and on behalf of Lender’s interest to do:

(a) statement agreement, planning, negotiation, signing, implementation nor restructurisation of Funding Agreement;

(b) collecting the Loan from Borrower based on the Funding Agreement that has been mutual agreed, receive and return the funds from Borrower’s loan repayment to the Lender; and

(c) other related actions as necessary required for the implementation of Funding Agreement, compliance to POJK 10, circular letter from OJK and laws and regulations that affect or need to be taken into account regarding LPBBTI, agreements between Lender and Cairin and the fulfillment of rights and obligations of the Lender based on the agreement between the Lender and the Borrower.

“Service” is a financial service in the form of provision of Platform by Cairin to unite the Lender and Borrower in order to implement the LPBBTI activity related to the distribution of Loan to the Borrower. “LPBBTI” is an Information Technology-Based Co-Funding Services, or known with peer-to-peer lending, to distribute the Loan from Lender to Borrower according to terms and conditions and its implementation as regulated in POJK 10 and SEOJK 19.

“Emergency Number” is an individual contact number which included by Borrower when submitting the loan application through Platform as a number which can, has a right and with the approval by the owner of the emergency number to be contacted by Cairin when Borrower has categorized as Payment Default.

“Non-Active Emergency Number” is as intended in Article 4.4 of this Privacy Policy.

“Platform” is a site and/or mobile version of the site which made, owned and operated by Cairin which currently located at and can be accessed at the URL www.cairin.id with the changes of following URL from time to time.

“Lender” is a party registered on the Platform to provide funding in the form of giving and distribution Loan to the Borrower through Platform.

“Borrower” is a party registered on the Platform to receive funding in the form of loan from Lender through Platform.

“User” is the Lender as a party to the agreement between the Lender and Cairin and Borrower as parties to the agreement between Lender and Borrower which registered in Platform.

“Loan” is a loan facility (including interest, fines and other financial obligations) from Lender which distributed by Lender to Borrower through Platform based on the agreement between Lender and Borrower.

“POJK 10” is a Financial Services Authority Regulation Number 10/POJK.05/2022 concerning Information Technology-Based Co-Funding Services along with all the implementing regulations, change, amendment, modification and/or additions which made from time to time.

“SEOJK 19” is a Circular Letter of the Financial Services Authority of the Republic of Indonesia Number 19/SEOJK.06/2023 concerning the Implementation of Information Technology-Based Co-Funding Services.

“ITE Law” is Law no. 11 of 2008 concerning Information and Electronic Transactions as amend based on Law No. 19 Year 2016 along with all the implementing regulations, change, amendment, modification and/or additions which made from time to time.

“PDP Law” is Law No. 27 years 2022 concerning the Personal Data Protection along with all the implementing regulations, change, amendment, modification and/or additions which made from time to time.

2. INTRODUCTION

2.1 By obtaining the Loan from Lender through Cairin based on an agreement between the Lender and the Borrower and as long as the Borrower is still a party in any agreement between the Lender and the Borrower and has financial obligations according to the terms of the agreement between the Lender and Borrower, then based on the approval of this Privacy Policy, Borrower is deemed by law has agree to all of provision in this Privacy Policy specifically the provision of Emergency Number usage as set forth in Article 4 with all the legal consequences are voluntary, without coercion or fraud and without necessity any formality or fulfillment of any procedure to enforce this law provision.

2.2 The approval of the Borrower as intended in Article 2.1 above remains valid unconditionally and irrevocably until the end of the entire of the legal agreement along with the financial obligations of the Borrower based on the agreement between the Lender and Borrower.

2.3 Electronic Borrower’s approval as intended in Article 2.2 above is:

(a) equalized with agreement as intended in Chapter 1320 Civil Code as a legal condition agreement;

(b) qualified as law evidence which legitimate based on Article 5 paragraph 1 of ITE Law; and

(c) an instrument of evidence that is accepted as part of the concept of civil evidence in court according to Article 1865 of the Civil Code.

2.4 Cairin has put forward transparency and exposure intensively regarding the content of Privacy Policy including the Emergency Number usage in process of Application Requests submission as regulated in Article 4 of this Privacy Policy, so that the Borrower is deemed to have carefully understood the contents of the Privacy Policy, as absolutely proven by Loan acceptance by Borrower through Platform.

2.5 With the implementation of provisions regarding the Emergency Number usage as set forth in the Article 4 of this Privacy Policy, Cairin expect:

(a) Borrower become a good consumer which can fulfil promise and commitment to pay off the Loan based on agreement between Lender and Borrower, as Cairin has carried out its responsibility to disburse the Loan with efficient, safe and effective for Borrower with all the track records transaction and flow application submission process recorded on the Cairin information and technology system; and

(b) Borrower become consumer which have good faith in carry out its responsibility to pay off the Loan on time and complete without getting involved in any dispute related to Payment Default with Cairin, and all financial obligations of the Borrower related to Loan can be fulfilled and completed so that the Borrower can be categorized as a responsible Borrower in lending borrowing activities which also responsible (responsible lending) complies with legal provisions and regulation.

3. PERSONAL DATA

Use of Personal Data

3.1 While using the Service, we have the right to request, obtain, collect, store, manage and use your Personal Data (if necessary) obtained through processes including but not limited to:

(a) filling out forms or online data contained on the Platform;

(b) information about devices including the information about the application that installed by User. Contents of installed applications are application name, application package name, application installation time, application installation time. Purpose: To monitor and collect applications installed by users in order to identify and analyze their behavior and the risk of multiple loans and to analyze the existence of money laundering activities. If our automated detection model finds a risk while processing a transaction or approving a loan, it can reject the user's transaction

(d) other information obtained via Platform, e-mail, telephone or other media

3.2 You hereby consent that we have the right to request, obtain, collect, process, store and use Personal Data that you provide through the Platform which will be used for, but not limited to, the following purposes:

(a) assessment, analysis, verification, validation or examination of (i) applications or applications for obtaining loans; (ii) process or application for registration as a Lender or Borrower; and/or (iii) your profile;

(b) carry out risk assessments, statistical and trend analysis and planning, including carrying out data processing, statistical, credit, risk and anti-money laundering analysis, creating and managing credit assessment models, conducting credit and other background checks and reviews, and keeping history your credit and your authorized attorney for current and future reference;

(c) managing Cairin's relationship with you which may include providing you with information about the Platform and enabling you to use the Services provided by the Platform;

(d) send notification via electronic mail (e-mail) to you;

(e) contact you regarding your request;

(f) prevent and detect fraud, including but not limited to the use of voice detection technology to analyze recordings of your telephone conversations with us;

(g) for our general business purposes such as to verify your identity and credit standing;

(h) identify you when you contact us or visit the Platform.

(i) send marketing and non-marketing commercial communications to you;

(j) send electronic mail notifications or bulletins if previously requested by you;

(k) provide sufficient information on the Platform to identify you to Lender and/or Borrower;

(l) allow you to participate in our interactive features services;

(m) allow banks, financial bodies or authorized third parties to perform limited checks on your status in our database or the Services;

(n) handle inquiries or complaints made by or about you in connection with the Platform and stored to prevent fraud;

(o) verify your compliance with the terms and conditions governing use of the Platform;

(p) survey, research, evaluation and/or development of products or services by Cairin or related interested parties;

(q) processing the User's escrow account with the escrow account provider;

(r) carry out anti-money laundering and prevention of terrorism funding checks in the financial services sector;

(s) fulfill the legal, regulatory and compliance requirements that apply to Cairin and its Platform and Services based on applicable laws and comply with any applicable agreements in connection with the implementation of the Services;

(t) carry out orders or policies of the government, regulatory bodies or authorized agencies;

(u) notify you about changes to the Platform and Services; And

3.3 Personal Data submitted by you to us for the purpose of publication on the Platform will be used for that purpose in accordance with the consent you have given to us.

3.4 We can reveal your Personal Data if:

(a) required by regulation legislation;

(b) there is legal proceedings which currently or will ongoing;

(d) required by instance or authorized party; or

(e) has approved in written by you.

3.5 If you provide us with false or inaccurate information, or we suspect fraud, we may record this in your credit history and share the information with the appropriate legal entity or authorities and/or fraud prevention agencies.

Storage of Personal Data

3.6 All Personal Data that you provide and/or we receive in accordance with the Privacy Policy is stored securely in the territory of the Republic of Indonesia.

3.7 Storage of User Personal Data by Cairin is for a minimum of 5 (five) years or as long as necessary to protect Cairin's interests as deemed necessary or if required by law.

Personal Data Security

3.8 We will take all reasonable steps and measures to prevent loss, misuse or alteration of your Personal Data by unauthorized parties.

3.9 We further guarantee that all your Personal Data information submitted to us will be stored on our secure servers. Our security systems meet industry standards and we constantly monitor internet developments to ensure our systems develop as required. We also test our systems regularly to ensure our security mechanisms are always up to date and we fully comply with applicable laws and regulations regarding data protection in Indonesia.

3.10 Regardless of the steps and precautions we take, we cannot provide full guarantees regarding the security of all forms of data sent to us via the internet where other parties take or use us unlawfully and without our permission. We will do our best to limit access to Personal Data by unauthorized parties.

3.11 When registering on the Platform, you are asked to create your own personal password. You are responsible for maintaining the confidentiality of the password. We urge you not to share or reveal your password to anyone who are not interested. Unless you want to log in to the Platform, we will never ask for your password.

Return and Destruction of Personal Data

3.12 Destruction of your Personal Data can only be carried out if:

(a) has passed the provisions for the storage period for Personal Data, 5 (five) years or in accordance with the provision of regulations;

(b) at your request, unless otherwise determined by provision of regulations.

3.13 Destruction as in Article 3.12 includes removing part or all of the documents related to your Personal Data that we manage so that the Personal Data cannot be displayed again in the electronic system unless you provide new Personal Data.

Changes to Personal Data

3.14 We understand that you may need to update or correct your information from time to time. When information updates are required, User can submit a written request via electronic mail (e-mail) to us and provide us with the relevant details. We will help update and/or correct your information for you if we deem such changes necessary.

Return and Deletion of Personal Data

3.15 Users have the right to return Personal Data that has been provided to us with the following conditions:

(a) not being bound by an agreement relating to the provision of Services on the Platform, whether an agreement between the Lender and the Borrower or the agreement between the Lender and Cairin;

(b) has no rights in connection with the provision of Services on the Platform, including but not limited to the right to claim for returns, repayment and settlement of receivables;

(c) has no obligations, financial responsibilities, debts or similar matters regarding the provision of Services on the Platform;

(d) not in the process of submitting a loan application and the verification and assessment process of the application by Cairin; And

(e) not registered as an active User of the Platform (has deactivated the account).

3.16 Requests for the return of Personal Data is submitted to us via electronic mail (e-mail) cs@cairin.id by including valid proof of identity (copy of identity card or passport) along with the reason for returning the Personal Data.

3.17 Users have the right to request deletion of Personal Data to Cairin by providing written notification no later than 14 (fourteen) working days before the desired deletion date, stating the type or form of Personal Data for which deletion is requested, provided that the Personal Data to be deleted includes Data Individuals who are proven to have been obtained from, have been requested or required by Cairin. This provision for deletion of Personal Data must be implemented in accordance with the related provisions including the PDP Law.

4. USE OF EMERGENCY NUMBERS

Purpose of Emergency Numbers Usage

4.1 The Emergency Number entered by the Borrower during the process of submitting a Loan application ("Application") will be used by Cairin specifically to contact the owner of the Emergency Number concerned when the Borrower is in Payment Default by requesting prior approval from the owner of the Emergency Number regarding the inclusion of the number.

Cairin Rights to Call the Emergency Number

4.2 As an absolute condition for utilizing Loans through the Platform, the Borrower hereby permits Cairin with prior notification and/or approval from the owner of the Emergency Number, to contact the party as the owner of the Emergency Number ("Emergency Number Owner") in the event that the Borrower is in Payment Default, as may be notified by Cairin, for the purposes of:

(a) search for or trace the whereabouts of the Borrower in the event that the Borrower has not paid off the Loan and the Borrower cannot or is difficult to contact via the Borrower's mobile phone number which is registered and recorded on the Platform during the Application submission process;

(b) request assistance from the Emergency Number Owner to remind the Borrower to pay and repay the Loan; and/or

(c) ask the Emergency Number Owner to convey a message from Cairin regarding the fulfillment of Loan repayment obligations and circumstances of Payment Default, without do the collection to the owner of Emergency Number.

4.3 Cairin will contact the Emergency Number Owner for the above purposes either via direct phone, SMS (Short Message Service), or Whatsapp and/or other methods from time to time in accordance with applicable regulations. In corresponding with Emergency Number Owner, Cairin will avoid all forms of intimidation, threats or other violations of law, including in this case not sending photos of Borrower to Emergency Number Owner.

Step Anticipation To "Non-active Emergency Number"

4.4 Emergency Number which be included by Borrower in process of Application submission so that recorded on Platform considered as "Non-active Number Emergency" if the Emergency Number:

(a) not even raised nor obtaining a response;

(b) not registered, inactive, not functioning or permanently no longer used; and/or

(c) has changed to another third party who is not related to the Borrower or has used by other parties which confess not know the Borrower.

Liability Exempt of Cairin

4.5 The Borrower hereby releases, defends and holds harmless and indemnifies Cairin and/or the Lender (including employees, directors, commissioners, shareholders, representatives, proxies, agents and/or affiliates) from any losses, expenses, costs or costs arising from or in connection with:

(a) disputes with third parties regarding Emergency Number for any reason or causes of dispute;

(b) violation of the rights or losses of third parties or any party related to the Emergency Number;

(c) sanctions, investigations or probes, probes, inspections or audits or any consequences of or related to violations of legal provisions and/or statutory regulations, government policies and/or decisions of any judicial or arbitration body as a result of or in connection with the implementation of Cairin's rights in these provisions or attempts to contact, access, search, obtain and/or utilize the Emergency Number.

5. USER RIGHTS

In connection with the use of Services on the Platform, User have the right to:

(a) regarding the confidentiality of Personal Data and Emergency Number;

(b) submit a complaint in the context of resolving Personal Data disputes regarding our failure to protect Personal Data to the Minister;

(c) obtain access or the opportunity to complete, correct, change or update their Personal Data without disrupting the Personal Data management system, unless otherwise determined by statutory provisions;

(d) obtain access or the opportunity to obtain historical Personal Data that has been submitted as long as it is still in accordance with the provisions of laws and regulations;

(e) request the destruction of Personal Data that we manage, unless otherwise determined by laws and regulations; And

(f) determine the confidential and non-confidential classification of Personal Data (if required).

6. WAIVER OF LIABILITY

6.1 You agree not to hold us liable for any infringement, violation or non-compliance with the Privacy Policy or Personal Data protection in the following situations:

(a) where an act of nature or unforeseen circumstances has occurred, resulting in damage, damage or destruction of equipment and/or machinery used to secure, store or process User Personal Data;

(b) where the Personal Data was available or could be discovered by the public before the Personal Data or such information was submitted to us;

(c) where after every reasonable effort and effort has been made by us to verify, secure and protect the data and personal information we provide, there is unauthorized access, hacking, misuse, modification, change, interference;

(d) regarding the accuracy (except Personal Data that has been verified by Cairin in accordance with its policy), validity, legality and completeness of your Personal Data and is not obliged to notify you or any party regarding this unless legally required; and/or

(e) where the misuse of Personal Data and information is caused by criminal acts, fraud or any criminal acts wrongful actions of third parties which are not under our control or instructions.

6.2 We will make reasonable efforts to notify you in writing via electronic mail (e-mail) if there is a failure to protect the confidentiality of Personal Data in the management of the Platform, whether caused by us or when we find out about it from a third party who is managed with the following notification provisions:

(a) by including the reasons or causes for failure to protect the confidentiality of Personal Data;

(b) written notification via electronic mail (e-mail) to you no later than 14 (fourteen) days after the failure becomes known;

7. COOKIES

7.1 By visiting and using the Platform, you acknowledge that cookies may installed on your device. Cookies are files that record information such as search traces site from device or for gather internet logs information and visitor’s behavior information. When you visit this Platform again, cookies will make it easier for us to adapt content in accordance with your need. Cookies will not track the user’s individual information, and all our cookie data is encrypt and cannot be read by other Platforms.

7.2 Although your computer device will automatically accept cookies, you can choose to make modifications through your search site settings, by choosing to reject cookies by deleting the cookies installed on your device at any time by configuring your search site software. You may not receive the benefit from some Services on the Platform if cookies are deleted or prevented from being installed on your device.

8. OFFERING AND/OR MARKETING OF PRODUCTS AND SERVICES

You need to know that based on your written agreement to this Privacy Policy, we can offer you various products and services carried out by the Cairin team from Monday to Sunday including national holidays from 08.00 – 20.00 local time. If you choose not to accept the offer, please contact cs@cairin.id.

9. SOCIAL MEDIA ACCESS

9.1 In order to provide Services on the Platform for credit risk assessment purposes, we may ask you to give us permission to access social media accounts including but not limited to Instagram, Twitter, Facebook, Google+ and/or LinkedIn.

9.2 You are not required to provide access to your social media accounts. However, regarding the Services, you need to understand that access to your social media accounts can increase your chances of getting access to easy loans with us.

9.3 In the event that you provide us with access to your social media account data, you must understand that we only use such data for the following purposes:

(a) identity verification;

(b) mitigating the risk of identity fraud;

(d) exercising regulatory control;

(e) provide information and answer questions; And

(f) prevent fraud, money laundering and other criminal activities.

9.4 We will not use your data for other purposes not mentioned above including but not limited to:

(a) share or sell your data directly or indirectly to third parties;

(b) upload any information to or to your social media account including but not limited to your membership in Cairin;

10. PRIVACY POLICY CHANGES

10.1 This Privacy Policy may be changed and/or updated from time to time. When we do, we will update and publish the most current version of this Privacy Policy on the Platform.

10.2 You are advised to carefully read and check this Privacy Policy from time to time to keep yourself informed of the latest changes in this Privacy Policy. If you do not agree to the most recent Privacy Policy, you must stop accessing the Platform or using the Services. Otherwise, you will be deemed to agree and will be subject to the updated Privacy Policy.

10.3 By continuing to access and use the Platform and Services, the User is deemed to have agreed to the changes in this Privacy Policy.

11. MISCELLANEOUS

We have prepared this Privacy Policy in accordance with applicable laws and regulations including but not limited to POJK 10, SEOJK 19, ITE Law, PDP Law, and other related regulations.

12. CONTACT

If you have questions, comments and requests regarding this Privacy Policy, you can direct contact to our email address at cs@cairin.id

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