3. Penyelenggara dengan persetujuan dari masing-masing Pengguna (Pemberi Pinjaman dan/atau Penerima Pinjaman) mengakses, memperoleh, menyimpan, mengelola dan/atau menggunakan data pribadi Pengguna (‘Pemanfaatan Data’) pada atau di dalam benda, perangkat elektronik (termasuk smartphone atau telepon seluler), perangkat keras (hardware) maupun lunak (software), dokumen elektronik, aplikasi atau sistem elektronik milik Pengguna atau yang dikuasai Pengguna, dengan memberitahukan tujuan, batasan dan mekanisme Pemanfaatan Data tersebut kepada Pengguna yang bersangkutan sebelum memperoleh persetujuan yang dimaksud.

4. Pemberi Pinjaman yang belum memiliki pengetahuan dan pengalaman pinjam meminjam, disarankan untuk tidak menggunakan layanan ini.

5. Penerima Pinjaman harus mempertimbangkan tingkat bunga pinjaman dan biaya lainnya sesuai dengan kemampuan dalam melunasi pinjaman.

6. Setiap kecurangan tercatat secara digital di dunia maya dan dapat diketahui masyarakat luas di media sosial.

7. Pengguna harus membaca dan memahami informasi ini sebelum membuat keputusan menjadi Pemberi Pinjaman atau Penerima Pinjaman.

8. Pemerintah yaitu dalam hal ini Otoritas Jasa Keuangan,tidak bertanggung jawab atas setiap pelanggaran atau ketidakpatuhan oleh Pengguna,baik Pemberi Pinjaman maupun Penerima Pinjaman(baik karena kesengajaan atau kelalaian Pengguna)terhadap ketentuan peraturan perundang-undangan maupun kesepakatan atau perikatan antara Penyelenggara dengan Pemberi Pinjaman dan/atau Penerima Pinjaman.

9. Setiap transaksi dan kegiatan pinjam meminjam atau pelaksanaan kesepakatan mengenai pinjam meminjam antara atau yang melibatkan Penyelenggara,Pemberi Pinjaman dan/atau Penerima Pinjaman wajib dilakukan melalui escrow account dan virtual account sebagai mana yang diwajibkan berdasarkan Peraturan Otoritas Jasa Keuangan Nomor77/POJK.01/2016 tentang Layanan Pinjam Meminjam Uang Berbasis Teknologi Informasi dan pelanggaran atau ketidakpatuhan terhadap ketentuan tersebut merupakan bukti telah terjadinya pelanggaran hukum oleh Penyelenggara sehingga Penyelenggara wajib menanggung ganti rugi yang diderita oleh masing-masing Pengguna sebagai akibat langsung dari pelanggaran hukum tersebut diatas tanpa mengurangi hak Pengguna yang menderita kerugian menurut Kitab Undang-Undang Hukum Perdata.

10. Data pengguna/peminjam yang diajukan melalui aplikasi Cairin juga akan dilaporkan ke Fintech Data Center (FDC) atau Pusdafil.

11. Bahwa Penerima Pinjaman sudah mengetahui dan menanggung sepenuhnya risiko atas pemberian pinjaman;

12. Bahwa Penerima Pinjaman sudah mengetahui risiko kehilangan aset ataupun harta kekayaaan akibat gagal bayar;

13. Bahwa Penerima Pinjaman sudah mengetahui, mempertimbangkan dan menyetujui segala tingkat bunga dan biaya yang berlaku sesuai dengan kemampuan dalam melunasi pinjaman;

14. Bahwa Penerima Pinjaman diwajibkan untuk mempelajari pengetahuan dasar mengenai LPMUBTI sebelum memberikan pinjaman;

15. Bahwa setiap kecurangan dan tindakan ilegal dilaporkan sepenuhnya kepada Otoritas Jasa Keuangan (OJK) dan masyarakat luas sesuai peraturan perundang-undangan yang berlaku;

16. Bahwa catatan kredit Penerima Pinjaman akan dilaporkan secara berkala kepada Otoritas Jasa Keuangan untuk kepentingan Pusat Data Fintech Lending yang akan dimanfaatkan bersama dengan para pelaku industri perbankan nasional dan industri keuangan lainnya;

17. Bahwa Penerima Pinjaman sudah membaca dan mempelajari setiap syarat dan ketentuan.

Terms and Conditions of Use of the Site and Application:

Welcome to Cairin. Thank you for visiting the Cairin Site and/or App. 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 of the Cairin Site and Application (“Terms and Conditions”) which is on this page.

By accessing and/or using the Services on the Cairin Site and/or Application, you agree 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 documents -other documents related to explanations contained in the Site and/or Application. If you do not agree to these Terms and Conditions, please NO access and use the Services on the Cairin Site and Application.

We can change these terms and conditions at any time without prior notice. Decisions made based on these Terms and Conditions are absolute and cannot be contested.

1. DEFINITIONS AND INTERPRETATION

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

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

“ Application” means the Cairin mobile Application for android and IOS Application operated and owned by us.

“ Cookies” means the file used by Cairin's servers to identify your computer.

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

“ Services” means information technology-based lending and borrowing services through Sites and Applications that bring together Lenders and Borrowers organized by Cairin.

“ E-mail Service” means the e-mail service 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 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 that places funds in Cairin's account to be distributed as loans to Borrowers through the Site and/or Application.

“ Loan Recipient” means an individual who is an Indonesian citizen.

“ Forcing Circumstances Event” is an event when a situation or event beyond the reasonable control of a party affects the general public in the country or territory of that party, and which results in the party being unable to comply or perform timely obligations 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, physical natural disasters, epidemics, quarantine restrictions, and non-functioning 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 was established under the laws of the Republic of Indonesia as the 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 of age and has the necessary legal capacity, right, power and authority to agree to these Terms and Conditions; and

(b) an individual user who is an Indonesian citizen. Cairin based on certain considerations may give consent to you who are less than 21 years old.

2.2 You will use the Services contained on the Site and/or Applications only for lawful and not unlawful purposes.

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

2.4 Loan limit through the Site and/or Application can be made in the amount Rp 400,000 (Four Hundred Thousand Rupiah) up to Rp 3,600,000 (Three Million Six Hundred Thousand Rupiah),</ span> but if the prospective loan recipient meets certain requirements, we add a larger loan limit in accordance with other applicable terms and conditions.

2.5 Cairin does not charge any fees in connection with the application made by the prospective Loan Recipient to apply for a loan.

2.6 Cairin has the right to conduct due diligence on prospective Loan Recipients. During the process, Cairin will contact the relevant institutions, companies, or individuals to seek information, verify and confirm information regarding potential Loan Recipients, including (but not limited to) legal and credit historical records. Prospective Loan Recipients are required to give permission and authorization to Cairin to do these things.

3. MATTERS RELATING TO PERSONAL DATA

3.1 GENERAL

You hereby agree that Cairin may 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 applicable law.

We ensure that all personal data sent by you through 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 does not use the personal data for any purpose other than to provide loan facilities. However, this does not apply to:

(i) prevention of 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 at that time not known through any violation of applicable law;

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

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

(v) such personal data is disclosed in any litigation proceedings; or

(vi) a person who acts as a lawyer, co-worker or any third party that we authorize in accordance with legal provisions.

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

You agree to receive all documents, notices and agreements electronically arising from the use of the Services through the Site and/or Applications, including for Services as a Lender or as a Borrower. All consent from you to every document, notice and agreement electronically arising from the use of the Service through the Site and/or Application is given by signing electronically and is fully responsible and binding on you as a user of the Service through the Site and/or Application, either rights and obligations arising from the agreement.

4. PERSONAL DATA ACCURACY

4.1 You agree that by accessing the Site and/or Application and using the Service, you guarantee the authenticity and accuracy of the personal data you provide through the Site and/or Application. The Personal Data you provide is true, accurate, complete, up-to-date and not misleading.

4.2 You understand that you have an obligation to always:

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

(b) safeguard your passwords and personal data;

4.3 If Cairin finds, either directly or in the future, that the personal data you provide 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 arises or will arise, both material and immaterial, for any inaccuracies in the personal data you provide.

5. COOKIES POLICY

This Site uses Cookies, which you must agree to use in order to enjoy the full use of this Site. The cookies we use will record which parts of this 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 this configuration may interfere with some functions of this Site.

6. MATTERS RELATING TO INTELLECTUAL PROPERTY

6.1 The intellectual property rights of this Site and/or Application, including, but not limited to, copyrights, patents, including trademarks for and on behalf of Cairin are wholly owned by and are fixed assets of Cairin.

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

(a) all such copies are the intellectual property rights of Cairin and the third parties we license; and

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

6.3 You agree that you will not use any part of this Site and App to:

(a) insert or knowingly or unintentionally transmit or transmit a virus, worm, trojan horse, time bomb, trap door or computer code, file, or program or make repeated requests designed to disrupt, damage or limit the functionality of the software, or computer hardware, or telecommunications equipment, or to reduce the quality, interfere with the appearance of, or damage the functionality of this Site and Application;

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

(d) upload, e-mail or send a link to any content that violates the intellectual property rights of third parties;

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

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

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

(h) there are no links from other sites on this Site and Application which may enter without our prior written permission. You have no right to name, modify, or re-share content from this Site and App 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 through the Cairin Site and Application:

(a) Loan Terms and Conditions; and

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

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

8. CHANGES TO THE TERMS AND CONDITIONS

8.1 Cairin reserves the right to change the General Terms and Conditions at its sole discretion from time to time. Any changes to these Terms and Conditions will take effect immediately after Cairin has posted it on the Site and/or Application.

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

9. SEPARATION

If any terms or conditions in these Terms and Conditions in whole or in part are declared to any extent as invalid or unenforceable under the law or legal regulations, such terms or conditions or parts to that extent are deemed not to be part of These Terms and Conditions and the enforceability of any other terms and conditions in the Terms and Conditions will not be affected. Cairin's failure to exercise or exercise any right or provision of these Terms and Conditions does not constitute a waiver of such right or provision in such circumstances 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 when there is a violation of these Terms and Conditions, the Terms and Conditions of the Loan, or other Agreements with Cairin that will govern your use of the Service, caused by you.

10.2 Please note that messages sent via an internet connection cannot be fully guaranteed and may be intercepted, lost or modified. We are not responsible for messages that are lost, modified by third parties, or withheld and we are not materially liable to you or anyone else for any damage or other matters in connection with messages sent by you to us or us to you via an internet connection.

11. FORCING EVENTS

No party shall be liable for any failure to perform its obligations under these Terms and Conditions if such failure is caused by a Force Majeure Event. Always provided that whenever possible, the affected party will continue to perform the said obligation as soon as the Force Majeure Event causing the failure ceases or subsides.

12. INDEMNITY

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

13. TERMINATION

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

14. APPLICABLE LAW AND DISPUTE SETTLEMENT

These Terms and Conditions and any other non-contractual obligations arising out of 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 as a result in connection with the use of the Site and Application will be resolved and finalized at the South Jakarta District Court.

15. CONTACT US

For more 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 created to protect, protect and maintain the privacy and confidentiality of our Platform Users. Users are expected to read this Privacy Policy carefully before using the Services provided through the Platform. By accessing and using the Services on the Platform, the User acknowledges that he has read, understood and agreed to the contents written in this Privacy Policy.

1. DEFINITION/INTERPRETATION

In this Privacy Policy, in addition to those defined elsewhere in this Privacy Policy, the following terms will have their definitions, meanings and interpretations set out below:

“ You” with grammatical variations and cognate expressions, refers to the Borrower, Lender or other person who uses the Platform and/or Service, whether registered on the Platform or not.

“ Personal Data” includes all data, information, information and documents, both electronic and non-electronic but other than Emergency Numbers, from or regarding Users (both Loan Recipients and Lenders, according to the context ) and/or related parties of the User (including but not limited to family, colleagues, employees, companies or service providers of the User, if required) that IDana receives or accesses from the User, is proposed, given or disclosed by the User to IDana, according to the approval of the relevant User. and stored and managed in connection with the provision of Services on the Platform and for the use of Services on the Platform by Users.

“ Failure to Pay” is an event where the Borrower has violated the terms of payment of the Loan, including interest, fines, and other financial obligations under the Loan Agreement, for any reason, whether intentional or negligence, including among others, violating the schedule and/or amount of Loan payment as stipulated in the Loan Agreement and its changes from time to time (if any).

“ We” or “ iDana”, used according to the context, is PT iDana Solusi Sejahtera which is known by the trademark “iDana, which is a financial technology company that carries out business activities LPMUBTI through the Platform based on POJK No. 77/2016 to provide loans for loan recipients. We or iDana are employees and legal representatives of iDana.

“ Authorization” is the granting of power of attorney as referred to in Article 1792 of the Civil Code (“Civil Code”) from the Lender to iDana to represent and act for and on behalf of and in the interest of the Lender to:

(a) statement of agreement, design, negotiation, signing, implementation or restructuring of the Loan Agreement;

(b) collection of Loans from the Borrower based on the Loan Agreement, receiving and returning funds from the repayment of the Loan from the Borrower to the Lender; and

(c) other related actions that are reasonably necessary for the implementation of the Loan Agreement, compliance with POJK 77, related OJK circulars and laws and regulations that affect or need attention regarding LPMUBTI, Fund Distribution Agreements and Loan Agreement and fulfillment of the rights and obligations of the Lender based on the Loan Agreement.

“ Services” means financial services in the form of providing a Platform by iDana to bring together Lenders and Borrowers in order to carry out LPMUBTI activities related to lending to Borrowers.

“ LPMUBTI” is a Technology-Based Borrowing-Lending Service, otherwise known as peer-to-peer lending, to channel Loans from Lenders to Borrowers as the terms, conditions and implementation are regulated in POJK 77

“ Emergency Number” is the individual contact number listed by the Borrower when submitting an application for a loan to the Company through the Platform as a number that the Company can, has the right and will contact when the Borrower has been categorized as a Default. .

“ Inactive Emergency Number” is referred to in Article 3.4 of this Privacy Policy.

“ Platform” means the site and/or mobile version of the site created, owned and operated by iDana which is currently located at and can be accessed at the URL [www.idana.id] following URL changes it from time to time.

“ Lender ” is a party registered in the Platform to conduct funding in the form of granting and distributing Loans to Borrowers through the Platform.

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

“ User ” is the Lender as a party to the Loan Distribution Agreement and the Borrower as a party to the Loan Agreement registered in the Platform.

“ Loan Disbursement Agreement ” is an agreement between iDana and the Lender for the disbursement of Loan funds from the Lender to the Borrower through the Platform.

“ Loan Agreement ” is a written agreement agreed between the Lender, iDana and the Lender that governs, among others, the rights and obligations of the Lender and the Borrower, the terms and conditions of the Loan distribution from the Lender through iDana to the Borrower, and the mechanism and Authority, procedure of repayment or payment of the Loan together with its alterations, extensions and appendices.

“ Perkominfo No. 20/2016 ”is the Regulation of the Minister of Communications and Informatics Number 20 of 2016 on the Protection of Personal Data in Electronic Systems along with all implementing regulations, changes, amendments, modifications and/or additions made from time to time.

“ Loan ” is a loan facility (including interest, fines and other financial obligations) from the Lender that the Lender distributes to the Borrower through the Platform under the Loan Agreement.

“ POJK 77 ” is the Financial Services Authority Regulation Number 77/POJK.01/2016 on LPMUBTI along with all implementing regulations, changes, amendments, modifications and/or additions made from time to time.

“ UU ITE ” is Law No. 11 of 2008 on Electronic Information and Transactions as last amended based on Law No. 19 of 2016 together with all implementing regulations, changes, amendments, modifications and/or additions made from time to time.

2. INTRODUCTION

2.1 By obtaining a Loan from the Lender through iDana under the Loan Agreement and as long as the Borrower is still a party to each Loan Agreement and has financial obligations under the terms of the Loan Agreement, the Borrower is deemed to have agreed to all provisions of this Privacy Policy. regarding the use of the Emergency Number as regulated in Article 3 below all legal consequences voluntarily, without coercion or fraud and without the need for a formality or fulfillment of any procedure to enforce this provision legally.

2.2 The Borrower's Approval as referred to in Article 2.1 above, shall remain in force unconditionally and irrevocably until the expiration of the legal contract following all financial obligations of the Borrower under the Loan Agreement.

2.3 Electronic Lender Approval as referred to in Article 2.2 above is:

(a) is equated with approval as referred to in Article 1320 of the Civil Code as a condition of the validity of an agreement;

(b) is qualified as a valid legal evidence under Article 5 paragraph 1 of the ITE Law; and

(c) is an instrument of proof accepted as part of the concept of civil proof in court pursuant to Article 1865 of the Civil Law Code.

2.4 iDana has promoted transparency and intensive disclosure of the contents of this Privacy Policy, including the use of Emergency Numbers in the Application submission process as set out in Article 3 of this Privacy Policy, so that the Borrower is deemed to have thoroughly understood the contents of the Privacy Policy, as evidenced absolutely. from the receipt of the Loan by the Borrower through the Platform.

2.5 With the enactment of the provisions regarding the use of Emergency Numbers as set out in Article 3 of this Privacy Policy, iDana expects:

(a) The Borrower becomes a good consumer by fulfilling his promise and commitment to repay the Loan under the Loan Agreement, as iDana has fulfilled its responsibility to disburse the Loan efficiently, securely and effectively to the Borrower with full track record. transactions and the application process process recorded in the iDana information system and technology; and

(b) The Borrower becomes a consumer who has good faith in carrying out his responsibility to pay off the Loan in a timely and complete manner without being involved in any dispute related to Default with iDana, but all financial obligations of the Borrower related to the Loan fulfilled and completed so that the Borrower can be categorized as a responsible borrower in lending and borrowing activities that are also responsible (responsible lending) that comply with the provisions of the law and legislation.

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 obtained through the process including but not limited to filling out forms or data online contained on the Platform, information about devices, visits as well as the use of the Platform when the User accesses the Platform, and other information obtained through the Platform, e-mail, telephone or other media (if needed).

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

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

(b) perform risk assessment, statistical and trend analysis and planning, including carrying out data processing, statistical analysis, credit, risk and anti-money laundering, creating and managing credit scoring models, conducting credit checks and reviews and other backgrounds, and retain your credit history and your legal authorization for current and future reference;

(c) managing iDana'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 you an e-mail notification;

(e) contact you regarding your request;

(f) prevent and detect fraud, including but not limited to using voice detection technology to analyze recorded telephone conversations with us;

(g) for our general business purposes eg to verify your identity and your credit reputation;

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

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

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

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

(l) allows you to participate in our interactive feature services;

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

(n) handle any questions 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 the use of the Platform;

(p) survey, research, evaluation and/or product or service development by iDana or related interested parties;

(q) managing User's escrow account to the provider of the escrow account;

(r) conduct anti-money laundering and prevention of terrorism funds in the financial services sector;

(s) meet the legal, regulatory and compliance requirements that apply to iDana 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 government, regulatory agencies or authorized agencies

(u) notifies you of changes to the Platform and Services.

3.3 The 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 us.

3.4 We may disclose your Personal Data if:

(a) required by law;

(b) there is a legal process that is currently or will take place;

(d) is required by the authorized agency or party; or

(e) has obtained your written consent.

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

Personal Data Storage

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's Personal Data by iDana for a minimum period of 5 (five) years or as long as necessary to protect iDana's interests as deemed necessary or when required by law.

Security of Personal Data

3.8 We will take all reasonable steps and measures to prevent the 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 regularly test our systems to ensure that our security mechanisms are always up-to-date and that we fully comply with the applicable laws and regulations regarding data protection in Indonesia.

3.10 Regardless of the steps and precautions we take, we cannot provide full guarantees for the security of all forms of data sent to us via the internet where there are other parties who take or use us against the law 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 disclose the password to unauthorized parties. Unless you wish to log in to the Platform, we will never ask for your password.

Return and Destruction of Personal Data

3.12 The destruction of your Personal Data can only be done if:

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

(b) at your request, unless otherwise stipulated by the provisions of laws and regulations.

3.13 Destruction as referred to in Article 3.12 includes removing part or all of the documents related to your Personal Data which 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 an information update is required, the User can submit a written application 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 the Personal Data that has been provided to us with the following conditions:

(a) not being bound by an agreement in connection with the provision of Services on the Platform, both the Loan Distribution Agreement and the Loan Agreement;

(b) does not have any rights in connection with the provision of Services on the Platform, including but not limited to the right to claim for refund, repayment and settlement of receivables;

(c) has no obligation, financial responsibility, debt or the like in connection with the provision of Services on the Platform;

(d) is not in the process of submitting an application for a loan including the verification and evaluation process of the application by iDana; and

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

3.16 The request for return of Personal Data is submitted to us via electronic mail (e-mail) [cs@idana.id] by attaching 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 the deletion of Personal Data to iDana by giving written notification no later than 14 (fourteen) working days prior to the desired deletion date by stating the type or form of Personal Data requested for deletion, provided that the Personal Data to be deleted is including Personal Data that has been proven to have been obtained from, has been requested or required by iDana. The provisions for deleting Personal Data must be carried out in accordance with the provisions of Perkominfo No. 20/2016

4. USE OF EMERGENCY NUMBER

Purpose of Use of Emergency Number

4.1 The Emergency Number listed by the Borrower during the process of submitting an application for a loan ("Application") will be used by iDana specifically to contact the owner of the Emergency Number concerned when the Borrower is in a state of Default.

iDana's Right to Call Emergency Numbers

4.2 As an absolute condition for using the Loan through the Platform, the Borrower hereby allows iDana without requiring approval from any party, to contact the party as the owner of the Emergency Number ("Emergency Number Owner") in the event that the Borrower is in a state of Default, as may be notified by iDana, 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 cellular phone number registered and recorded on the Platform during the application submission process Application;

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

(c) requesting the Emergency Number Owner to deliver a message from iDana regarding the fulfillment of Loan repayment obligations and the state of Default.

4.3 iDana will contact the Emergency Number Owner for the above purposes either through, among others, direct telephone, SMS (Short Message Service), BlackBerry messenger, WeChat, or Whatsapp and other means as determined by iDana from time to time. In correspondence with the Emergency Number Owner, iDana will avoid all forms of intimidation, threats or other violations of law, including not sending photos of the Loan Recipient to the Emergency Number Owner.

Precautions Against “Inactive Emergency Numbers”

4.4 The Emergency Number listed by the Borrower in the process of submitting the Application so that it is recorded on the Platform is considered a "Non-Active Emergency Number" if however the Emergency Number:

(a) not also picked up, getting a response or response;

(b) is not registered, inactive, not working or permanently deprecated; and/or

(c) has changed hands to another third party who is not related to the Borrower or has been used by another party who claims not to know the Borrower.

iDana Disclaimer

4.7 The Borrower hereby releases, defends and does not harm and indemnify iDana and/or Lenders (along with employees, directors, commissioners, shareholders, representatives, proxies, agents and/or affiliates) from any losses, expenses, fees or costs arising out of or in connection with:

(a) dispute with third party regarding Emergency Number for any reason or cause of dispute;

(b) violation of rights or losses of third parties or any parties related to Emergency Numbers;

(c) sanctions, investigations or investigations, investigations, inspections or audits or any consequences of or related to violations of legal provisions and/or laws and regulations, government policies and/or decisions of any judicial or arbitration body as a result of or in connection with the exercise of iDana's rights in this provision or attempts to contact, access, search, obtain and/or utilize Emergency Numbers.

5. USER RIGHTS

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

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

(b) file a complaint in the context of resolving a Personal Data dispute over the failure to protect Personal Data by us to the Minister;

(c) get access or opportunity to change or update their Personal Data without disturbing the Personal Data management system, unless otherwise stipulated by the provisions of laws and regulations;

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

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

(f) determines 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 violation, violation or non-compliance with the Privacy Policy or the protection of Personal Data 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's Personal Data;

(b) where the Personal Data has been made available or can be discovered by the public before the Personal Data or such information is 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 that we provide, there is unauthorized access, hacking, abuse, modification, alteration, distraction;

(d) for the accuracy (except Personal Data which has been verified by iDana in accordance with its policies), the validity, legality and completeness of your Personal Data and is not required to notify you or any other party about it unless legally required; and/or

(e) where misuse of Personal Data and information is caused by any crime, fraud or criminal act or wrongful act of a third party which is not under our control or instructions.

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

(a) by including the reasons or causes for the failure of the confidential protection of Personal Data;

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

7. COOKIES

7.1 By visiting and using the Platform, you acknowledge that cookies may be installed on your device. Cookies are files that record information such as browsing traces of a site from a device or to collect internet log information and visitor behavior information. When you visit this Platform again, cookies will make it easier for us to customize the content according to your needs. These cookies do not track individual User information, and all of our cookie data is encrypted 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 refuse cookies by deleting cookies installed on your device at any time by configuring your search site software. You may not benefit from some Services on the Platform if cookies are deleted or prevented from being installed on your device.

8. SOCIAL MEDIA ACCESS

8.1 In order to provide Services on the Platform, we may ask you to give us permission to access social media accounts including but not limited to Twitter, Facebook, Path, Google+ and/or LinkedIn.

8.2 You are not required to provide access to your social media accounts. However, regarding the Service, you need to understand that access to your social media accounts can increase your chances of getting a cheaper loan with us.

8.3 In the event that you give us access to your social media account data, you should understand that we only use that data for the following purposes:

(a) identity verification;

(b) identity fraud risk mitigation;

(d) perform regulatory control;

(e) provides information and answers questions; and

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

8.4 We will not use your data for any 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 accounts including but not limited to your membership in iDana;

9. PRIVACY POLICY CHANGES

9.1 This Privacy Policy may be modified and/or updated from time to time. When we do, we will update and publish the latest version of this Privacy Policy on the Platform.

9.2 You are advised to carefully read and review this Privacy Policy from time to time to keep you informed of the latest changes to this Privacy Policy.

9.3 We may notify you of changes made to this Privacy Policy by e-mail to your registered e-mail address.

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

10. MISCELLANEOUS

We have compiled this Privacy Policy in accordance with the applicable laws and regulations, including but not limited to POJK No. 77/2016 and Perkominfo No. 20/2016.

11. CONTACT

If there are questions, comments and requests regarding the Privacy Policy, please address our Data Protection Officer at the email address [cs@idana.id].

Cairin

Pemberitahuan