Privacy Policy

PT. Duta Teknologi Kreatif (“DTK”) as the provider of DutaMoney and DutaPay services honor the affairs related to your Personal Data (as referred to in the prevailing laws and regulation) protection. Therefore we prepare this privacy policy (“Privacy Policy”) to explain to you how We (PT. Duta Teknologi Kreatif, DTK, DutaMoney and/or DutaPay, depending on the context) collect, process, use, disclose, share and/or delete (“Processing”) your Personal Data. 

This Privacy Policy is a series of rules that are an integral part of the Terms and Conditions of DutaMoney, DutaPay and/or other services, products that have existed and/or will exist in the future provided by DTK. This Privacy Policy is made as a basis for all of our activities in terms of Processing Your Personal Data. Definitions or terms that begin with capital letters contained in the Terms and Conditions page of DutaMoney, DutaPay and/or other services, products provided by DTK are considered to have the same meaning and interpretation as the terms used in this Privacy Policy, unless otherwise specified in this Privacy Policy.

By adhering to this Privacy Policy, you are also deemed to be bound by DutaMoney, DutaPay and/or other services of products Terms and Conditions provided by DTK that are (as applicable). Under no circumstances shall the invalidity of those terms and conditions render this Privacy Policy null, void, and/or unenforceable.

This Privacy Policy is applicable to you as DTK’s services users, job applicants and/or partners, vendors or suppliers. By reading this Privacy Policy, you acknowledge that you have understood this Privacy Policy and all its provisions.

  1. Personal Data that We Collect?

The Personal Data we collect varies depending on the situation in which it is collected and the type of Services and/or legal relationship you have with DTK. The data we collect includes, but is not limited to, the following:

Personal Data:

Information about you or other data combined to identify you.

  1. Individual Identification Data: name, national identification card (“KTP”), driver’s license (SIM), taxpayer identification number (“NPWP”), temporary stay permit card (KITAS), personal photo, family card (KK), user or other identification, educational certificates, skills certificates, date of birth, gender, religion, marital status, place of birth, nationality, occupation, mother’s name, source of income, and/or income amount;
  2. Business Entity Identification Data: business name, address, phone number, articles of incorporation, articles of association and amendments along with regulatory approvals, business permits, operational permits, structure of directors/management, board of commissioners/supervisors, shareholders, and identification of directors and commissioners (e.g., KTP, passport, KITAS), NPWP, and Business Registration Number (NIB);
  3. Contact Data: address (including postal code and city name), email address, GPS data, geo-location, phone number (including mobile number), and social media usernames or accounts. This information also aids in address verification and streamlining the Know Your Customer (KYC) process;
  4. Biometric Data: fingerprints and facial recognition used for authentication to access DTK services;
  5. Credential Data: this includes passwords, security hints, and similar security information used for account and DTK services authentication;
  6. Transaction History Data: information related to the history on the use of DTK’s services (transaction);
  7. Account Data: this includes account-related information such as transaction history, subscription packages, account numbers or name and initials;
  8. Interaction History Data: this includes your interaction history with  DTK, such as call recordings between you and DTK’s Contact Center personnel, emails, and messages via other communication media provided by DTK;
  9. Log Data: this includes records in our system such as device IP address, date and time of access, application features or pages viewed/browsing history, application workflow, other system activities, browser type, and third-party sites or services you used before interacting with our services;
  10. Cookies Data: this includes small text files stored in your browser. Details of data collected through cookies, web beacons, and other technologies are used for advertising purposes;
  11. Product and Service preferences: Certain activities when you tell Us such information, or Our assumptions about your preferences, based on how you use Our products and services.
  12. Advertising ID: used for advertising and promotional activities.
  13. Third-Party Information: information that we legitimately obtained from other sources, such as credit agencies, fraud prevention agencies, and other data providers, operating lawfully and with your consent. This includes demographic data, interest-based data, and internet browsing behavior.

B. When and How Do We Collect Your Personal Data?

  1. When you access our website and/or our application and/or use our services available on third parties’ application;
  2. When you register for an account to use our services or applying for job with us;
  3. When you contact and use our communication channels, such as but not limited to the Contact Center, live chat, email, and other communication media provided by us;
  4. When you use features that require access permissions on your device;
  5. When you are a customer of a company involved in corporate actions (mergers or acquisitions) with us, in accordance with applicable laws and regulations;
  6. When you visit our office premises equipped with CCTV devices;
  7. Through information that is obtained from third parties with a lawful basis for processing your Personal Data, provided we also have a lawful basis for processing it; and/or
  8. Through your information that is publicly available.

We collect your Personal Data only for the purposes of processing our services (including which we may provide in collaboration with third parties), product development and/or marketing activities for our services.

C. Use of Your Personal Data by Us

We will use your Personal Data to:

  1. identify your use of DutaMoney, DutaPay  and/or our other services;
  2. process the transactions you request;
  3. process and manage your account;
  4. prevent, detect and resolve criminal acts that may occur in the use of our services including but not limited to fraud, embezzlement, theft and/or money laundering;
  5. developing, adding and providing products to meet your needs;
  6. managing your Account administration
  7. conducting research on demographic data of users of Our services;
  8. developing, improving and providing Our services and the features therein;
  9. sending information that We consider useful to You including information about Our services (newsletters)after You have given Us consent that You do not mind being contacted regarding Our services;
  10. internal administrative purposes, such as; audits, data analysis, records in databases;
  11. communicate with you in connection with all matters concerning Our services, and/or features thereof; and
  12. maintaining the safety, security and continuity of our services and/or their features.

D. How Do We Store Your Personal Data?

The Personal Data we collect is stored in data storage facilities (data centers) managed by us and/or by third parties located within or outside the jurisdiction of Indonesia. All data storage facilities, infrastructure, and systems, whether managed by us or third parties, are equipped with security controls to ensure the protection of your Personal Data. 

Your Personal Data may be stored in printed copies or electronic formats.

The retention period for your Personal Data varies depending on the processing purposes we provide in this Policy and is subject to the applicable laws and regulations.

E. With Whom Do We Share Your Personal Data?

We share your information with other parties in order to provide our services and to improve your experience in using our services. In maintaining the security of your Personal Data, we will only share it with other parties who have a legitimate basis for processing and have implemented Personal Data protection efforts in accordance with applicable laws and regulations and the requirements that we determine.

We share your information with the following parties:

  1. our affiliated companies for the purpose of providing our services, services by our affiliated companies or processing data on our behalf;
  2. vendors, partners, suppliers, or third parties involved in authentication processes and the provision of our services;
  3. third parties assist us in providing information for identification, authentication, and due diligence (KYC) purposes, including fraud prevention agents, business assessment agents, or credit rating agencies, including banking institutions;
  4. public accountants and other audit institutions;
  5. law enforcement agencies, government institutions, regulators, courts, or other authorized parties, as required by law and with a lawful basis;
  6. third parties for promotional purposes, marketing, loyalty programs, events, or offers of our services and products; and/or
  7. third parties advertising with us to present offers to you, subject to the specific privacy policies of such services.

Fraud Management and Law Enforcement

We will disclose information when necessary to protect ourselves from fraud, safeguard our rights or property, or protect the interests of our Users.

We may also need to disclose your information to comply with law enforcement obligations, or for the legitimate interests of any subject in the context of national security, legal proceedings, litigation, criminal investigations or to prevent epidemics, emergencies declared by the government. Your Personal Data will only be provided if we, in good faith, believe that we are obligated to do so in accordance with applicable laws and regulations and based on a thorough evaluation of the provisions of the laws and regulations.

Mergers and Acquisitions

If we undergo a reorganization, are acquired by another company, or merge with another legal entity, your information will be shared with the relevant party. This transfer will be governed by confidentiality agreements between us and the third party. At that time, we will notify you and provide public information through our official communication channels.

Third Parties Collaborating with Us

If you access and/or use our services provided in collaboration with third parties or partners, we may need to exchange information with them as part of managing those relationships and your account—for example, to deliver the services and to help protect and secure our systems and Services.

If we contract service providers or contractors to provide Services on our behalf and they gain access to your Personal Data, we do not permit them to use or disclose your Personal Data except in connection with delivering our services which are being the object of the cooperation with them.

F. How Do We Protect Your Personal Data?

We have designed, implemented, and maintained an information security system in an effort to protect and secure your Personal Data from unauthorized access, modification, and disclosure and ensure the availability of data when needed. However, we cannot fully guarantee that your Personal Data will not be hacked, accessed, disclosed, modified, or destroyed by third parties who access our system unauthorizedly due to factors beyond our control.

You are responsible for maintaining the confidentiality of your account credentials, including but not limited to your password, one-time password (OTP), access to your email, malware or viruses that may attack your device.

G. Use of Cookies and Third-Party Services

Cookies are text files placed on your computer or device for record-keeping purposes. We use cookies to help us improve your convenience in accessing our services. Cookies will record your Personal Data such as the data you enter into our application and/or website. The Personal Data you previously provided will be displayed again when you use our services in the next occasion, so activating cookies will make it easier for you to use our services.

You can set your browser to disable cookies partially or completely, but when you disable cookies completely (including essential cookies), you may not be able to access all or part of our services and/or feature. In general, browsers have features to control most cookies. To learn more about cookies, including but not limited to managing, deleting and seeing what cookies are active, you are encouraged to visit  www.aboutcookies.org or www.allaboutcookies.org.

We reserve the right to use third party services to analyze your Personal Data for us, such as Google Analytics and other third party services for the purpose of developing our services. These third party services include, among others, collecting data from your visits and activities while accessing our services and using our features.

H. Your Rights as a Personal Data Subject

As the owner of Personal Data, you have rights concerning your data that are protected by the applicable laws and regulations, and we, as the Personal Data controller, are obligated to honour those rights. You may exercise your rights by contacting us through the contact information provided in this Privacy Policy by attaching proof of your identity and an explanation of your request. Below are your rights related to your Personal Data:

  1. Right to Update Personal Data

You have the right to complete, update, and/or correct any errors or inaccuracies in your Personal Data, through the application we provide or by contacting the Data Protection Officer via the "Contact Us" section of this Privacy Policy.

  1. Right to Access Personal Data

You have the right to request a copy of the Personal Data you have provided to us, through the application we provide or by contacting the Data Protection Officer via the "Contact Us" section of this Privacy Policy. The said access  will be provided at the latest 3 x 24 hours after we received the access request, as mandated by the prevailing laws and regulations of Personal Data Protection.

  1. Right to Cease Processing, Delete, and/or Destroy Personal Data

We store and process your data for as long as necessary to achieve the purposes described in this Privacy Policy and in accordance with the retention period required by applicable laws and regulations. You have the right to terminate the processing that we do or delete your data that we have (as long as it does not conflict with applicable laws and regulations) at the risk that you will not be able to use our services in full due to the minimum information that we need to provide our services cannot be processed. You have the right to destroy your data and your requests on such matters can be submitted by contacting the contact in the Contact Us section of this Privacy Policy.

  1. Right to Withdraw Consent for Personal Data Processing

You have the right to withdraw your consent to the processing of Personal Data that has been given to Us at the risk that you will not be able to use Our services in their entirety because the minimum information that We need to provide Our services cannot be processed. Our services cannot be processed. The withdrawal of Personal Data consent shall be made at the latest 3 x 24 hours after we received the withdrawal consent of Personal Data, as mandated by the prevailing laws and regulations of Personal Data Protection.

  1. Right to Opt-out of Marketing Information

We may from time to time provide promotions and offers to you in accordance with the lawful basis for processing. You have the right to withdraw consent to the processing of Personal Data related to marketing so that we do not share marketing-related information with you. You will still receive information related to our services and will still be able to use our services. You can withdraw consent to the processing of Personal Data related to marketing through the media that we provide from time to time or contact us via the contact information in the “Contact Us” section of this Privacy Policy.

  1. Right to Data Portability and Interoperability

You have the right to obtain and/or use your Personal Data provided to us in a commonly used or machine-readable format, such as transaction history. You may also transmit your Personal Data to other Personal Data controllers, provided that both systems can securely communicate under Personal Data Protection principles as defined by applicable laws.

  1. Right to Restrict Personal Data Processing

If you feel that the data we hold about you is inaccurate, or you believe we should not be processing your Personal Data, please contact the Personal Data Protection Officer to discuss your rights. In certain circumstances, you have the right to ask us to restrict the processing of your Personal Data. The restriction of Personal Data processing request either partially or entirely will be implemented at the latest 3 x 24 hours as of receipt of suspension and restriction of Personal Data processing, as mandated by the prevailing laws and regulation of Personal Data Protection.

  1. Right to Close an Account

We provide a means for you to close your account by contacting us.

You need to know that even if you are no longer a registered user, your Personal Data may still be stored for a period of time required by the applicable laws and regulations. However, we still provide you with limited access to access your Personal Data stored in Flip Application.

If you wish to exercise any of the rights above or file a complaint regarding how we use your Personal Data, please contact our Data Protection Officer as provided in the "Contact Us" section.

We reserve the right to deny your requests to access, correct, and/or delete, in whole or in part, your Personal Data in our possession if permitted or required under the applicable laws and regulations. 

I.  Transfer of Personal Data Abroad

In some of our processes (such as live verification of the pictures), we may transfer your Personal Data outside the jurisdiction of Indonesia. Storing infrastructure of such Personal Data in this matter will be located outside Indonesia and managed by third-party partners. We will always ensure the security of your data by ensuring: 

  1. that the country of the third-party partner receiving the Personal Data transfer has a level of personal data protection equivalent to or higher than that of Indonesia; or
  2. there is an adequate and binding personal data protection measures; or
  3. that you have consented to the transfer of Personal Data abroad by your consent to this Privacy Policy.

J. Automated Decision-Making

In the processes of analyzing Account registrations, processing the Transactions, providing promotions or offers, and fraud prevention activities, we may use automated decision-making (i.e., without human involvement), including profiling, which may result in certain legal consequences or directly impacting you.

You have the right to object to decisions made solely based on automated processing through the objection submission mechanism outlined in this Privacy Policy.

K. Provisions Regarding Minors

We do not intentionally collect Personal Data from minors. If you are under 17 years old, you need to ensure that you have obtained consent from your parents (father or mother) or your guardian based on the prevailing laws and regulations.

If we become aware that we collect Personal Data from minors without a valid consent,we will take certain measures to erase such Personal Data as soon as possible.  

L. Provisions Regarding Persons with Disabilities

If you are a person with a disability, we require consent from you and/or your guardian in accordance with the applicable regulations.

M. Website Privacy Policy and Other Services

We may provide you with a link to a third-party website, landing page, and/or other content pages. If you choose to browse or access those links to those websites, landing page, and/or other content pages, please be aware that such websites, landing pages, and/or content pages may be subject to a privacy policy difference from this Privacy Policy. We are not responsible for any risks or consequences that may arise from your access to such websites, landing pages, and/or content pages, as we have no control over them. We strongly recommend that you read and understand the terms and conditions, as well as the privacy policies of these third parties, which govern your rights when accessing their websites, landing pages, and/or content pages.

N. Updates and/or Changes to the Policy

We may update and/or amend this Privacy Policy from time to time. The updated version of this Privacy Policy will be uploaded on this website, the application and/or other appropriate and relevant locations which based on our assessment is appropriate to be used as a medium to notify you of such updates and/or amendments. If the changes to this Privacy Policy materially affect your personal data and information, we will notify you at least 30 (thirty) business days prior to the effective date of the changes, or within any other period as permitted by applicable laws and regulations (“Notification Period”).

If you do not agree with the updates and/or amendments to this Privacy Policy, you may submit an objection and have the right to close your Account during the Notification Period. If you do not raise any objections to the proposed changes to this Privacy Policy during the Notification Period, we will have the right to assume that you have agreed to the changes, and you will be bound by all the amendments determined by us.

O. Granting of Consent by You

  1. By agreeing to this Policy, you represent and warrant that the Personal Data you provide to us through is accurate, complete, truthful, updated data and based on the actual circumstances. Furthermore, you are fully responsible for the Personal Data and have full authority and/or personal rights to provide such Personal Data to us. You also release us from any civil claims or criminal charges from third parties that may arise from the misuse of information and/or misleading information related to the Personal Data you have provided to us.
  2. By agreeing to this Privacy Policy, you grant us the right to, from time to time, request authentication, verification, and/or updates to your Personal Data. This right is necessary to ensure that the data and information you have provided to us remains accurate, complete, truthful, and up-to-date. You also grant us the right to temporarily or permanently suspend, or to limit your access in using our services in the event that you have not completed the authentication or updates of your Personal Data.
  3. By continuing to access our services, you expressly consent to us to obtain and collect your Personal Data as outlined in this Privacy Policy. Furthermore, you declare that this consent is given voluntarily, in a competent state, and with full awareness.

P. Contact Us

Any questions you may have and/or requests to exercise your rights as set forth in this Privacy Policy can be directed to:

PT. Duta Teknologi Kreatif
Attn: Data Protection Officer

Graha Teknologi Kreatif

Jl.Raya By Pass Juanda Baru No.19, Sedati , Sidoarjo, Jawa Timur, 61253

dpo@dutamoney.co.id

Effective Date:  January 1, 2025

 

 

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