Ximply application and website (hereinafter referred to as “We/Ximply”) are wholly owned and operated by PT Aplikasi Lintas Bangsa (hereinafter referred to as “Company”). Ximply upholds your privacy and protects your personal data. In order to provide you with more convenient services, we will collect, store, process, organize, use or disclose and/or delete or destroy your Personal information that we receive as Users or third parties (“Personal Data Processing”), based on the scope agreed in this Privacy Policy. This Privacy Policy applies to all persons and entities who access or use Our Platform and/or Services. Therefore, We advise You to read this Privacy Policy carefully, to help You understand how to protect Your Privacy rights. So that You can better understand this Privacy Policy, We will use “bold” typing to indicate the terms in this Privacy Policy that have or may affect Your interests. When you click the “Agree” button, you are deemed to have agreed to all the terms of this Privacy Policy and understand how to protect your personal information and agree to the legal use of your personal information.

The legal basis of this Privacy Policy is:

1. Law No.27 of 2022 concerning Personal Data Protection.
2. Law No.11 of 2008 concerning Electronic Information and Transactions which has been amended into Law of the Republic of Indonesia No.19 of 2016.
3. Regulation of the Minister of Communication and Informatics Number 20 of 2016 concerning Protection of Personal Data in Electronic Systems along with all implementing regulations, changes, amendments, modifications and/or additions made from time to time.

This Privacy Policy consists of the following provisions:

ARTICLE 1

DEFINITIONS

Other than as specified elsewhere in this Privacy Policy, the following terms will have the definitions, meanings and be interpreted as specified below:

1. “You” means referring to a person, business entity, as a User of the Ximply Platform and/or Services.
2. “Personal Data” means including all data, information and documents, both electronic and non-electronic, of or concerning the User and/or the User’s related parties (including but not limited to the User’s family, colleagues, employees, companies or service providers, if required) received or accessed by Us from the User, submitted, provided or disclosed by the User to Us, according to the relevant User’s consent and stored and managed in connection with the provision of Services on the Platform and in the context of utilization of Services on the Platform by the User.
3. “We” means PT Aplikasi Lintas Bangsa, a technology service provider company that offers businesses in Indonesia access to its proprietary Platform where businesses can, among other things, track, budget, and manage income and expenses through the Ximply application.
4. “Services” means services provided and/or provided through the ximply application/platform including products in the ximply application/platform.
5. “Platform” means (a) the web portal and/or mobile version of the web portal created, owned and operated by the Company currently located at and accessible at the following URL: www.XIMPLY.io and any changes to such URL from time to time; and/or (b) the mobile applications of Ximply created, owned and operated by the Company, including iOS and Android and any changes thereto from time to time.
6. “PDP Law” means Law of the Republic of Indonesia No.27 Year 2022 on Personal Data Protection.
7. “Perkominfo No.20/2016” means the Regulation of the Minister of Communication and Information Technology No.20/2016 on the Protection of Personal Data in Electronic Systems and all implementing regulations, changes, amendments, modifications and/or additions made from time to time.
8. “ITE Law” means Law of the Republic of Indonesia No.11 of 2008 on Electronic Information and Transactions as last amended by Law of the Republic of Indonesia No.19 of 2016.
9. “Electronic Signature” means a signature consisting of Electronic Information attached, associated or related to other Electronic Information used as a verification and authentication tool.
10. “Application Programming Interface” (API) is an interface that can connect one application with another application that acts as an intermediary between the various different applications contained in the Ximply Platform that we need to validate the personal data inputted on the Platform.
11. “Partner” is all of our business partners who cooperate with us and have a special engagement in the form of a cooperation agreement that provides services and additional benefits for You, so that You can use and enjoy, where in the use of these services, We, with Your consent, can process and transfer some or all of the personal data that You provide through Our Platform, to be used by Partners in providing their services to You according to Your choices and decisions.

ARTICLE 2

PERSONAL INFORMATION

COLLECTION AND ACQUISITION OF PERSONAL INFORMATION

1. As long as You access, use this application and Our services, You will provide Your personal information to Us and other information for the purpose of processing Your personal data and for other purposes as long as agreed by You in advance and based on applicable laws and regulations. Your Personal Information collected is as follows:

1. By using, visiting and registering this application, you will independently provide your Personal information to us, at the time of:

1. Creating or updating an account, including your name (username), email address, phone number, pin, password, address, photo, location and other information that identifies you as a User of the application;
2. Fill out an application form, using your identity, namely: full name, gender, identity card number, biometric information i.e. selfie, employment information, personal financial information;
3. Accessing our app, requesting access to your activities on your phone, namely the following: App Install, Camera, Microphone and GPS;
4. Using and accessing services on the app, related to products and services, how you view and interact with content, information you search for, content you view, and actions you take on the app;
5. Fill in payment data when you use services on the application, namely your account number; including but not limited to bank account data, virtual accounts, instant payments, internet banking, retail outlets; and / or other data in connection with products and services on the Platform;
6. Use features on the application that require permission to access relevant data stored on your device; and/or participate in surveys, assessments, or sweepstakes through the application and If you participate, we may request certain additional information from you.

2. Data recorded when you use our application, namely:

1. a unique identification number created by us associated with the installation of the software (“User ID”) at the time you register with the application and use the application to conduct transactions at merchants provided by us; real or estimated location data i.e. IP address and geo-location;
2. time-stamped data of any of your activities in connection with the use of the app, registration, login and transaction times;
3. usage data or your preferences, such as your interactions in using the app, saved choices and selected settings. Such data is obtained using cookies, pixel tags and similar technologies that create and maintain unique identifiers; and/or
4. log data, including records on the server that received the data, namely the IP address of the device, date and time of access, application features or pages viewed, application work processes and other system activities, browser type, and/or third party sites or services that you used before interacting with our application.

3. By accessing this application, you grant us access (i) to know your location while using this application and/or (ii) to know the transactions you make at the store merchant partners who are our Partners.

4. As well as data obtained from other sources during your access, use of our application; and at publicly available sources including but not limited to credit scoring agencies or bureaus, vendors, partners and other parties who provide services to us, perform tasks on our behalf, or with whom we will collaborate. In such cases, We will only collect Your Personal Information for or in connection with the purposes for which such third parties are involved or the purposes of Our cooperation with such third parties.

5. As well as data obtained from other sources during your access, use of our application; and at publicly available sources including but not limited to credit scoring agencies or bureaus, vendors, partners and other parties who provide services to us, perform tasks on our behalf, or with whom we will collaborate. In such cases, We will only collect Your Personal Information for or in connection with the purposes for which such third parties are involved or the purposes of Our cooperation with such third parties.

2. In order to provide you with better and more convenient services, including but not limited to the provision of our services, provision of information on our marketing promotions, dispute resolution, transaction security guarantees, provision of information related to service improvement, information regarding business scale expansion, cooperation with third parties, conducting user satisfaction surveys, etc., we will collect, store, process, organize, use and disclose your personal information by ourselves or to affiliated companies, third party cooperation agencies, credit agencies and other third parties that provide credit scoring services. We will use encrypted security systems to collect, store, process, organize, use and disclose your personal information.

THE USE OF PERSONAL INFORMATION

3. You agree that We reserve the right to store, process, organize, use, transfer and disclose the personal information that You provide through the above terms and conditions, including but not limited to:

1. Disclose your personal information in this app to provide services to you;
2. Acquire, assess, organize and store your personal information by manual or automated procedures;
3. Using your personal information to improve design, promotion, service provision, dispute resolution, transaction security assurance, improving service type or business scope, business scale expansion, and cooperation with third parties etc;
4. Use the contact information you provide to contact you and communicate information about services and management to you;
5. Analyzing Your personal information and providing information tailored to Your needs to third parties as Partners who provide services to You;
6. Transferring your personal information for the benefit of Our business partners in providing services that you choose and according to your needs; 
7. Conduct monitoring related to transactions made by users in terms of purchasing services or products provided and offered by Ximply on the platform;
8. Validate your requests, activities or transactions and increase the chance of getting approval for the services we provide. We may also use the information we collect to verify your identity as a User to prevent fraud, formulate statistical models related to credit scoring, formulate statistical models related to your phone usage patterns, contact you regarding the account you are using on our application, research the effectiveness of the application in conducting marketing, allow banks and other financial institutions to check your account on our application;

4. Assist Users when communicating with our customer service, including to:

1. check and address your concerns as a User;
2. directing your inquiries to the appropriate customer service personnel to address the issues;
3. monitoring and improving our customer service responses;
4. verifying your compliance with the terms and conditions governing the use of the Platform;
5. contacting you via email, telephone, WhatsApp, and other communication methods, including but not limited to, to assist and/or complete the transaction process or the process of resolving obstacles, as well as delivering news or other notifications in connection with the protection of User Personal Data by us, including failure to protect User Personal Data;
6. use information obtained from you as a User for the purpose of research, analysis, product development and testing to improve the security of services in the application, as well as develop new features and products; 
7. Survey, research, evaluation and/or development of products or services by us or related interested parties; and
8. inform Users regarding products, services, promotions, studies, surveys, news, latest developments, events and other information, either through the application or through other media. We may also use such information to promote and process contests and sweepstakes, award prizes, and present relevant advertisements and content about our services and our business partners.

DISCLOSURE OF PERSONAL INFORMATION

5. You acknowledge, understand, comprehend and agree that We may disclose or provide Your Personal Information with Our partners, vendors, and/or affiliates or third parties for purposes permitted by applicable laws and regulations, namely:

1. In order to provide or recommend services, products or provide more comprehensive services or to make your social experience more extensive, We will share such information with affiliated companies, parent companies, subsidiaries, branch companies, third-party cooperating institutions etc;
2. We may provide your Personal Data as a User to our business partners in accordance with your consent to use the business partners’ services, including applications or other sites that have integrated their APIs or services with each other;
3. in connection with the verification process that We believe is necessary before we register You as a user of the Service, including the know your customer process, conducting background checks, conducting credit assessments, eligibility assessments;
4. to third parties, including agents, vendors, suppliers, contractors, partners, and other parties who provide services to Us or You, perform tasks on Our behalf, or parties with whom We enter into commercial cooperation; and
5. in the event that We share Personal Information with Affiliates, We will do so with the intention that they assist Us in providing the Services, to operate Our business (including, when You subscribe to our mailing list, for direct marketing purposes), or for data processing purposes on Our behalf. All of our Affiliates are committed to processing the Personal Information they receive from Us in accordance with this Privacy Policy and applicable laws and regulations.

6. Where we disclose your Personal Data as a User to third parties, such third parties are obliged not to disclose or use it for purposes other than those for which you have consented to perform tasks in connection with one or more of the purposes as set out in this Privacy Policy.
7. When You breach the agreement with Us or Our other users, We will disclose Your personal information and breach of contract cases, blacklist Your breach of contract information and share the data with necessary third parties, as a review material for Us and third parties;
8. We aim to protect Our rights and legitimate interests in accordance with the requirements of legal regulations, judicial institutions and government authorities; and to ensure the integrity and operation of Our business and service systems;
9. We may disclose aggregate and non-personal information that we collect. Such disclosures do not include personal and non-public information regarding individual Users.
10. You expressly agree that this provision will not be invalidated if You stop using Our services.
11. In connection with the disclosure of Your Personal Information as referred to in section 2.5 above, We may disclose, display, transmit, perform data updates and provide Your Personal Information and other information related to You to other parties in connection with the purposes of providing the Services which include:

1. Credit information providers to obtain information on collectibility status or other financial information.
2. Financial Transaction Analysis Reporting Center (“PPATK”), if We identify suspicious financial transactions as stipulated in the statutory provisions regarding the prevention and eradication of money laundering and terrorism financing. The processing and retention period of Your Personal Information will be subject to policies determined solely by PPATK.
3. Law enforcement authorities in the Republic of Indonesia, including the Indonesian National Police, the Corruption Eradication Commission (“KPK”), the Courts, and so forth (collectively, the “Law Enforcement Authorities”) for any purposes related to law enforcement allegedly involving you (including, but not limited to cases of violations of the law, crime, money laundering, terrorism financing, corruption) which in this case must be officially and in writing requested by the relevant authorities. The retention period of your Personal Information will be subject to the policies determined solely by such Law Enforcement Authorities.

ARTICLE 3

USE OF COOKIES

To optimize access and provide more convenient services for You, when You visit Our websites, applications or when using Our services, We may identify Your identity to help You save time to log back in on these websites and applications, as well as help You determine whether Your account is secure. This digital data may be in the form of cookies, flash cookies or search engines or other storage-related devices (commonly referred to as “cookies”). You understand that when changing cookie settings, including but not limited to accepting or rejecting settings, this type of operation will affect access to this website and application and the security of the services We provide.

ARTICLE 4

SECURITY OF PERSONAL INFORMATION

1. We protect any User Personal Data stored in the system, as well as protect such data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security measures and procedures, including passwords and User OTP (One Time Password) codes.
2. When You login with your account, you can check and manage your account information. To ensure the security of your personal information, We guarantee to use industry practices to protect your data. We will implement various security measures with various physical, technical and appropriate controls to the maximum extent, so that your data will not be scattered, damaged, or lost, including but not limited to SSL, extra security storage, data center control, We also use strict controls that may be related to your data, including executive control and access to different levels and jobs, We are subject to data privacy protection laws in Indonesia and fully comply with and uphold any applicable regulations.
3. The confidentiality of your data and Personal Information is of utmost importance to us. We will apply best and reasonable efforts and measures to protect and secure Your Personal Information, as well as to prevent unauthorized access or disclosure of Personal Information or contrary to applicable law. However, We cannot fully guarantee that Our system will be completely impenetrable due to viruses, malware, interference or extraordinary events including unauthorized access by third parties. You acknowledge that We cannot guarantee the integrity and accuracy of any Personal Information that You transmit via the internet, or guarantee that such Personal Information will not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond Our control. You must not disclose Your account password to anyone and must always maintain the confidentiality of Your password and the security of the device You use.

ARTICLE 5

DATA STORAGE

1. All of your personal information data in Our Services will be stored securely for a limited period of at least 5 (five) years and as long as we need it to fulfill the purposes we described earlier, unless required by law.
2. Please note that there is still a possibility that some of Your Personal Information is stored by other parties including, Our Partners, vendors and/or affiliates or other third parties for certain purposes and in certain permitted ways. Information submitted through communication between users and service providers conducted other than through the Platform (such as through telephone calls, SMS, mobile messages or other means of communication) can also be stored in several ways.
3. We will not be responsible for the storage of Your Personal Information stored by other parties, and You agree to indemnify, defend and hold Us, Our officers, directors, employees, agents, partners, contractors and Affiliates harmless from and against any and all claims, losses, liabilities, costs, damages and expenses (including but not limited to legal fees and full indemnity expenses) resulting directly or indirectly from any unauthorized storage of Your Personal Information.

ARTICLE 6

COMPLAINTS RELATED TO PERSONAL DATA PROTECTION

1. If the User has concerns about our handling or treatment of the User’s Personal Data or if the User believes that his/her privacy has been violated, the User may contact us through our customer service or to our contacts listed in this Privacy Policy by explaining the identity and nature of the User’s complaint.
2. We will investigate the User’s complaint and endeavor to provide a response to the complaint within a reasonable period of time after receiving the complaint submitted by the User.

ARTICLE 7

DATA SUBJECT REQUESTS AND DELETION OF PERSONAL DATA

1. You have the right to request Us to delete the data collected by You in relation to Your Loan application. You can contact Us through various communication media including phone, chat, and email.
2. We will retain the information as long as your account as a User is active in accordance with the provisions of applicable legal regulations in Indonesia.
3. Users have the right to submit a data subject request to us as follows:

1. The right to obtain clarity of identity, the basis of legal interests, the purpose of requesting and using Personal Data.
2. The right to access his/her Personal Data.
3. The right to update or correct errors and/or inaccuracies in his/her Personal Data.
4. The right to withdraw consent to the processing of his/her Personal Data.
5. The right to erasure and/or destruction of his/her Personal Data.
6. The right to suspend or limit the processing of Personal Data in proportion to the purposes of the processing.
7. The right to obtain and/or use Personal Data about him/her from the Controller of Personal Data in a form that is consistent with the structure and/or format commonly used or readable by electronic systems.
8. The right to object to decision-making actions based solely on automated processing related to a person’s profile (profiling), which give rise to legal consequences or have a significant impact on Users; and/or
9. Other rights in accordance with the applicable laws and regulations.

4. The User may request the deletion of User information by closing the User’s account. We will only process such request if the User has no outstanding obligations to us. We reserve the right to refuse the request to delete User’s Personal Data processed by us if it is permitted or required based on the applicable legal provisions.
5. We will process the data subject’s request in accordance with the provisions of the applicable legal regulations in Indonesia.
6. We may retain archival copies of User data as required by law or as necessary to protect the rights of us or its users.

APPLICATION FOR DELETION OF PERSONAL DATA

7. Any request for deletion of personal data by you, must be submitted in writing through the communication channels established by us, namely through WhatsApp customer service and email.
8. Customer Service must explain and convey to you the procedures for deleting personal data, namely:

1. Customer must inform the complete Name and NIK;
2. Registered phone number; and
3. The Company only stores personal data for a maximum of 5 (five) years since the data is received by the Company;
4. Personal data that can be deleted are: customer data, loan data, contact data and payment-related data.

9. Submission of personal data deletion is directed directly to the Director of Operations, and is processed within a maximum period of 7 (seven) working days.
10. After the deletion of your personal data has been carried out, customer service can send a notification via WhatsApp and/or email to you.

ARTICLE 8

UPDATE

In order to serve you better, We may periodically update and revise our Privacy Policy in the future published on this page and, if necessary, we will notify you through this website and Platform, you understand and agree to the revised Privacy Policy. Before accessing this website and Platform, We encourage You to check, read and seek information regarding the privacy concerned.

ARTICLE 9

CONTACT US

If you have any questions and/or comments regarding our Privacy Policy, you may contact us via email: ___ and whatsapp ___ by including the words “Privacy Policy Terms” in the subject or body of the email.

ARTICLE 10

LIMITATION OF LIABILITY

You hereby release and/or discharge Us or Our Affiliates from all demands, claims and/or lawsuits arising in connection with, but not limited to: (i) granting access, obtaining, collecting, processing, using, analyzing, distributing, disclosing, displaying, and sending Your Personal Information as stipulated in this Privacy Policy or for other matters that have obtained Your consent from time to time, (ii) incorrect and inaccurate information that You provide to Us or Our Affiliates, (iii) not updating the data changes or Your Personal Information used for Service registration, and/or (iv) if You provide passwords to third parties.

ARTICLE 10

STATEMENT

We, as the owner of the Platform, declare that this policy takes effect from the moment you access the Platform. No other policy applies other than this policy.