PRIVACY AND POLICY

This Privacy Policy applies to Services provided by TRUEMONEY Indonesia and sets out how we may collect, use and disclose User’s “personal data”, “personally identifiable information” or other personal information (collectively, “Personal Data”) in connection with User’s access to and use of the TRUEMONEY App.

As more fully described in the Terms and Conditions for TRUEMONEY INDONESIA (“Terms and Conditions”), TRUEMONEY App is an integrated services app designed by TRUEMONEY for users. TRUEMONEY App provides a gateway for registered Users of TRUEMONEY App to participate in a variety of activities, including accessing information or promotions, and making payments.

TRUEMONEY App is provided free of charge for registered users. TRUEMONEY Indonesia is a non-bank institution that has obtained licenses to perform stored value facility under supervision of Bank Indonesia as the authority. For more detailed explanation of this Privacy Policy regarding TRUEMONEY Indonesia, please read the relevant section in TRUEMONEY App.

From time to time, it is necessary for Users to provide us with Personal Data in connection with User’s access to and use of the TRUEMONEY App. By agreeing to the Terms and Conditions or by continuing to access or use the TRUEMONEY App, Users will be deemed to have agreed to and been notified of the terms of this Privacy Policy concerning the collection, use, process, storage, transfer, and disclosure of User’s Personal Data as set out in this Privacy Policy.

If a User does not provide such Personal Data to us, we will remain unable to provide such User with full Services in TRUEMONEY App nor to comply with any laws or guidelines issued by regulator or relevant authorities.

In this Privacy Policy, the word “including” shall not be limiting.

A. PERSONAL DATA COLLECTION

We may obtain User’s Personal Data from various sources (e.g. from User or through third parties), including:

1. Information obtained (directly or indirectly) about User’s mobile device or other item of hardware which are used to access the TRUEMONEY App (including User’s IP address, geographical location, browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term that the User use) (“Device Information”).
2. Information obtained (directly or indirectly) when User signs up for TRUEMONEY Account as a user of the TRUEMONEY App, including User’s name, date of birth, address, telephone number, and e-mail address (“Registration Information”).
3. Information obtained (directly or indirectly) during the TRUEMONEY Account usage, including User’s bank account numbers, billing and delivery information, transaction data, and other information from checks or money orders (“Account Information”).
4. Information obtained (directly or indirectly) when User utilize virtual account provided by TRUEMONEY Indonesia to receive electronic money and/or electronic wallet payment from payer, whether you are a service provider or Merchant, TRUEMONEY may collect certain information related to your utilization including but not limited to service and/or goods transacted, amount you collect from every transaction, withdrawal or settlement account details and withdrawal or settlement history.
5. TRUEMONEY may also collect your Personal Data from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with). In such cases, we will only collect your Personal Data for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be).
6. The above Device Information, Registration Information, and Account Information or other information may be accessed or collected (automatically or manually) at the time during User’s registration with TRUEMONEY account as a user of the TRUEMONEY App and/or during the course of User’s use of the TRUEMONEY App and TRUEMONEY account. The above information obtained by us may constitute User’s Personal Data. We have taken steps to ensure that we do not collect more information (whether or not such information constitutes Personal Data) from User than is necessary for us to provide User with our Services, to perform the functions set out in Part B of this Privacy Policy, to protect User’s TRUEMONEY account, comply with our legal obligations, protect our legal rights, and to operate our business.

B. USE OF PERSONAL DATA

We may use the Personal Data that we obtained about User for the following purposes:

1. Verifying User’s eligibility to use any of the features and functions of the TRUEMONEY App.
2. Processing User’s registration with TRUEMONEY account as User of the TRUEMONEY App, maintaining and managing User’s registration.
3. Providing User with services and related customer services regarding the use of User’s TRUEMONEY account, including, working in collaboration with TRUEMONEY Indonesia to facilitate the settlement of purchase price for goods and services, shipping, and related services for purchases, charge-backs, sending notices about User’s transaction, and responding to User’s queries, feedback, claims, or disputes.
4. Providing User with Services and related customer services regarding the use of TRUEMONEY App, which is to provide convenience for User in identifying other TRUEMONEY App Users when the User is checking its mobile phone contacts book through TRUEMONEY App.
5. Improving and expanding our offerings by way of research and development of new functions of the TRUEMONEY App or other new products and services that we may offer from time to time.
6. Conducting research, statistical analysis or surveys, whether orally or in writing, in order to manage and protect our business including our information technology infrastructure, to measure the performance of TRUEMONEY App and other services we offer and to ensure User’s satisfaction with our service.
7. Analysing trends, usages, and other behaviours (whether on an individualized or aggregated basis), which help us better understand how User and our collective User base access and use the TRUEMONEY App and the underlying commercial activities conducted, including for purposes of improving our Services and responding to customer queries and preferences.
8. Subject to having obtained User’s consent in accordance with applicable law and as contemplated in section D below, we may provide direct marketing information to User relating to services offered by us and our affiliates and selected third parties using User’s Personal Data to contact User, including by telephone, text (SMS), e-mail, and post.
9. Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing and/or solving fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our information technology platform.
10. Detecting, investigating, preventing or remediating violations of the Terms and Conditions, any applicable internal TRUEMONEY App policies, relevant industry standards, guidelines, laws or regulations.
11. Making such disclosures as may be required by any law or regulation of any country applicable to us or our affiliate, government official, or a third party, including any card association or other payment networks. Disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement in any country applicable to us or our affiliate (including anti-money laundering and counter-terrorist financing reporting requirements).
12. Making any disclosure to prevent any harm or financial loss, to report any suspected illegal activity or to deal with any claim or potential claim brought against us or our affiliate.
13. Any other legitimate business purposes, such as protecting Users from losses, protecting lives, maintain the security of our systems and products, and protecting any of our other rights and/or properties.

We also may use User’s Personal Data in other ways for which we provide specific notice at the time of collection or for which User have subsequently consented.

C. DISCLOSURE OF PERSONAL DATA

User’s Personal Data held by us will be kept confidential but we may provide such information to the following parties (domestically or abroad) for the purposes set out in B.1 to B.13 above:

1. TRUEMONEY account and other TRUEMONEY Services wholly or partly owned group companies.
2. Any agent, contractor or third party service provider that we work with in providing User with our Services, including for fraud prevention, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts, and payment extension services.
3. Entities with whom we maintain business referral or other commercial arrangements, including affiliated parties, third parties or entities which are engaged commercially with TRUEMONEY Indonesia.
4. Merchants and other organizations, such as payment networks or financial institutions, to or through whom these payments are made using the TRUEMONEY App, or other entities that allow TRUEMONEY App usage.
5. Third-party financial institutions, banks, collection agents and credit agencies.
6. Third-party marketing service providers.
7. Professional advisers, law enforcement agencies, insurers, government, and regulatory authorities or any other institutions to which TRUEMONEY Indonesia is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement, including arrangements with any card association or payment network.
8. Entities involved in any merger, acquisition, financing transaction or joint venture with us.

D. DIRECT MARKETING

As specified at B.7, TRUEMONEY may wish to use User’s Personal Data in direct marketing activities and will, in the future, obtain User’s consent with respect to the contemplated scope and manner for such direct marketing activities. Where User provides such subsequent consent, then please note that:

1. Certain Personal Data obtained by us from time to time may be used in direct marketing and promotion.
2. We may offer User promotion of goods and services which are considered relevant to User for which User’s subsequent consent will be specifically obtained. This may include goods and Services that are offered by us, any of our affiliates, our business partners or selected third parties, including any payment and financial products.
3. We may provide User’s Personal Data to certain third parties for use by them in marketing their own goods and Services, including (i) our affiliates, (ii) business partners and (iii) other third parties.
4. User’s consent to the use of User’s Personal Data for direct marketing purposes will be solicited by way of an opt-in checkbox or other positive indication of no objection.
5. If at any time User does not wish us to continue to use or provide to other persons User’s Personal Data for use in direct marketing as described above and in the relevant consent, then User may exercise User’s “opt-out” right by notifying us.

E. SECURITY MEASURES AND RETENTION

We take all reasonable steps, including technical, administrative and physical safeguards to help protect User’s Personal Data that we process, from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

We will retain and procure our service providers to retain User’s Personal Data only for so long as is necessary for the purposes set out in this Privacy Policy and in accordance with the Privacy Policy and all applicable regulatory requirements.

For registered users of TRUEMONEY account, User’s Registration Information and Account Information (if any) can be viewed and edited in the TRUEMONEY App through User’s TRUEMONEY account, which is protected by a password or PIN code. We recommend that User does not disclose its password or PIN code to anyone. Our personnel will never ask any User for its password in an unsolicited phone call or in an unsolicited e-mail. User should not save its log-in information (e.g., user ID and password) on shared or public computer.

F. THIRD-PARTY SERVICES AND WEBSITES

TRUEMONEY App may provide links to other websites and services (including apps operated by third parties) for User’s convenience and information. These services and websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest User to review before conducting any activities or using any of their services. For any linked websites which are not owned or controlled by us, we are not responsible for their contents, their privacy practices and the quality of their services.

G. CHANGES TO THIS PRIVACY POLICY

TRUEMONEY Indonesia reserves the right to review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice published on the Application and/or website, or otherwise to your e-mail address set out in your account. You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and that your continued use of the Application or website, communications with us, or access to and use of the services following any amendments to this Privacy Policy will constitute your acceptance to this Privacy Policy and all of its amendments.

H. MISCELLANEOUS

1. This Privacy Policy shall be subject to, governed, and implemented in accordance with the law of the Republic of Indonesia.

Any legal action or dispute that may arise in connection with this Privacy Policy, shall be settled in South Jakarta District Court or without prejudice to the right of TRUEMONEY INDONESIA to submit claim to other competent district courts in Indonesia. 

I. ACKNOWLEDGEMENT

By using TRUEMONEY App, Users acknowledge that Users have read and understood this Privacy Policy and agree to the usage, processing, and transfer of Personal Data as set forth in this Privacy Policy.

J. FURTHER INFORMATION

In accordance to User’s right under this Privacy Policy to access or correct User’s Personal Data or “opt-out” or if User would like to ask any questions or complaints, please contact the Customer Care below:

PT. Witami Tunai Mandiri
Millenium Centennial Center,
Level 36. Jl.Jend.Sudirman No.Kav 25,RT.4/RW.2,
Kuningan,Karet Kuningan,Kecamatan Setiabudi Kota Jakarta Selatan,
Daerah Khusus Ibukota Jakarta 12920

Contact Center: 0804-1000-100
Email: info@truemoney.co.id