PRIVACY POLICY

1. Personal data is all true and real information that can be used to identify you. PT Honest Financial Technologies ("Honest"/"we") understands that your personal data is important. What we can learn about you will help us in providing a better service for you.
2. We will protect your data. This Privacy Policy ("Privacy Policy") explains how we protect the confidentiality of your personal data in accordance with personal data protection regulations in Indonesia ("Law").
3. Please read this Privacy Policy to understand how we collect, process and store your data.
4. This Privacy Policy is binding upon your consent.
5. Personal data we collect
   
   We collect the following information about you:

1. Personal information you provide when you use or make applications for our products or services, including your name, address, national identification number, place and date of birth, email address, nationality, and biometrics;
2. Communication data, including your communication and marketing preferences;
3. Financial information, including card information, account information, transactions using our products, and all data related to our products and services;
4. Technical data and related information, including cellular networks, installed applications, operating systems, IP addresses, mobile phone technology, and other device data;
5. Usage data, including how you use our products and services;
6. Information we may access with your permission, including geolocation and photos from your camera;
7. Information from third parties that may assist us in providing products and services or complying with Legal requirements; and/or
8. Other information we require with prior notice to us collects.

6. When we collect your personal data
   
   We collect your personal data when:

1. You gave it to us;
2. You use our products and services;
3. You interact with us;
4. You give permission for us to collect data for the benefit of the service; and/or
5. Required to comply with applicable law.

7. Source of your personal data
   
   We collect personal data from you. We may also collect your data from third parties including our partners, public domains, websites, cookies, behavior or location tracking tools, banking services, or other financial services.
8. Purposes of our use of your data
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   We may use, transfer and/or disclose your data to:

1. Process your application for our products or services;
2. Check your credit or credit score or reports related to your creditworthiness;
3. Provide, operate, and maintain our products and services, including fulfilling requests and communicating with you;
4. Develop, improve and design our products and services;
5. Meet our internal operational and compliance requirements, including risk management, tests, audits and administrative matters;
6. Develop credit and risk score models;
7. Develop or maintain your credit history;
8. Assist other financial institutions in conducting credit checks;
9. Manage, enforce and fulfill your rights and obligations with us and vice versa;
10. Market our products and services or otherwise;
11. Comply with laws and regulations applicable to us or requests from or audits by regulatory authorities;
12. Provide you with materials, content or invitations;
13. Communicate with you, including providing notices;
14. Conduct research, analysis or surveys in connection with our services or products;
15. Prevent, investigate or report fraud or illegal activities;
16. Carry out corporate actions including but not limited to acquisitions, mergers, mergers or separations; and/or
17. Other purposes related to the above.

9. Disclosure of Information to Third Parties
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   We maintain the confidentiality of the data we hold for the purposes stated in Clause 8 above, but we may provide this data or information to other parties for the above Purposes, including when you start the application process for our products. Such other parties include:

1. Affiliated or related entities, including our subsidiaries or parent companies;
2. Service providers, agents or contractors, including telecommunications, verification companies, KYC vendors, data analytics vendors, or cybersecurity vendors;
3. Financial institutions, payment system operators, payment infrastructure operators;
4. Third party financial institutions, insurance companies, credit card companies or merchants, securities and investment service providers;
5. Companies or credit information management institutions;
6. Collection agencies or collection service companies;
7. Marketing agency;
8. Transferee of any or all of our business or assets associated with you;
9. Any third party that guarantees your obligations;
10. Reward, loyalty, co-branding, or privilege program providers;
11. Authorized agencies within or outside Indonesia;
12. Purchasers or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets;

10. We may transfer your personal data outside Indonesia for the above Purposes in accordance with the laws and regulations applicable to personal data and those applicable to us.
11. We may retain and you hereby consent to the retention of your data after our business relationship or interaction ends for purposes stated in Clause 8 of this Privacy Policy. The data we retain includes, but is not limited to, your personal information, data relating to customer due diligence, data relating to the use of our Platform or service, financial transactions relating to us, and communication between you and us.
12. Cookies Policy
    
    Cookies help us understand and improve your browsing experience . Cookies are small data files on your device that capture your interaction with our Platform. Cookies are generally used to learn about your activity on our Platform and remember your preferences so that we can recognize you when you visit.
    
    We may use several types of cookies:

1. We use necessary cookies to check whether you have cookies enabled in your settings so that temporary information can be transferred between different pages  of our website and does not need to be entered repeatedly.
2. Functionality cookies help us recognize you each time you visit our website, so we can tailor content based on your preferences and other details.
3. Analytical/performance cookies help us collect statistics, such as the number of new and repeat visits to our website. This information is used to understand how you use our website so that it is more intuitive.
4. Targeting/advertising cookies record your visit to the website, your response to our online advertisements and the pages and links you visit so we know what you like.
5. Third-party cookies may be installed on your device by us or third parties on our behalf. These cookies may be managed by well-known advertising networks and external service providers, such as Google or Facebook. Your browser information is shared with such third parties (but does not include your personal information). Most of these cookies are analytical/performance or targeting/advertising cookies.

10. You can block cookies by changing the settings in  your web browser. However, some features on our Platform may not be usable if cookies are blocked.

13. This Privacy Policy does not apply to third party websites located on or connected to our Platform, which have their own privacy policies. We are not responsible for the content of such third party websites.
14. We do not guarantee the security of personal data and/or other information you provide on third party websites, but we have implemented various measures to maintain the security of your personal data that we hold or control. Your personal data is protected by a secure network and can only be accessed by a few people who have special access to the system and are required to maintain the confidentiality of personal data.
    
    When you place an order or access personal data, we give you the option to use a secure server. All personal data or sensitive information you provide is encrypted into our database and only accessed for the above purposes.
15. Please contact us to update or access your personal information in accordance with our procedures and applicable law.
16. Please contact us to withdraw your consent regarding personal data. However, we may terminate our relationship if you revoke that consent. This means you can no longer use our services.
17. You may decline any email or subscription offer from us by following the instructions we provide in the subscriptions.
18. If you have any questions regarding your personal data or this Privacy Policy, you can contact us through our Customer Care which is available every day, 24/7, at 0800-1-101-101 (Indonesian domestic calls), +6221-50867077 (international calls) or via our WhatsApp at +6281119191101. Our customer service personnel are ready to answer your questions. Your conversation with Customer Care will be recorded. However, we reserve the right to refuse or not process your request to the extent permitted by Law or if the request is detrimental to us.
19. We reserve the right to amend this Privacy Policy from time to time. You'll get a notification if there are any changes. The English version of the Privacy Policy is for reference only. The binding version is the Bahasa Indonesia version.
20. You have read this Privacy Policy. By using our Platform, you are giving electronic consent that has the same power as a wet signature.