The following Privacy Policy describes how we, Transfez (PT INDO KOALA REMITTANCE hereinafter referred to as "we") collect, store, use, process, control, transfer, disclose and protect your Personal Data, in accordance with all applicable laws, including the Personal Data Protection Act 2012 of Singapore. This Privacy Policy applies to all users of our website (www.transfez.com), services or products ("Applications"), unless otherwise set forth in a separate privacy policy.

By accessing and/or using Transfez services, the User represents that each User's Personal Data is true and valid data, and the User gives consent to Transfez to obtain, collect, store, transfer, manage and use such Personal Data as stated in the Transfez Privacy Policy and Terms and Conditions (“Consent”). Your Consent shall remain valid until such time as withdrawn by you in writing or, subject to Article 11, following the termination of your contractual relationship with us.

If you have any questions about how we protect or use your data, please send an e-mail to [email protected]

1. Data Protection

1. We are serious about guarding the security of your Personal Data and use a secure server to store your Personal Data. All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using Transport Layer Security technology.
2. However, we must tell you and you understand that there is no system that cannot be infiltrated by the unauthorized and irresponsible third parties. Therefore, you agree to waive, release and forever discharges us from and against any legal action, whether in civil or criminal proceeding in connection the successfull infiltration by the third parties (if any).
3. You may not disclose your password to anyone. No matter how effective a technology is, there is no impenetrable security system.
4. We restrict access of your Personal Data to those employees of Transfez who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of your information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Data from unauthorized access.

2. Information Collection

Transfez collects User data for the purpose of processing User transactions, managing and streamlining the process of using the Application, as well as other purposes as long as permitted by applicable laws and regulations.

We may collect and use the following data:

1. Information that you give us.
• You may give us information about you when you sign up to use our Services, e.g. when you provide us with personal details, such as name and e-mail address. This also includes information that you provide through your continued use of our Services, participate in discussion boards or other social media functions related to us, enter a competition, promotion or survey, and when you report a problem with our Services. The information that you give us may include your name, address, e-mail address, phone number, nationality, date of birth, financial information, transaction reason, and photograph.
• We may also need additional commercial and/or identification information from you e.g. if you send certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
• In providing the Personal Data of any individual (other than you) to us during you use of our Services, you promise that you have obtained consent from such individual to disclose your personal data to us, as well your consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy
• For the purposes of this Privacy Policy, “Personal Data” means “data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organization has or is likely to have access.
2. Information we collect about you. With regard to your use of our Services we may automatically collect the following information:
• details of the transactions that you carry out when using our Services, including geographic location from which the transaction originates;
• technical information, including the Internet Protocol (IP) address used to connect the computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products that your viewed or searched for; page response time, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
3. Information we receive from other sources. We may receive information about you if you use other websites we operate or other services we provide. We also work closely with third parties and may receive information about you from them, for example, the banks and payment service providers you use to transfer money to us; your beneficiary's payment service provider; business partners; technical sub-contractors, payment and delivery services; advertising networks; analytics providers; find an information provider; and credit reference institutions.
4. Information from social media networks. If you log in to our Services using your social media account (for example Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including name, profile image, and e-mail address. We use such information, together with any other information that you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy.

3. Cookies

Cookies are small files that will automatically take place on the User's device that performs the function of storing user preferences and configurations during a site visit. Such cookies are not intended to be used at the time of accessing other data that the User has on the User's computer device, other than those that the User has agreed to convey.

4. Uses Made of the Information

1. We use your information in the following ways:
• to carry out our obligations relating to your contract with us and to provide you with the information, products, and services;
• to comply with any applicable legal and/or regulatory requirements;
• to notify you about changes to our Services;
• as part of our efforts to keep our Services safe and secure;
• to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Services and to ensure that they are presented in the most effective manner;
• to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
• to allow you to participate in interactive features of our Services, when you choose to do so;
• to provide you with information about other similar goods and services we offer;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or
• to combine information that we receive from other sources with the information from you that you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
2. We may also use your personal data in other ways for which we provide specific notice at the time of collection or for which you have subsequently consented.

5. Use of Information

We may use Personal Data collected for the following purposes or for other purposes permitted by applicable laws and regulations ("Purposes"):

• to identify and register you as a user and to administer, verify, disable, or manage your account;
• to facilitate or enable any verification that we consider necessary before the service provider provides services to you or before we register you as a user, including conducting the Know Your Customer (KYC) process
• Checking and resolving User issues;
• Contact the User by email, mail, phone, and others, including but not limited to, to assist and/or complete the transaction process and the process of resolving obstacles.
• Monitoring or investigating suspicious transactions or transactions indicated to contain elements of fraud or violation of the Terms and Conditions or applicable laws, as well as taking the necessary actions as a follow-up to the results of monitoring or investigating such transactions.

6. Disclosure of Your Information

1. We may share your information with selected third parties including:
• affiliates, business partners, suppliers and sub-contractors for the performance and/or execution of any contract we enter into with them or you;
• financial institutions, banks, collection agents and credit agencies; to comply with credit card association rules requirements to be included in the list of discontinued Users (b) to comply with their anti-money laundering and counter financing requirements of terrorism or (c) if we believe that disclosing your information is necessary to help us prevent fraud or assess and manage operational or financial risks.
• Law enforcement, regulators, government officials, or other third parties in accordance with subpoenas, court orders, notices and regulatory guidelines, or legal proceedings or other requirements applicable to us or any of our affiliates when we need to do so to comply with law or credit card rules or when we believe, in our own policy, that disclosure of Personal Data is necessary to prevent physical loss or financial loss , report suspected illegal activity or to investigate violations of our Terms and Conditions
• advertisers and advertising networks solely to select and serve relevant adverts to you and others;
• analytics and search engine providers that assist us in the improvement and optimization of our site;
• our group entities or subsidiaries; and
• entities involved in any merger, acquisition, financing transaction or joint venture with us.
2. We may disclose your Personal Data to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreement and other applicable agreements; or to protect the rights, property, or safety of Transfez, our customers, or other party. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
• to prevent and detect fraud or crime;
• in response to a subpoena, warrant, court order, or as otherwise required by law;
• to assess financial and insurance risks;
• to recover debts or in relation to your insolvency; and
• to develop customer relationships, services, and systems.

7. ACCESS AND CORRECTION OF PERSONAL DATA

1. Subject to applicable laws and regulations, you may request that you access and/or correct your Personal Data under our ownership and control, by contacting us in the details provided below.
2. We reserve the right to refuse your request to access, or to correct, some or all of your Personal Data that we own or control where permitted or necessary under applicable law. This includes in circumstances where such Personal Data may contain references to others or where requests for access or requests to correct are for reasons we consider irrelevant, not serious, or troubling.

8. Your Personal Data Storage Location

The Personal Data that we collect from you shall be transferred and stored in the jurisdiction where we collect the Personal Data from, as regulated by applicable law. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We may also retain your Personal Data for as long as we deem necessary to comply with the Purposes, the terms of this Privacy Policy or in accordance with any applicable laws.

9. Sharing Your Data Outside the Jurisdiction where we collect the Personal Data from

1. In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties that are based outside the jurisdiction where we collect the Personal Data from as mentioned in Article 5 point 1 above. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
2. If you are a customer providing us Personal Data from Singapore, in the event that we and/or our services providers store, transfer or otherwise process your Personal Data outside of Singapore, we shall take steps to ensure that the Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and consistent with our personal data protection policies and practices. By accepting this Privacy Policy, you acknowledge that you have agreed and consented to us transferring, storing or processing your Personal Data in accordance with Article 9.

10. Profiling and Automated Decision Making

1. We may use some instances of your data in order customize our Services and the information we provide to you, and to address your needs such as country of address and transaction history. For example, if you frequently send funds from one particular currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take our best effort to ensure that your privacy and security are protected and we only use pseudonymized data where ever possible.
2. As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information that you have provided to us. None of our ADM processes have a legal effect on you.

11. Your Rights and Obligation

1. You have the right to ask us not to contact you for marketing purpose by contacting us at [email protected], or by adjusting the notification preferences.
2. You have the obligation to correct any Personal Data that we hold on you that is inaccurate, incorrect, or out of date.
3. You also represent that you have the right to share all information that you have provided to us and to give us the right to use, change, and/or delete the data you provide that does not correspond to the information you provide.
4. You have the right ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Transfez is subject to and you have the right to withdraw your Consent (whether in part of in whole) at any time in writing to us. Upon the receipt of your written request, we will inform you of the consequences of such withdrawal and we will cease to collect, use or disclose your Personal Data in accordance with this Privacy Policy. Notwithstanding the above, you agree that we may continue to use and disclose your Personal Data for the Purposes, for a reasonable period of time after the termination of the contractual relationship with us.
5. You have the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.
6. Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

12. ACCOUNT BLOCKING AND CLOSED

1. Upon your request, We will block your Account and use of Transfez Services with Your Account. In addition, if in Our consideration, things happen that are detrimental and / or can harm Us or You, We will also block it. However, we provide you with a path to file a complaint in accordance with the terms of this Privacy Policy.
2. Account Blocking may occur including due to, but not limited to, the following events :
• Your report that your User Id was stolen or hacked;
• Blocking orders issued by government or monetary institutions or based on court orders;
• Use of your Account and/or Transfez Services in a manner contrary to this Privacy Policy, and other terms that Transfez may govern, the Transfez Terms and Conditions and any applicable laws and regulations
• Other reasons that harm you or Us, including abusive and fraudulent actions or when our system catches suspicious patterns of financial transactions.
• If your Account is blocked and you have strong evidence that nothing suspicious has happened, you may file your complaint as stated in these Terms and Conditions. After checking your complaint, we may determine whether to terminate or continue blocking your Account. Blocking will not be continued unnaturally if We decide that the things that resulted in the blocking have ended.
3. Your account may be closed due to the following :
• Your request, if you have never made a transaction if you have made a transaction then your Account will be unverified but can not be closed because according to the regulation your account must be stored for five (5) years.
• Our policies are based on applicable laws and regulations;
• The majeure occurs for 3 (three) months or more in a row; and/or Another reason for blocking accounts.
• We will refund your money (if any) through a mutually agreed method between the parties, after deducting the fees owed (if any), unless in Our sole consideration a certain part of your money is required, for example due to a reasonable belief that such part is related to or resulting from fraud and/or other violations of the law.
• Your account will be terminated automatically or closed when you close your Account.

13. Changes to Our Privacy Policy

1. We reserve the exclusive right to change, amend or revise this Privacy Policy from time to time.
2. Any changes we may make to our Privacy Policy will be posted on Website or App and, where appropriate, notified to you app notification. Please check back frequently to see any updates or changes to our Privacy Policy.

14. Contact

1. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]
2. If you feel that we have not addressed your questions or concerns adequately, you may make a complaint to our Customer Service support.

15. Recognition and Approval

By agreeing to the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and agree to all its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring or processing your Personal Data in accordance with this Privacy Policy.