For the purpose of the relevant data protection regulations, Transfez (PT. Indo Koala Remittance hereinafter refer to as “we”, “us”, or “our”) are the “data controller” of your information. We are located on Tebet Raya 45B Street, Tebet, Jakarta Selatan. If you have any questions about how we protect or use your data, please e-mail at firstname.lastname@example.org.
1. Data Protection
- We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using Transport Layer Security technology.
- 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 againsts any legal action, whether in civil or criminal proceeding in connection the succesfull infiltration by the third parties (if any).
- You may not disclose your password to anyone. No matter how effective a technology is, there is no impenetrable security system.
- We restrict access of your personal information 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 information from unauthorized access.
2. Information Collection
We may collect and use the following data:
- 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.
- 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.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:
- the banks that you use to transfer money to us will provide us with your basic personal information, such as your name and your address, as well as your financial information such as bank account details;
- business partners may provide us with your name and address, as well as financial information, such as card payment information;
- advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website;
- credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information that you have provided to us.
4. Uses Made of the Information
- 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).
- 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. Disclosure of Your Information
- 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;
- 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.
- We may disclose your personal information 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.
6. Your Personal Data Storage Location
7. Sharing Your Data Outside Indonesia
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 Indonesia 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.
8. Profiling and Automated Decision Making
- 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.
- 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.
9. Data Retention and Security Measures
- As a regulated financial institution, Transfez is required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
- We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.
- Retention periods for the storage of your data in accordance with statutory provisions and is kept for a minimum of 5 (five) years, if there are no statutory provisions that specifically regulate it.
- We take all reasonable steps, including technical, administrative and physical safeguards to help protect your personal data that we process from loss, misuse and unauthorized access, disclosure, alteration and destruction.
- For registered users of Transfez, your registration information and account information (if any) can be viewed and edited in the Transfez App through your account with Transfez, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. If you share a computer with others, you should not choose to save your log in information (e.g. user ID and password) on that shared computer.
10. Your Rights and Obligation
- You have the right to ask us not to contact you for marketing purpose by contacting us at email@example.com, or by adjusting the notification preferences.
- You have the obligation to correct any personal information that we hold on you that is inaccurate, incorrect, or out of date.
- 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.
- 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.
- 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.
- If you feel that we have not addressed your questions or concerns adequately, you may make a complaint to our Customer Service support.
API : The application programming interface provided by Transfez.
App : The mobile application software, the data supplied with the software and the associated media.
Services : All products, services, content, features, technologies or functions offered by us and all related websites, applications (including the App), and services (including the Website and API).
Website : Any webpage, including but not limited to www.transfez.com, where we provide the Services to our customers.