Privacy Policy

This Privacy Policy ("Privacy Policy") is prepared as a notice from PT. Fliptech Lentera Inspirasi Pertiwi (“Flip” or “We”, “Our”, “Us”) to users of our website, Flip Application, platforms, products, and Services ("Customers"), job applicants, third-party service providers, vendors, and/or Flip business partners ("You") regarding how Flip processes your personal data ("Personal Data").

Personal Data processing activities regulated in this Privacy Policy include activities to obtain, collect, store, control, use, process, analyze, correct, update, display, announce, transfer, disclose and protect Personal Data (all referred to as “Data Processing”) that Flip collects when you use Flip products or Services, apply for a job with Flip and/or have other legal relationships with Flip.

This Privacy Policy is a set of rules that forms an integral part of the Flip Application Usage Terms and Conditions and/or the terms and conditions of our other products or Services, serving as the basis for all Flip’s activities regarding Data Processing. Terms capitalized in this Privacy Policy are deemed to have the same meaning and interpretation as those used in the Flip Application Usage Terms and Conditions  and/or the terms and conditions of other Flip products or Services unless explicitly stated otherwise in this Privacy Policy.

By adhering to this Privacy Policy, you are also deemed to be bound by Flip Application Usage Terms and Conditions and/or the terms and conditions of other relevant Flip products or Services (as applicable). Under no circumstances shall the invalidity of the Flip Application Usage Terms and Conditions and/or the terms and conditions of other relevant Flip products or Services render this Privacy Policy null, void, and/or unenforceable.

By reading this Privacy Policy, you acknowledge that you have understood this Privacy Policy and all its provisions.

A. What Personal Data Do We Collect?

The Personal Data we collect varies depending on the situation in which it is collected and the type of Services and/or legal relationship you have with Flip. The data we collect includes, but is not limited to, the following: 

Personal Data: 
Information about you or other data combined to identify you.

1. Individual Identification Data: this includes information used to specifically identify an individual, such as name, national identification card (“KTP”), driver’s license (SIM), taxpayer identification number (“NPWP”), temporary stay permit card (KITAS), personal photo, family card (KK), user or other identification, educational certificates, skills certificates, date of birth, gender, religion, marital status, place of birth, nationality, occupation, mother’s name, source of income, and/or income amount;

2. Business Entity Identification Data: this includes information to identify your business entity, such as business name, address, phone number, articles of incorporation, articles of association and amendments along with regulatory approvals, business permits, operational permits, structure of directors/management, board of commissioners/supervisors, shareholders, and identification of directors and commissioners (e.g., KTP, passport, KITAS), NPWP, and Business Registration Number (NIB);

3. Contact Data: this includes information used to contact an individual, such as address (including postal code and city name), email address, GPS data, geo-location, phone number (including mobile number), and social media usernames or accounts. This information also aids in address verification and streamlining the Know Your Customer (KYC) process;

4. Biometric Data: this includes biometric information such as fingerprints and facial recognition used for authentication to access Flip Services; 

5. Credential Data: this includes passwords, security hints, and similar security information used for account and Flip Services authentication;

6. Transaction History Data: this includes data based on fund transfer instructions provided to Flip; 

7. Account Data: this includes account-related information such as transaction history, subscription packages, account numbers or names, initials, nicknames, and loyalty points/Flip Coins; 

8. Interaction History Data: this includes your interaction history with Flip, such as call recordings between you and Flip’s Contact Center personnel, live chats on the website, emails, and messages via other communication media provided by Flip; 

9. Log Data: this includes records in our system such as device IP address, date and time of access, application features or pages viewed/browsing history, application workflow, other system activities, browser type, and third-party sites or services you used before interacting with our Services; 

10. Cookies Data: this includes small text files stored in your browser. Details of data collected through cookies, web beacons, and other technologies are used for advertising purposes; 

11. Flip Application Data: is the data collected from Flip Application as follows: 

a. SMS from your inbox that helps us in identifying various bank accounts you may have, cash flow patterns, description and amount of transactions you make as a User. This SMS data also includes your historical data. We also collect data in the form of sender name, SMS content, time of receipt and sending data to third parties. This data is used to understand your income, spending patterns that help us and/or our partners or affiliates in credit evaluation and help us and/or our partners or affiliates in facilitating higher limits, faster approval rates. We do not read any private messages;

b. Device-specific information: Information such as hardware model, operating system and version, and user profile data to uniquely identify devices and prevent fraud. We do not collect unique device identifiers like IMEI or serial numbers; 

c. installed application metadata information including application name, package name, installation time, update time, version name and version code of each application installed on your device. We collect information about the applications installed on your device to provide better personalized services and improve our and/or our partners’ or affiliates’ credit risk assessment. This information is securely shared with our trusted partner, FinBox, for analysis;

d. list of contact metadata information including number of contacts, number of contacts with phone numbers, contacts created each month to detect fraudulent behavior. Personal contact information such as contact name or contact phone number and other similar information is not collected;

e. notification data such as sender name, notification body, time received and sends data to third parties. This data is used to understand your income, spending patterns which helps us in credit evaluation and helps us in facilitating higher limits, faster approval rates. We do not read any notifications sent by social media apps or Chat apps like WhatsApp, Instagram, etc.;

f. interactions, reviews, criticisms, suggestions and/or messages from you addressed to us, including anything expressed when you contact us through the means of communication we provide or when we provide assistance in resolving problems arising in connection with the use of the Flip Application; and/or

g. other things you do in the Flip Application and/or Features and other data you enter into the Flip Application and/or Features.

12. Product and Service preferences: Certain activities when you tell Us such information, or Our assumptions about your preferences, based on how you use Our products and Services.

13. Advertising ID: used for advertising and promotional activities.

14. Third-Party Information: information that we legitimately obtained from other sources, such as credit agencies, fraud prevention agencies, and other data providers, operating lawfully and with your consent. This includes demographic data, interest-based data, and internet browsing behavior.

B. How Do We Collect Your Personal Data?

1. When you access the Flip Application and/or use its Features;

2. When you register for an account in the Flip Application or applying for job with Flip;

3. When you use Flip Services and/or Features in the Flip Application

4. When you contact and use our communication channels, such as but not limited to the Contact Center, live chat, email, and other communication media provided by us;

5. When you participate in our promotional activities, events, marketing campaigns, loyalty programs, surveys, or other activities;

6. When you use Features that require access permissions on your device;

7. When you are a customer of a company involved in corporate actions (mergers or acquisitions) with us, in accordance with applicable laws and regulations;

8. When you visit our office premises equipped with CCTV devices;

9. Through information that is obtained from third parties with a lawful basis for processing your Personal Data, provided we also have a lawful basis for processing it; and/or

10. Through your information that is publicly available.

We collect your Personal Data only for the purposes of processing the Flip Services and/or services available on the Flip Application (which we may provide in collaboration with third parties), product development and/or marketing activities for our Services and/or services available on our Application.

In the event that you choose not to provide or provide incompletely your Personal Data to Us, We may not be able to provide the Flip Services and/or and/or Features to you.

C. How Do We Use Your Personal Data?

We collect your Personal Data for data processing purposes, which include the following:

1. To Provide Information and Flip Services We use your Personal Data to deliver Flip Services, their benefits, and updates, either directly or through our collaborating partners:

a. to communicate and implement Know Your Customer (KYC) processes with you;

b. to offer products, services, campaigns, promotions, events, or loyalty and retention programs with third-party partners;

c. to understand how you interact with Flip Services and provide the best possible experience; and/or

d. to ensure security, and deliver the latest versions, features, options, and controls related to your system or device.

2. To Communicate With You We use your Personal Data to interact with you or individuals whose data you provide via Flip Services and/or the Flip Application (which maybe provided in collaboration with third parties):

a. to send service messages about account registration in the Flip Application;

b. to use your information for participation in surveys; and/or

c. to enable us to send you information via electronic mail (email), telecommunications (telephone calls or text messages) or social media about Flip products and services offered by Flip.

3. For Our Business Operations We process your Personal Data to:

a. to process transactions and respond to requests for Flip Services;

b. to conduct research and studies you may voluntarily participate in by sharing your Personal Data; and

c. for business operations to carry out accounting, auditing, billing, reconciliation and collection activities, including monitoring and preventing crime or fraud, protecting Our legal rights, and carrying out obligations under an agreement/contract/agreement.

4. For Functionality, Development, and Improvement of Flip Products and Services We use your Personal Data:

a. to measure the utilization of Flip Services, diagnose server issues, and enhance security features;

b. to utilize User Personal Data related to User habits in using Flip Services to understand and categorize Users;

c. to use Personal Data for the purposes of researching, testing, modifying, improving or developing Flip products and Services, Our new technologies and to identify trends;

d. to utilize User Personal Data regarding User habits in using Flip Services for further analysis and to carry out marketing processes that are more in line with User preferences; and/or

e. to process Users Personal Data in the context of preventing fraud and for security purposes.

5. For Advertising and Marketing of Flip Services

We may use your device's physical location, combined with information about what ads you view and other information we collect, to enable Us to provide personalized content and to study the effectiveness of advertising and marketing campaigns; and

You can choose to allow or decline subscriptions or sharing of your device's location by changing your device settings.

6. To Fulfill Related Parties’ Needs:

We may share your Personal Data with related parties for

a. national defense and security purposes;

b. law enforcement purposes;

c. public interest in state administration; or

d. interests in supervising the financial services sector, monetary, payment systems, and financial system stability carried out in the context of state administration.

B. How Do We Store Your Personal Data?

The Personal Data we collect is stored in data storage facilities (data centers) managed by us and/or by third parties located within or outside the jurisdiction of Indonesia. All data storage facilities, infrastructure, and systems, whether managed by us or third parties, are equipped with security controls to ensure the protection of your Personal Data.  

Your Personal Data may be stored in printed copies or electronic formats.

The retention period for your Personal Data varies depending on the processing purposes we provide in this Policy and is subject to the applicable laws and regulations.

C. With Whom Do We Share Your Personal Data?

We share your information with other parties in order to provide Flip Services and/or services in Flip Application and to improve the experience of Flip Services and/or services in Flip Application. In maintaining the security of your Personal Data, we will only share it with other parties who have a legitimate basis for processing and have implemented Personal Data protection efforts in accordance with applicable laws and regulations and the requirements that we determine.

We share your information with the following parties:

1. our affiliated companies within the Flip group of companies for the purpose of providing Flip Services, services by our affiliated companies or processing data on Flip's behalf;

2. vendors, partners, suppliers, or third parties involved in authentication processes and the provision of Flip Services on Flip's behalf;

3. third parties assist us in providing information for identification, authentication, and due diligence (KYC) purposes, including fraud prevention agents, business assessment agents, or credit rating agencies, including banking institutions;

4. public accountants and other audit institutions;

5. law enforcement agencies, government institutions, regulators, courts, or other authorized parties, as required by law and with a lawful basis; 

6. third parties for promotional purposes, marketing, loyalty programs, events, or offers of Flip Services and products; and/or 

7. third parties advertising with us to present offers to you, subject to the specific privacy policies of such services.

Fraud Management and Law Enforcement

We will disclose information when necessary to protect ourselves from fraud, safeguard our rights or property, or protect the interests of our Users.

We may also need to disclose your information to comply with law enforcement obligations, or for the legitimate interests of any subject in the context of national security, legal proceedings, litigation, criminal investigations or to prevent epidemics, emergencies declared by the government. Your Personal Data will only be provided if we, in good faith, believe that we are obligated to do so in accordance with applicable laws and regulations and based on a thorough evaluation of the provisions of the laws and regulations.

Mergers and Acquisitions

If we undergo a reorganization, are acquired by another company, or merge with another legal entity, your information will be shared with the relevant party. This transfer will be governed by confidentiality agreements between us and the third party. At that time, we will notify you and provide public information through our official communication channels.

Third Parties Collaborating with Us

If you access and/or use Flip Services provided in collaboration with third parties or partners, we may need to exchange information with them as part of managing those relationships and your account—for example, to deliver the services and to help protect and secure our systems and Services.

If we contract service providers or contractors to provide Services on our behalf and they gain access to your Personal Data, we do not permit them to use or disclose your Personal Data except in connection with delivering Flip Services which are being the object of the cooperation with them.

D. How Do We Protect Your Personal Data?

We have designed, implemented, and maintained an information security system in an effort to protect and secure your Personal Data from unauthorized access, modification, and disclosure and ensure the availability of data when needed. However, we cannot fully guarantee that your Personal Data will not be hacked, accessed, disclosed, modified, or destroyed by third parties who access our system unauthorizedly due to factors beyond our control.

You are responsible for maintaining the confidentiality of your account credentials, including but not limited to your password, one-time password (OTP), access to your email, malware or viruses that may attack your device.

E. Use of Cookies and Third-Party Services

Cookies are text files placed on your computer or device for record-keeping purposes. We use cookies to help us improve your convenience in accessing Flip Application. Cookies will record your Personal Data such as the data you enter into Flip Application. For example, if you create an account in Flip Application, cookies will help us remember specific Personal Data for your next visit. When you return to access Flip Application, the Personal Data you previously provided will be displayed again, so activating cookies will make it easier for you to use Flip Application.

You can set your browser to disable cookies partially or completely, but when you disable cookies completely (including essential cookies), you may not be able to access all or part of the Flip Application and/or Features. In general, browsers have features to control most cookies. To learn more about cookies, including but not limited to managing, deleting and seeing what cookies are active, you are encouraged to visit  www.aboutcookies.org or www.allaboutcookies.org.

We reserve the right to use third party services to analyze your Personal Data for us, such as Google Analytics and other third party services for the purpose of developing Flip Application and Features. These third party services include, among others, collecting data from your visits and activities while accessing Flip Application and using our Features.

F. Your Rights as a Personal Data Subject

As the owner of Personal Data, you have rights concerning your data that are protected by the applicable laws and regulations, and we, as the Personal Data controller, are obligated to honour those rights. You may exercise your rights by contacting us through the contact information provided in this Privacy Policy by attaching proof of your identity and an explanation of your request. Below are your rights related to your Personal Data:

1. Right to Update Personal Data

You have the right to complete, update, and/or correct any errors or inaccuracies in your Personal Data, through the application we provide or by contacting the Data Protection Officer via the "Contact Us" section of this Privacy Policy.

2. Right to Access Personal Data

You have the right to request a copy of the Personal Data you have provided to us, through the application we provide or by contacting the Data Protection Officer via the "Contact Us" section of this Privacy Policy.

3. Right to Cease Processing, Delete, and/or Destroy Personal Data

We store and process your data for as long as necessary to achieve the purposes described in this Privacy Policy and in accordance with the retention period required by applicable laws and regulations. You have the right to terminate the processing that we do or delete your data that we have (as long as it does not conflict with applicable laws and regulations) at the risk that you will not be able to use our services in full due to the minimum information that we need to provide our services cannot be processed. You have the right to destroy your data and your requests on such matters can be submitted by contacting the contact in the Contact Us section of this Privacy Policy.

4. Right to Withdraw Consent for Personal Data Processing

You have the right to withdraw your consent to the processing of Personal Data that has been given to Us at the risk that you will not be able to use Our services in their entirety because the minimum information that We need to provide Our services cannot be processed.

5. Right to Opt-out of Marketing Information

We may from time to time provide promotions and offers to you in accordance with the lawful basis for processing. You have the right to withdraw consent to the processing of Personal Data related to marketing so that we do not share marketing-related information with you. You will still receive information related to our services and will still be able to use our services. You can withdraw consent to the processing of Personal Data related to marketing through the media that we provide from time to time or contact us via the contact information in the “Contact Us” section of this Privacy Policy.

6. Right to Data Portability and Interoperability

You have the right to obtain and/or use your Personal Data provided to us in a commonly used or machine-readable format, such as transaction history. You may also transmit your Personal Data to other Personal Data controllers, provided that both systems can securely communicate under Personal Data Protection principles as defined by applicable laws.

7. Right to Restrict Personal Data Processing

If you feel that the data we hold about you is inaccurate, or you believe we should not be processing your Personal Data, please contact the Personal Data Protection Officer to discuss your rights. In certain circumstances, you have the right to ask us to restrict the processing of your Personal Data.

8. Right to Close an Account

We provide a means for you to close your Account on Flip Application and our Features. The means are available in the “Manage Account” menu, then you can follow the next steps, namely (i) submitting the reason for closing the Account, and (ii) entering your Account PIN. After that you will receive a notification that your Account is officially closed. You can also contact us to close the Account by providing the reason for closing through the means of communication listed in this Privacy Policy. In the event that you close your Account, you consciously understand the consequences that you cannot use Flip Features and Application or other Flip Services because you are no longer registered as a User.

You need to know that even if you are no longer a registered User on Flip Application, your Personal Data may still be stored for a period of time required by the applicable laws and regulations

However, we still provide you with limited access to access your Personal Data stored in Flip Application.

If you wish to exercise any of the rights above or file a complaint regarding how we use your Personal Data, please contact our Data Protection Officer as provided in the "Contact Us" section. 

We reserve the right to deny your requests to access, correct, and/or delete, in whole or in part, your Personal Data in our possession if permitted or required under the applicable laws and regulations, especially if such requests may affect the following matters, including but not limited to:

1. endangering your or another person’s physical or mental safety;

2. involving the disclosure of someone else’s Personal Data;

3. conflicting with national defense and security interests; and/or

4. irrelevant to you or the Personal Data processing activities that we conduct. Additionally, requests may be denied if identification of the data is insufficient or if the data cannot be verified.

G. Transfer of Personal Data Abroad

In some of our processes (such as live verification of the pictures), we may transfer your Personal Data outside the jurisdiction of Indonesia. Storing infrastructure of such Personal Data in this matter will be located outside Indonesia and managed by third-party partners. We will always ensure the security of your data by ensuring:  

1. that the country of the third-party partner receiving the Personal Data transfer has a level of personal data protection equivalent to or higher than that of Indonesia; or 

2. there is an adequate and binding personal data protection measures; or

3. that you have consented to the transfer of Personal Data abroad by your consent to this Privacy Policy.

H. Automated Decision-Making

In the processes of analyzing Account registrations, processing the Transactions, providing promotions or offers, and fraud prevention activities, we may use automated decision-making (i.e., without human involvement), including profiling, which may result in certain legal consequences or directly impacting you.

You have the right to object to decisions made solely based on automated processing through the objection submission mechanism outlined in this Privacy Policy.

I. Provisions Regarding Minors

We do not intentionally collect Personal Data from minors. If you are under 17 years old, you need to ensure that you have obtained consent from your parents (father or mother) or your guardian based on the prevailing laws and regulations. 

If we become aware that we collect Personal Data from the minors without a valid consent,we will take certain measures to erase such Personal Data as soon as possible.   

J. Provisions Regarding Persons with Disabilities

If you are a person with a disability, we require consent from you and/or your guardian in accordance with the applicable regulations.

K. Website Privacy Policy and Other Services

We may provide you with a link to a third-party website, landing page, and/or other content pages. If you choose to browse or access those links to those websites, landing page, and/or other content pages, please be aware that such websites, landing pages, and/or content pages may be subject to a privacy policy difference from this Privacy Policy. We are not responsible for any risks or consequences that may arise from your access to such websites, landing pages, and/or content pages, as we have no control over them. We strongly recommend that you read and understand the terms and conditions, as well as the privacy policies of these third parties, which govern your rights when accessing their websites, landing pages, and/or content pages.

L. Updates and/or Changes to the Policy

We may update and/or amend this Privacy Policy from time to time. The updated version of this Privacy Policy will be uploaded on this website, the application and/or other appropriate and relevant locations which based on our assessment is appropriate to be used as a medium to notify you of such updates and/or amendments. If the changes to this Privacy Policy materially affect your personal data and information in Flip Application, we will notify you at least 30 (thirty) business days prior to the effective date of the changes, or within any other period as permitted by applicable laws and regulations (“Notification Period”).

If you do not agree with the updates and/or amendments to this Privacy Policy, you may submit an objection and have the right to close your Account during the Notification Period. If you do not raise any objections to the proposed changes to this Privacy Policy during the Notification Period, we will have the right to assume that you have agreed to the changes, and you will be bound by all the amendments determined by us.

M. Granting of Consent by You

1. By agreeing to this Policy, you represent and warrant that the Personal Data you provide to us through the Flip Application and/or its Features is accurate, complete, truthful, updated data and based on the actual circumstances. Furthermore, you are fully responsible for the Personal Data and have full authority and/or personal rights to provide such Personal Data to us. You also release us from any civil claims or criminal charges from third parties that may arise from the misuse of information and/or misleading information related to the Personal Data you have provided to us through the Flip Application and/or its Features.

2. By agreeing to this Privacy Policy, you grant us the right to, from time to time, request authentication, verification, and/or updates to your Personal Data. This right is necessary to ensure that the data and information you have provided to us remains accurate, complete, truthful, and and up-to-date. You also grant us the right to temporarily or permanently suspend, or to limit your access to the Flip Application and/or certain Features in the event that you have not completed the authentication or updates of your Personal Data.

3. By continuing to access Flip Application, use its Features, and/or our other services, you expressly consent to us to obtain and collect your Personal Data as outlined in this Privacy Policy. Furthermore, you declare that this consent is given voluntarily, in a competent state, and with full awareness.

N. Contact Us

Any questions you may have and/or requests to exercise your rights as set forth in this Privacy Policy can be directed to:

PT. Fliptech Lentera Inspirasi Pertiwi
Attn: Data Protection Officer

Arkadia Tower F, 3rd Floor
Jl. T.B. Simatupang Kav. 88, Kebagusan, Pasar Minggu, South Jakarta, DKI Jakarta - 12520
[email protected]

Effective Date:  December 27, 2024 

Previous Amendment: 
August 12, 2024 
July 19, 2024