Privacy Policy

In order to ensure that the data relating to identity, contact, profile, behavior on the Flip Application and the data relating to Your other personal information which identifiable both directly or indirectly (“Personal Data”) You are always protected whenever You access the Flip Application and/or use the Features contained therein which developed by PT Fliptech Lentera Inspirasi Pertiwi (“Flip” or “We”, “Our”, “Us”), We are committed to protect the Personal Data that is furtherly set forth under this Privacy Policy.

This Privacy Policy (“Policy”) constitutes a set of rules that are integral parts of the Terms and Conditions, which are made as the basis of Our activities in obtainment and collection, processing, storing, displaying, distribution and removal of Personal Data on the Flip Application. The terms and definitions started in capital letters contained under the page of the Terms and Conditions shall have the same meaning and interpretation as the terms used in this Policy, unless otherwise specified under this Policy.

By accessing and/or using the Flip Application, You have read, understood, and given approval to Flip to obtain, collect, store, process, and use Personal Data as set forth under this Policy and are bound to all the terms set forth in this Policy. Your Personal Data is important to Us, and You can opt out of this Personal Data collection at any time. If You do not approve this Policy, You will not be granted the permission to access and/or use the Flip Application.

Subject to this Policy, You are also considered to be bound by the Terms and Conditions of Flip Application Usage and the Terms and Conditions of Flip for Business, whereas this Policy constitutes an inseparable and integral part of the Terms and Conditions of the Flip Application Usage. The invalidity of the Terms and Conditions of the Flip Application Usage and the Terms and Conditions of Flip for Business shall not cause this Policy to become illegal, invalid, and/or unenforceable.

1. Acquisition or Collection of Personal Data
   1. When You access the Flip Application or use the Features contained on the Flip Application, You have, directly or indirectly provided Us with Personal Data. For example, when You register by creating an Account in the Flip Application, We shall collect and store Your Personal Data in the form of Your name, email address, password, and other data needed so You can have access to Your Account or the Merchant’s Account. In addition, We collect Your Personal Data including when You are:
      1. accessing the Flip Application and/ or using the Features;
      2. registering by creating an Account or a Merchant’s Account on the Flip Application;
      3. responding the surveys distributed by Us;
      4. sending reviews, messages, critics and/ or Your suggestions to Us;
      5. contact Us, through the communication facilities that We provide;
      6. use the Features that require access permission on Your device; or
      7. entering information(s) in relation with Personal Data in any form to the Flip Application and/ or Feature.
   2. The Personal Data that We collect is the data that You have provided to Us in the manner that We have previously explained. The Personal Data shall include, among others:
      1. Personal data relating to Your personal information, including Your name, address, telephone number, e-mail address, Identification Card (Kartu Tanda Penduduk), Tax Registration Number (Nomor Pokok Wajib Pajak), Family Card (Kartu Keluarga), the photo of You, occupation, line of business, birth mother's name, source of income, and/or amount of income;
      2. corporate data relating to Your company information, including name, address, telephone number, composition of the board of directors/management, commissioners/advisors, shareholders, and the identity of the directors and commissioners, in the form of either an Identity Card (Kartu Tanda Penduduk) or passport or residence permit, and Business Identification Number (Nomor Induk Berusaha) or Business Certificate (Surat Keterangan Usaha);
      3. Your response to the survey We provided;
      4. Transaction history pursuant to the Fund Transfer Orders provided to Us;
      5. data of real or approximate location of Your device such as Internet Protocol addresses, Wi-Fi locations, geo-locations, and others. This also helps Us to verify the address and expedite know your customer (KYC) process;
      6. data in the form of time of each usage activity, including registration, login, transaction, and others;
      7. Your data of usage and/ or preferences, including Your interactions in using the Flip Application, stored choices, Activity that You choose or trade as well as the settings selected in the Flip Application;
      8. information about the software and hardware that You use to access the Flip Application and/ or use the Feature;
      9. Flip Application collects SMS from Your inbox which helps Us in identifying the various bank accounts that You may be holding, cash flow patterns, description and amount of the transactions undertaken by You as a User. This SMS data also includes Your historical data. ;We also collect Transactional SMS data like sender names, SMS body, received time and transmits the data to third parties. This data is used to understand Your income, spending patterns which help Us and/or Our partner or affiliate in the credit evaluation and help Us and/or Our partner or affiliate in facilitating higher limits, faster approval rates. We do not read any personal messages;
      10. Flip Application collects and monitors specific information about Your device including Your hardware model, operating system and version, user profile information to uniquely identify the devices and ensure that unauthorized devices are not able to act on Your behalf to prevent frauds. We do not collect any unique device identifiers like IMEI or serial number;
      11. Flip Application collects a list of the installed applications metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device. We collect information about the apps installed on Your device to provide better personalized services and improve Our and/or Our partners or affiliate’s credit risk assessment. This information is securely shared with Our trusted partner, FinBox, for analysis; 
      12. Flip Application collects a list of the contacts metadata information which includes the number of contacts, count of contacts with phone number, contacts created monthly to detect the fraudulent behavior. Personal contact information like name of the contacts or phone number of the contacts and other similar information is not collected;
      13. Flip Application collects notifications data like sender names, Notification body, received time and transmits the data to third parties. This data is used to understand your income, spending patterns which help us in the credit evaluation and help 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, and others.
      14. data log, including records on the server that received a data such as the IP address of the device, the date and time of access, Feature or viewed page on the Flip Application, site work processes and other system activities;
      15. interactions, reviews, critics, suggestions and/ or messages from You which addressed to Us, including everything that is disclosed when You contact Us through the means of communication that We provide or when We provide the assistance to resolve the issues that arise in connection with the use of the Flip Application; and/ or
      16. other things that You do in the Flip Application and/ or Feature and other data that You provided into the Flip Application and/ or Feature.
   1. In some instances, to provide better experiences for You in our Flip Application and/or in providing the existing and/or future Features, We may directly collect Personal Data from services operated by a third party such as when our business partner provides us with verification of Your Personal Data. In such instances, we request our business partner to take lawful and proper measures.    
   2. You hereby represent and warrant that the Personal Data which You input onto the Flip Application and/ or Features is the accurate, precise and complete Personal Data based on the actual condition, and You are fully responsible for the Personal Data and You have full authority and/ or personal rights to submit Personal Data to Us, including releasing Us from any civil lawsuits or criminal charges arising from misuse or misleading information relating to Personal Data that You input into the Flip Application and/ or Features.
   3. We have the right from time to time to request the authentication, verification and/ or updating of Your Personal Data, therefore Your data and information is accurate, complete and up-to-date, including temporarily/permanently terminating or prohibit You to access certain Features optimally in the event that You have not conducted authentication and update Your Personal Data.
   4. By continuing to access the Flip Application, using Features, and/ or other Our services, You hereby expressly giving approval to Us to obtain and collect Your Personal Data as set out in Article 1.1 and 1.2 in this Policy, and hereby represents that such approval is made without any coercion, with full capacity, and consciously.
       
2. Use of Personal Data
   1. The Personal Data that We have collected and obtained shall be fully used for Your, Our, and/or Our partners or affiliate (including Our affiliate that have cooperation with Us to provide Flip’s service) interests in accordance with this Policy and the Applicable Law in Indonesia. We may use the Personal Data to, among others:
      1. process Your data for Your needs in accessing Flip Application, using Features;
      2. process the Transaction in accordance with the Fund Transfer Orders which given to Us;
      3. manage, operate, administer and provide You with the services offered on the Flip Application;
      4. contacting You in regards of the matters relating to Your usage and / or access of the Flip Application and Features available on the Flip Application;
      5. communicate with You in connection with the requests for critics and suggestions;
      6. inform the information, insight, surveys or interesting program(s) or promotion for You;
   2. Flip Application and/ or Feature development in order to improve Our services, including using information obtained for research, analyzing, product development and testing purposes to improve Your security and comfort in accessing and using the Flip Application, services, and/ or Feature, and developing services, Features and/ or new product;
      1. business development, services, Feature, new product and/or marketing strategy;
      2. measure and improve Your experience and satisfaction toward the Flip Application;
      3. assist You when filing a report to Us regarding the use of the Flip Application through the communication facilities We provide;
      4. conduct monitoring or investigation of suspicious transactions or indicated transactions which containing materials of fraud or violations of the Terms and Conditions of the Flip Application Usage, Terms and Conditions of Flip for Business, or Applicable Law, as well as taking necessary actions as response on the outcome of such monitoring or investigation;
      5. enforce and apply the Terms and Conditions of the Flip Application and/ or Terms and Conditions of Flip for Business;
      6. resolve complaints that We receive, help resolve disputes regarding Flip Services, Flip for Business's Services, and/or operated Flip Application; and / or
      7. for other purposes as notified to You on the time of collection or other purpose as long as conducted in accordance with the Applicable Law.
   1. You hereby understand that using Features in the Flip Application requires a process of authenticating, verifying, and/ or updating Your Personal Data. By continuing to access Our Flip Application and using Our Features, and other services, You hereby expressly give Your approval to the use, utilization and/ or disclosure of Your Personal Data, and hereby state that such approval is made without any coercion, with full capacity, and consciously.
3. Distribution of Personal Data to the Third Parties
   1. We understand the confidentiality of Your Personal Data and We are committed not to sell, rent, display, or distribute Your Personal Data without Your prior consent unless otherwise specified in this Policy. We shall only disclose Your Personal Data to third parties with Your consent.
   2. Waiving the provision in paragraph (1) above, by continuing to access Our Flip Application, and using Our services, Features and other products s, You hereby directly grant Us the approval in any form to disclose Your Personal Data and You allow Us to provide access, disclose, and send the Personal Data to the appointed third party to help and/or cooperate with Us to provide the services, Features, and/or products for You including to support the implementation of the Transaction pursuant to the Fund Transfer Orders in the Flip Application such as Flip’s bank partner, affiliate, and/or other partners (“Appointed Third Parties”), and release Us from any loss and damage resulted from the Appointed Third Parties failure to secure Your Personal Data. You fully acknowledge that this approval is made without any coercion, with full capacity, and consciously.
   3. We are not able to guarantee the security of Your Personal Data on any third party systems including the Appointed Third Parties systems and We have no control or responsibility for the privacy policies or content of the third parties, including the Appointed Third parties. Therefore, We recommend You to learn and examine the privacy policies of each third party, so that You understand their terms on handling Your Personal Data.
   4. We are authorized to disclose Your Personal Data to comply with a valid court orders, request from the Central Bank of Indonesia, or other authorized authorities based or based on provisions of Applicable Law. If possible and permitted, We shall send You a notification in the event that We are disclosing Your Personal Data. Waiving the provisions of provision in paragraph (1) above, by continuing to access the Flip Application and use Our other features and services, You directly hereby give consent in any form to disclose Your Personal Data and You allow us to provide access, disclose and send Personal Data to Bank Indonesia or other competent authorities.
   5. You understand and agree that for the purpose of Flip Application development, We may use or share Your data and information which do not identify You as an individual, to be processed, developed or cooperated with Appointed Third Parties and other third party. We acknowledge Your privacy, therefore the data and information that We may use and share are aggregate data which do not identify You as an individual.
4. Use of Cookies and Third Party Services
   1. Cookies are text files that are placed on Your computer for recording purposes. We use cookies to help Us improve Your comfort in accessing Our Flip Application.
   2. Cookies shall record Your Personal Data as well as the data that You input into the Flip Application. For example, if You create an account in the Flip Application, cookies shall help Us recall specific Personal Data for Your next visit. When You re-access the Flip Application, the Personal Data that You provided previously will be displayed, so the activation of cookies shall facilitate You in accessing the Flip Application.
   3. You may set to disable cookies in Your browser partially or entirely, but when You choose to disable cookies entirely (including significant cookies), You may not be able to access all of part the Flip Application and/or Features.
   4. In general, the browser has a feature to control most cookies. To find out more about cookies, including but not limited to managing, deleting and seeing which cookies are active, You are encouraged to visit www.aboutcookies.org or www.allaboutcookies.org.
   5. We reserve the right to use third party services to analyze Personal Data for Us, such as Google Analytics and other third party services that aim to develop Flip Application and Features, among others, Features that support communication services which provide facilities for Users to interact directly with Vendors. These third-party services including among others the collection of data from Your visits and activities while accessing the Flip Application and using the Feature.
5. Your Options and Transparency
   1. In using the Flip Application and the Features that We provide, We respect You by providing options that include but are not limited to:
      1. You are able to modify Your profile information in your Account through the Feature in the Flip Application, in case that you are registered as the User;
      2. You are able to unsubscribe from the notification of a new activity is marketed, a variety of the latest promo information, and exclusive offers if You no longer wish for such information;
      3. Your request to withdraw Your consent to the acquisition, use, or disclosure of your Personal Data by giving notice to Us through the Contact Us and You understand that the withdrawal request may result in Your access to the Flip Application being limited/ no longer able to access the Flip Application.
          
6. Storage and Removal
   1. Your Personal Data that You input into the Flip Application as well as We obtain based on the provisions of Article 1 of this Policy shall be stored with security procedures and facilities in accordance with the provisions of the law for the period specified in the provisions under the Applicable Law in Indonesia.
   2. We provide any means for You to close Your Account in Our Flip Application and Features. This facility is available in the "Manage Account" menu, then you can follow the next steps, namely (i) stating the reason for closing the Account and (ii) input Your Account PIN, after which you will receive a notification that your Account has been officially closed. If You wish to close Your Account, You can also submit a request for the closure of the Account to Us by including the reason for deletion through the communication facilities mentioned in this Policy. In the event that You close Your account, You consciously understand the consequences that You cannot use Features and Flip Application or other Flip’s services because You are no longer registered as a user. Please be informed that even though You are no longer a registered user of the Flip Application, Your Personal Data can still be stored for the required period based on the provisions of the Applicable Law.
   3. We have the authority to block Your own Account based on Our terms, based on court decree or judgment, and/ or in accordance with law. We shall notify You by email regarding the blockade of Your Account under this authority.
   4. We have the authority to delete Your Personal Data based on Your written request or at Our discretion, in the manner that We specify but remain subject to the Indonesian Applicable Law.
7. Limitation of Liability
   1. You are responsible for security and implement appropriate measure in safeguarding Your Personal Data, such as, restricting access, creating strong passwords, protecting passwords, updating password from time to time (as required) and/ or protecting One-Time Password (OTP).
   2. We are not responsible for the exchange and/ or provision of Your Personal Data that You do personally, including what You do through the Flip Application.
   3. Our Flip Application may contain links to other websites. In case you use such links, you should understand that We do not have any control on such websites and / or Flip Application, therefore you understand and warrant that we are not / shall not be held accountable on the privacy policies of the sites / Flip Application of the other third party, based on such links and recommend You to read the privacy policy of each site / Flip Application You visit that collects Personal Data.
   4. We are only responsible for the protection and security of Your Personal Data to the extent that Personal Data is stored in a system developed and managed by Us and We at any time shall perform and take any reasonable effort that is required to protect and safeguard Your Personal Data. By continuing to access Our Flip Application, using Our Features, and / or other services, You waive the rights to file any claims, losses, demands and lawsuit that You may have in the event that failure of Personal Data protection arising from a part of negligence committed by Yourself in maintaining the security and confidentiality of Personal Data and/ or as a result of actions by third parties who attempt to obtain Personal Data unlawfully.
   5. We are not responsible for the originality, authenticity, validity, accuracy and/or completeness of the Personal Data You provided.
8. Miscellaneous
   1. We always try to provide the best services for You in accessing the Flip Application and using Our Features therefore We have the right to make changes to this Policy to perform adjustment for business developments and applicable legal provisions. Changes to this Policy shall from time to time be uploaded to the Flip Application so that You can read the changes from this Policy. If changes to this Policy are material to personal Flip Application data and information, We shall notify You no later than 30 (thirty) business days prior to the proposed changes take into effect or another time period as permitted by applicable laws and regulations ("Notice Period"). If You do not agree with the changes to the contents of the Policy proposed by Flip, then you can submit an objection and have the right to close your Account during the Notice Period. If You do not submit an objection to changes to the contents of the Policy submitted by Flip during the Notice Period, then Flip has the right to deemed that You agree to the changes and You are bound by all changes set forth by Flip.
   2. If there are provisions or parts of this Policy that are against the law, cannot be applied or become invalid, then the provisions or such parts shall be deemed has been removed from this Policy and We will adjust such provisions so that it can be performed, whereby the other provisions of this Policy shall remain in full force.
   3. In the event of a change of controller or a change in ownership of all or part of Our business, including the Flip Application, due to the performance of a merger, consolidation, acquisition, joint venture, transfer, bankruptcy, and/ or other corporate actions, Your Personal Data may/ shall be the part of the transfer based on such corporate actions.
   4. This Policy can be translated into other languages, other than Indonesian as provided by Us. It is possible that some parts of this Policy have different meanings, interpretation or definitions when translated into other languages. Should any differences occur in the interpretation between the Indonesian version and the other language version, the Indonesian version shall prevail and You are suggested to refer to the Indonesian version.
9. Contact Us
   1. You may submit questions, critics and suggestions, complains, or report that related to Personal Data by contacting Us through email [email protected]. All correspondence between You and Us may be noted or recorded by Us for Our interest.
   2. In order to respond to your questions or complaints, We will firstly verify Your data. We reserve the right to refuse the processing of Your question or complaint if the data that You provide does not match the data listed on Our system.
   3. We will give Our best endeavors to help You solve any problems that You experience. In order to improve Our services, any correspondence between You and Us may be noted or recorded by Us.
   4. You hereby state that understanding the conditions for submitting questions, criticisms and suggestions, complaints, or complaints in connection with Personal Data can only be done via email to [email protected] and cannot be done by telephone, email to a different email address and /or via social media in any form. Therefore, release Us from all civil lawsuits or criminal charges arising from Your failure and/or negligence in submitting questions, criticisms and suggestions, complaints, or complaints in connection with Personal Data as regulated in this Policy.

Updated on: August 12th, 2024

Previous version:  July 19th, 2024