Privacy Policy

Singapay wants to give you the best possible experience in enjoying the financial services we provide, both now and in the future. The privacy and security of your Personal Data will always be of the utmost importance to us. Therefore, we set out transparently how we collect, store, and use your Personal Data as described below:

General Provisions

This Privacy Policy applies to the services provided by PT Abadi Singapay Indonesia (“PT ASI” or “Singapay” or “We/Us”). This Policy explains how We collect, use, store, transfer, protect, and disclose Users’ personal data, personally identifiable information, or other personal information (collectively, “Personal Data”) in connection with Users’ access to and use of the Singapay mobile application (the “Singapay Application”).

As further explained in the Terms and Conditions for Singapay Users (the “Terms and Conditions”), the Singapay Application is an integrated service application designed by PT ASI for its users. The application is provided free of charge to registered Users.

Registration and ownership of an account on the Singapay Application may only be carried out by individuals who are at least 17 (seventeen) years of age. If you do not meet the age requirement, the submission and processing of your Personal Data may only be carried out with the consent of your parent and/or legal guardian in accordance with applicable laws and regulations. If We become aware of any processing of Personal Data that does not meet these requirements, We will delete such Personal Data. PT ASI is a non-bank institution under the supervision of Bank Indonesia as the authority with the power to regulate the operation of payment systems.

Users are required to provide and update Personal Data from time to time in connection with access to and use of the Singapay Application. By agreeing to this Privacy Policy, the User declares that they have understood and accepted the provisions of this notice regarding the collection, use, storage, processing, and disclosure of Personal Data as set out herein.

If the User does not provide the requested Personal Data, this may result in Us being unable to provide the Singapay Application services to the User or to fulfil obligations under laws and regulations as well as guidelines established by the competent agencies or authorities.

Personal Data includes, but is not limited to, name, address, place of birth, date of birth, occupation, telephone number, facsimile number, bank account, gender, identity numbers issued by competent agencies or authorities (including KTP, driving license (SIM), and Passport) or other government-issued identification, photographs, nationality, telephone numbers of Singapay users and non-users contained in the Singapay User’s mobile phone contact list, biometric information (including but not limited to facial recognition), and other information that, directly or indirectly, whether separately or in combination with other information, can be used to identify the User. Specifically with respect to the telephone numbers of Singapay non-users contained in the User’s mobile phone contact list, processing by Singapay is limited solely to matching purposes in order to support the transfer-between-Users feature, is not stored permanently, and is not used for any other purposes. The User warrants that they have obtained the consent of the relevant contact owners before granting contact list access to Singapay. Owners of non-user telephone numbers may submit an objection and/or a request for deletion of their data through Singapay’s official channels, and Singapay will follow up in accordance with the laws and regulations on personal data protection.

Please read this Privacy Policy carefully to ensure that, as a User, you fully understand and agree with the way we obtain, process, use, store, and disclose Users’ Personal Data.

Unless otherwise defined in this Privacy Policy, capitalized terms have the same meanings given to them in the Terms and Conditions.

Obtaining and Collection of Personal Data

Singapay may obtain Users’ Personal Data from various sources (for example, from the User or through third parties) at any time, including but not limited to when the User accesses the Singapay Application or conducts transactions using the Singapay Application, including data relating to:

1. Information obtained (directly or indirectly) when the User accesses the Singapay Application, relating to information about the computer, telephone device, other hardware components, software, and telecommunications networks used by the User to access and use the Singapay Application (including the User’s IP address, geographic location, browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/use, page views, and any search terms the User uses) (“Device Information”).
2. Information obtained (directly or indirectly) when the User registers to create a Singapay Account, including the User’s name, date of birth, address, telephone number, email address, photograph, and identity card (including KTP, driving license (SIM), and Passport) (“Registration Information”).
3. Information obtained (directly or indirectly) while the User uses the Singapay Application, including the User’s bank account number, billing and delivery information, transaction data, and other information from checks or money orders (“Account Information”).
4. Information obtained when the User updates their information or at other times as may be requested by Singapay from the User as needed from time to time.
5. The Device Information, Registration Information, and Account Information above and other information may be accessed or collected (automatically or manually) upon the User’s registration of a Singapay account as a user of the Singapay Application and/or during the User’s use of the Singapay Application and Singapay Account.

The above information that we obtain may constitute the User’s Personal Data. We have taken steps to ensure that we do not collect information (regardless of whether such information constitutes Personal Data or not) from Users beyond what we need to provide our services to Users, to perform the functions set out in Section 3 of this Privacy Policy, to protect the User’s Singapay Account, to comply with our legal obligations, to protect our rights under the law, and to operate our business.

Singapay may collect Users’ Personal Data from third parties (including agents, vendors, suppliers, contractors, partners, and other parties providing services to Singapay or other partners cooperating with Singapay). In such cases, those third parties are responsible for obtaining the necessary consents from the authorized parties for the collection and disclosure of Users’ Personal Data to Singapay, and Singapay will process the Personal Data in reliance on the consent obtained by such third parties. In this regard, Singapay will use the User’s Personal Data for the purposes of Singapay’s cooperation with such third parties.

Use of Personal Data

We may process, analyze, and/or use the Personal Data we obtain about Users for the following purposes as well as other purposes permitted by applicable laws and regulations, including:

1. Verifying the eligibility and/or suitability of the User’s data for use of the features and functions in the Singapay Application, or any verification that Singapay deems necessary before providing services to the User or before Singapay registers the User, including but not limited to the Know Your Customer (KYC) process.
2. Identifying and processing the registration of the User’s Singapay Account, as well as maintaining and managing the User’s registration.
3. Processing and managing the Singapay User’s Balance.
4. Providing services to Users and customer services relating to the use of the User’s Singapay Account, including collaborating with Singapay to facilitate payment for purchases of goods and services, delivery and other services related to purchases, applying charge-backs, sending notifications regarding the User’s transactions and bills, and responding to questions, feedback, complaints, claims, or disputes from Users.
5. Providing services to Users relating to the User’s use of the Singapay Application, namely making it easier for Users to identify other Singapay Application Users when viewing their mobile phone address book through the Application.
6. Improving and developing our offerings through research and development of new functions of the Singapay Application or other new products and services that we may offer from time to time.
7. Conducting research, statistical analysis, or surveys, whether oral or written, to manage and protect our business including our information technology infrastructure, to measure the performance of the Singapay Application and other services we offer, and to ensure your satisfaction with our services.
8. Conducting analysis of trends, usage, and other behaviors (whether individually or in aggregate) that help us better understand how Users and our user base access and use the Singapay Application and the commercial activities conducted through the Singapay Application, including for the purpose of improving services and responses to customer inquiries and preferences.
9. Subject to obtaining the User’s consent in accordance with applicable law as referred to in Section 4 below, we may use Personal Data to provide direct marketing information to the User in relation to the services we offer, and our affiliates and selected third parties may use the User’s Personal Data to contact the User by telephone, short message service (SMS), electronic mail (e-mail), post, and facsimile.
10. Managing risk, conducting checks on creditworthiness and ability to pay (solvency), or assessing, detecting, investigating, preventing, and/or remediating fraud or activities that potentially violate or violate laws and regulations and Singapay’s interests, or protecting the integrity of our information technology platform.
11. Detecting, investigating, preventing, or remediating violations of the Terms and Conditions, the Privacy Policy, all Singapay internal policies applicable from time to time, industry standards, guidelines, laws, or related regulations.
12. Making disclosures as may be required by the laws or regulations of any country applicable to us or our affiliates, government officials, or third parties, including electronic money operator associations or other payment networks and other relevant industry associations. Disclosures may also be made in connection with court summonses, court judgments and/or orders, orders of authorized law enforcement officials in the context of investigations, inquiries, or other legal processes, or any requirement in any country applicable to us or our affiliates (including anti-money laundering and counter-terrorism financing reporting requirements).
13. Making a disclosure to prevent harm or financial loss, to report any suspected illegal activity, or to address any claim or potential claim brought against us or our affiliates.
14. Conducting due diligence and other assessments or evaluations of actual or proposed mergers, acquisitions, financing transactions, or joint ventures.
15. Notifying Users of any updates to the Singapay Application or changes to Singapay services.
16. Developing and improving the quality of the application to meet Singapay Users’ needs and preferences with respect to features currently held or to be developed by Singapay in the future.
17. Monitoring and analyzing the activities, behavior, and demographic data of Singapay Users, including habits and usage of the various services available in the Singapay Application.
18. Offering or providing services from partners or affiliates cooperating with Singapay to Users.
19. Sending information, advertisements, surveys, promos, vouchers, and other information deemed relevant by Singapay to Users.
20. Providing technical assistance or resolving technical obstacles and operational issues occurring in the Singapay application.
21. Facilitating business asset transactions (which may take the form of a merger, acquisition, spin-off/separation, or asset sale) involving Singapay and/or Singapay’s affiliates.
22. For other legitimate business purposes, such as protecting Users and other users of the Singapay Application from losses, protecting life, maintaining the security of our products and systems, and protecting our other interests, rights, and/or property.
23. We may also use the User’s Personal Data in other ways, for which we will provide specific notice at the time of collection of such data, to be consented to by the User.

Disclosure of Personal Data

The User’s Personal Data that we store will be kept confidential; however, we may provide the User’s Personal Data to the following parties (whether inside or outside the User’s country of residence) for the purposes set out in Section 3 above:

1. Companies within the Singapay group and companies affiliated with members of the Singapay group.
2. Agents, contractors, and third-party service providers cooperating with Singapay in providing our services to Users, including for fraud prevention, bill collection, data entry, database management, promotion, marketing, research, surveys, customer service, technology services, product and service notifications, and payment extension services.
3. Entities with whom we have business referral relationships or other commercial agreements, including third parties and entities wholly or partly owned by PT ASI.
4. Merchants and other organizations, such as electronic money operator associations, payment networks, or financial institutions, to or through whom payments are made using Singapay, or other entities that enable the use of the Singapay Application by third-party financial institutions, banks, receiving agents, financing institutions, and others.
5. Third-party service providers.
6. Professional advisors, law enforcement agencies, insurance companies, governments, and other authorities or agencies where PT ASI is obligated to make disclosures as needed, upon lawful request, and under applicable law, regulations, or commercial arrangements, including arrangements with card associations or payment networks, or other relevant industry associations.
7. Entities involved in mergers, acquisitions, financing transactions, or joint ventures with us.

Singapay may also disclose and share the User’s Personal Data with the parties mentioned above for the following purposes:

1. To improve the quality of the services provided by Singapay to Users from time to time.
2. Where required or permitted by applicable laws and regulations, or upon the order and/or official request of authorities, agencies, state institutions, and/or law enforcement officials.
3. For the purposes of legal proceedings of any kind between the User and Singapay.
4. For audit purposes, whether routine or incidental, as required from time to time.
5. For the purposes of processing licenses, registrations, or filings required for Singapay’s business activities.
6. For any verification processes required before registering the User as a User, including the Know Your Customer (KYC) process.

Singapay will not sell or rent the User’s Personal Data to other parties. Other than as set out above, Singapay may disclose and share the User’s Personal Data for other purposes and/or to other parties after obtaining the User’s consent for such disclosure.

Security Measures and Storage

We take all reasonable and maximal steps, including providing technical, administrative, and physical safeguards, to help protect the User’s Personal Data that we process from the risks of loss, misuse, unauthorized access, disclosure, alteration, and unwanted destruction.

We will store, and ensure that our service providers also store, Users’ Personal Data only for as long as needed for the purposes set out in this Policy and in accordance with applicable laws and regulations.

Users’ Personal Data will only be stored for as long as necessary to fulfil the purposes for which it was collected, or for as long as such storage is required or permitted by laws and regulations.

For Users registered with Singapay, registration information and User Account information (if any) can be viewed and modified in the Singapay Application through the User’s Account, which is protected by a password, PIN code, or other security method.

We remind Users not to disclose their password, PIN code, or other security keys to any party. Our employees, officers, agents, and representatives do not know and will never ask for a User’s password in unsolicited telephone communications or unsolicited emails.

If the User uses a device that can be accessed by others (for example, a public device), the User should choose not to save login information on that device. The User is responsible for the confidentiality of their account details, including passwords, PIN codes, and One Time Passwords (OTP), as well as for the security of the device used.

Third-Party Services

The Singapay Application may provide links to other websites and services (including applications operated by third parties) for the User’s convenience and information. Such services and websites may operate independently of us and may have their own privacy notices or policies.

We advise Users to first read the privacy policies of such sites or services before using them or conducting any activity on them. The provision of links to other websites and services is provided for information purposes only.

We do not provide any endorsement or warranty of any kind regarding the content and information contained in such links. With respect to websites visited by the User that are not owned or controlled by us, we are not responsible for the content, privacy practices, and service quality of such third parties.

Changes to this Privacy Policy

Singapay holds the exclusive right to amend, supplement, and/or revise the notices and information relating to this Privacy Policy from time to time. In the event of changes, the User will be asked to give their consent to the amended, supplemented, and/or revised version of the Privacy Policy.

If the User does not give consent to the latest version of the Privacy Policy, Singapay has full authority to discontinue the provision of services in the Singapay Application to the User.

The User agrees that they are responsible for reviewing this Privacy Policy periodically to obtain up-to-date information regarding Singapay’s data processing and data protection practices.

Other Provisions

1. This Privacy Policy is subject to, governed by, and implemented in accordance with the laws of the Republic of Indonesia.
2. In the event of a dispute over the interpretation and implementation of this Privacy Policy, the User and PT ASI agree to resolve it through amicable deliberation.
   If within 30 (thirty) calendar days the deliberation does not result in an agreement, the dispute will be resolved through the Tangerang District Court.
3. We will implement information security systems that we consider adequate and consistent with industry standards or applicable legal provisions.
   However, the transmission of information through communication networks is not entirely secure and may involve risks. Therefore, any transmission of information by the User to us is carried out at the User’s own risk.
   We do not guarantee the complete security of our database, and cannot guarantee that data sent by the User to us will always be delivered without disruption or delay.

Declaration

By using the Singapay Application, the User declares that they have read, understood, and agreed to this Privacy Policy, including the collection, use, processing, storage, disclosure, and deletion of Personal Data as set out in this Privacy Policy.

Keeping Your Data Secure

Singapay is committed to protecting Users’ Personal Data and strives to implement the best technical measures in accordance with industry standards and applicable legal provisions to ensure the security of Users’ data.

Nevertheless, Users need to be aware that no system is completely secure. Therefore, Users must also safeguard the security of their Singapay Account by protecting possession of the mobile number and device used to access the Singapay Application, and by using and keeping confidential a strong and unique password and/or PIN code to avoid unauthorized access.

Storage, Access, Correction, Updating, and Deletion of Your Data

Singapay stores Users’ Personal Data for as long as necessary to provide Singapay services and for legitimate and essential business interests, including:

1. To maintain the performance and quality of services across the features of the Singapay Application.
2. To make business decisions based on the data provided by Users for the purposes of product development and service quality improvement.
3. To resolve unresolved issues relating to the User’s account, such as chargebacks, refunds, or other disputes, in which case the Personal Data will be retained until such issues are resolved.
4. To fulfil legal, tax, audit, and accounting obligations for the periods required by applicable law.
5. For other legitimate purposes as previously mentioned, such as fraud prevention or the protection of User security.

The User has the right to:

1. Request access to their Personal Data history,
2. Make corrections or updates to their Personal Data, and/or
3. Request the deletion of their Personal Data.

In such cases, we will provide the information in a format determined by us.

Further Information

If the User wishes to ask questions or submit a complaint, please contact Singapay Customer Service via:

PT ABADI SINGAPAY INDONESIA (SINGAPAY)
Foresta Business Loft 5, Lengkong Kulon,
Kecamatan Pagedangan, Kabupaten Tangerang, Banten 15331
Business Hours: Monday – Friday / 09.00 – 18.00 WIB
Telephone: 021 – 38929036
Email: cs@singapay.id

By agreeing to this Privacy Policy, you declare that you have read and understood the entire contents of this Privacy Policy, and grant consent to Singapay to collect, use, share, disclose, store, transfer, and/or process your Personal Data in accordance with the provisions of this Privacy Policy.