Privacy Policy

  1. DEFINITIONS AND INTERPRETATION

    In this Privacy Policy:

    "We", "us", "our" means PT Cipta Andalan Manajemen Prima and its affiliated companies.

    "You", "your" means individuals who are subject to this Privacy Policy.

    "Personal Data" means any data or information, whether true or not, and whether recorded in material form or not, about an identified or identifiable individual, including but not limited to name, identification number, location data, contact details, financial data, online identifiers, or specific factors related to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual, as defined in applicable data protection laws, including but not limited to Law of the Republic of Indonesia Number 27 of 2022 on Personal Data Protection and its implementing regulations.

    "Principal" means third-party providers of financial products and/or services licensed by the Indonesian Financial Services Authority (OJK), with whom we have cooperation agreements to offer and/or facilitate access to their products as part of the Services provided through the Site.

    "Service Providers" means our third-party issuers, advertisers, vendors, business partners, and contractors, whether existing, ongoing, or future.

    "Services" means products, services, content, features, technology, or functions offered on websites, applications, and services operated by us or our Principals.

  2. YOUR CONSENT

    1. This Privacy Policy applies to personal data of every individual that we possess or control, and will govern your use of the Services. This Privacy Policy is in addition to other terms and conditions that may apply in connection with your use of the Services.
    2. You are deemed to have accepted this Privacy Policy when you provide your personal data to us or register, access, or use our Services.
    3. Notwithstanding the above, you may withdraw your consent for us to collect, use, or disclose your personal data, but this may affect our ability to provide Services to you. We will not be responsible for any failure to provide Services to you if such failure is caused by your withdrawal of consent or deletion of your personal data at your written request.

  3. COLLECTION OF PERSONAL DATA

    1. We may from time to time collect your personal data to provide Services to you and also to enhance your experience. Such personal data may include:

      1. general identification and contact information (e.g., name, address, email address, phone number, age, date of birth, gender, username, password, etc.);
      2. financial information and account details (e.g., bank account number, credit card number, assets, liabilities, salary, etc.);
      3. information from cookies, pixel tags, web beacons, and similar technologies;
      4. images, photos, closed-circuit television (CCTV) recordings, voice recordings, and electronic communications;
      5. data about pages you access, your Internet protocol address, your device's unique identifier, your device type, your geographic location information, your mobile network information, referral URLs, page view statistics, and other information automatically sent to us by your device or service provider; and
      6. other information you may provide to us.

    2. Your personal data may be collected:

      1. automatically (e.g., when your device or service provider automatically sends such data to us);
      2. from you (e.g., when you submit web forms to us, add or update your account information, participate in discussions, chats, or dispute resolution, or correspond with us); and
      3. from third parties (e.g., from social media sites).

  4. USE OF PERSONAL DATA

    1. Core Business Purposes. We may use your personal data to:

      1. provide our Services to you; measure the performance of our Services; monitor Services provided by or through us;
      2. verify your identity; conduct due diligence checks for our internal purposes;
      3. facilitate your onboarding process with our Principals and to meet our Principals' requirements in the event you choose to access or use certain Services;
      4. determine your geographic location, provide localized or targeted content, provide customized or personalized recommendations or content to you, determine your Internet service provider, respond to any queries, requests, or feedback; optimize our selection and recommendation algorithms and delivery;
      5. communicate with you (such as via email, text messages, online messages, push notifications) to assist you with operational requests such as password reset requests;
      6. prevent, detect, and investigate fraud or other potentially prohibited or illegal activities; to detect, prevent, and recover from any violations of our policies or terms and conditions;
      7. handle or investigate any complaints, claims, or disputes;
      8. handle requests for data access or correction;
      9. analyze and understand our users; improve our services (including our user interface experience); participate in industry exercises and studies;
      10. train employees and Service Providers; monitor quality assurance;
      11. enforce any obligations owed to us;
      12. seek professional advice, such as legal advice;
      13. prepare and maintain financial reporting, regulatory reporting, management reporting, risk management, audit, and record-keeping purposes;
      14. enable any actual or proposed assignee, transferee, participant, or sub-participant of our rights, business, or obligations to evaluate the proposed transaction; negotiate a business transaction, including (but not limited to) any financing, merger, acquisition, or liquidation;
      15. manage our business infrastructure and operations (including information technology infrastructure) and comply with internal policies and procedures;
      16. conduct due diligence and comply with tax enforcement, sanctions, or prevention or detection of money laundering, terrorism financing, or other illegal activities;
      17. comply with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any authority (whether local or foreign), including regulatory, government, tax, and law enforcement authorities or other authorities; and
      18. any other purposes specifically set out in certain products or services we offer or as permitted or required by law or relevant authorities.

    2. Marketing Purposes. We may also use your personal data to:

      1. offer our Services to you (such as special offers, promotions, contests, or rights that may interest you or that you may qualify for), through various communication modes such as email, short message service (SMS), and push notifications; and
      2. enhance and personalize Services, content, and advertising. If you do not wish to receive marketing communications from us or participate in our advertising personalization programs, please notify us.

  5. DISCLOSURE AND TRANSFER OF PERSONAL DATA

    1. We may from time to time disclose your personal data to our employees, personnel, our Principals, our Service Providers, or to third parties, whether located in Indonesia or elsewhere, to carry out the purposes mentioned above. When we disclose your personal data to such persons or parties, we will require them to comply with this Privacy Policy.
    2. We may transfer, store, process, and/or handle your personal data in accordance with applicable data protection or privacy laws.

  6. RETENTION

    1. Your personal data will be retained for as long as the purpose of collection exists and until the data is no longer needed for any other legal or business purposes.

  7. ACCESS AND CORRECTION

    1. You may request access to or make corrections to your personal data that we hold, but we may charge a fee to process your access request.
    2. If you believe that your personal data held by us is inaccurate, incomplete, or outdated, please notify us. We will endeavor to respond within a reasonable time and, if necessary, promptly correct any personal data found to be inaccurate, incomplete, or outdated.

  8. COOKIES AND RELATED TECHNOLOGIES

    1. When you access or use our Services, we may store some data on your device using technologies such as cookies or other local storage provided by your browser or application (collectively referred to as "Cookies"). Such data is stored on your device to enable us to (i) provide Services; (ii) recognize, identify, or authenticate you; (iii) customize our Services for you; (iv) provide advertising; (v) provide our measurement and reporting; and (vi) fulfill other purposes mentioned above.
    2. You are free to refuse or block our Cookies (to the extent permitted by your browser or application), but this may interfere with the provision of our Services and you may not be able to use certain features or functions of our Services. We will not be responsible for any failure to provide any Services to you if such failure is caused by our Cookies being refused or blocked.
    3. We may also use other technologies (such as pixel tags or web beacons) for the purposes mentioned above.

  9. CHANGES TO THIS PRIVACY POLICY

    1. We may from time to time modify this Privacy Policy by posting a revised version of this Privacy Policy on our Site. We will provide notice to you on the Site or via email. The revised version will be effective from the published effective date. If you continue to use our Services after the notice period, you will be deemed to have accepted the changes made in the revised version.

  10. CONTACT US

    1. For any questions or notifications regarding your personal data, please contact our Data Protection Officer at compliance@campinvestasi.id.