Privacy Policy

Version 1.0

PT Media Indonusa ("Faspay" or "We"), a limited liability company incorporated under the laws of Indonesia, provides payment platforms and services to support online business activities. In the performance of the Services, We collect data about our business and customers ("Data"). This Privacy Policy describes how We collect, use and disclose such Data. 

In this document, the term "You" refers to the visitor of Our site, the user of Our Services ("User"), or the User's Customer ("Customer"). We seek to provide clarity as to who this Privacy Policy applies to in each point. This Policy does not cover third-party sites, products, or services that may be connected to Our Services. If you do not agree with the practices in this Privacy Policy, please immediately stop using Our Services and delete cookies from your device after leaving Our site.

1. PURPOSE

The data We collect depends on how the Services are used. We obtain Data both directly, such as when a Faspay account is created or a transaction is made, and through interaction with technology such as cookies. In addition, We receive Data from third parties such as identity verification services. This Data Collection is essential to provide Our Services, improve the security of online payments, and reduce the risk of fraud, money laundering, and other malicious activities. 

2. DATA WE COLLECT

  1. Personal data. Data that identifies, or can reasonably be used to identify, you as an individual, We refer to as "Personal Data". We use several ways to collect Personal Data. For example, We collect Personal Data when a company registers to create a Faspay account, a Customer makes a payment or transaction through the User's website or application, someone responds to an email or survey of Faspay. We also receive Personal Data from a variety of other sources, such as Our partners, identity verification services, and other publicly available sources. Personal Data does not include Data that has been collected or made anonymous so that it can no longer be reasonably associated with a particular individual. The Personal Data We may collect includes: 
    • Contact details, such as name, mailing address, phone number, email address; 
    • Financial and transaction data, such as credit or debit card related information, and other bank account related information; and 
    • Other Personal Data, such as date of birth, other government-issued identifiers 
  2. Other Data. Data that is not Personal Data, we refer to it as "Other Data". We collect Other Data through a variety of sources. One of the sources of Our Other Data is cookies and other technologies that record Data related to the use of Our site, the sites that implement Our Services, and the general use of Our Services. Other Data We Collect includes:
    • Browser and device data, such as IP address, device type, operating system and internet browser type, screen resolution, name and version of the operating system, factory and model of the device, language, plug-ins, add-ons, and version of the Services you are using; 
    • Transaction data, such as purchases, purchase amounts, purchase dates, and payment methods; 
    • Cookies and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and 
    • Company data, such as the company's legal structure, products and services offered, jurisdiction, company records, and information filed. 

(Personal Data and Other Data are collectively referred to as "Data") 

3. HOW WE USE DATA

  1. Personal Data. We use Personal Data to: (i) provide the Services; (ii) detecting and preventing fraud, (iii) mitigating financial losses or other harm to Users, Customers, and Faspay, and (iv) promoting, analyzing and improving Our products, systems, and tools. Examples of the use of Personal Data that We may do include:
    • To verify identity for compliance purposes;
    • To evaluate applications to use Our Services; 
    • To conduct manual and systematic supervision of fraud and other dangerous activities; 
    • To respond to inquiries, send service notifications and provide customer assistance; 
    • To process payments with various Faspay products, communicate about a payment, and provide related customer assistance; 
    • For audits, regulatory purposes, and compliance with industry standards; 
    • To develop new products; 
    • To send you marketing communications; 
    • To improve or modify Our Services; and 
    • To conduct analysis and aggregation that enables Us to operate, protect, make informed decisions, and report on the implementation of Our business. 
  2. Other Data. We may use Other Data for a number of purposes, provided that We comply with applicable law and Our contractual commitments. Where applicable, local regulations may require Us to treat some or all of the Other Data as "personal data" under applicable data protection laws. In such case, We will process Other Data only for the same purposes as Personal Data under this Privacy Policy; 

(the data processing purposes referred to in this Privacy Policy are referred to as the "Data Processing Purposes") 

We may, from time to time, appoint processors and/or sub-processors of Data (including but not limited to Our partners) to be able to perform certain parts of the collection, processing and storage of Data in accordance with the Data Processing Purposes. 

4. HOW WE DISCLOSE DATA

Faspay does not sell or rent Personal Data to marketing parties or unaffiliated third parties. We share your Personal Data with trusted third parties, including: 

  1. Provider. We share Data with service providers who help Us provide the Services ("Service Providers"). Service providers assist Us in matters such as payment processing (e.g., banks, payment method providers), site hosting, data analysis, information technology and related infrastructure, customer service, sending e-mails and audits; 
  2. Our Users. We share Data with Users (such as Merchants) as necessary to process payments or provide the Services. For example, We share Data with Users regarding purchases made by their Customers through Faspay's payment processing services; 
  3. Third parties who have authority. We share Data with parties who are directly authorized by the User to receive Data, such as when the User authorizes a third-party application provider to access the User's Faspay account. Use of Data by authorized third parties is subject to the privacy policies of such third parties; 
  4. Third Parties. We will share Data with third parties (where it is necessary to know) in the event of a reorganization, merger, sale, joint venture, transfer, transfer or other disposition or all or any part of Our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and 
  5. For Security, Legal, and Law Enforcement Purposes. We use and disclose Data that We deem necessary: (i) under applicable law or payment method rules; (ii) to enforce Our terms and conditions; (iii) to protect the rights, privacy, safety or property of Us, You, or others; and (iv) to respond to requests from courts, law enforcement officials, regulators, and any other public and governmental authorities, which may include authorities outside of the country in which you reside. 

5. SECURITY

We store all Customer data in an encrypted database. Sensitive systems with isolated physical and logical access and access rights are limited to authorized personnel only. We restrict access to data based on job functions. 

We use reasonable organizational, technical and administrative efforts to protect Personal Data within Our organization. Unfortunately, no transmission or storage system can be guaranteed to be 100% secure. If You have reason to suspect that Your interaction with Us is no longer secure (for example, if you feel that the security of your account is compromised), please stop using Our Services immediately and contact Us. 

6. ADVERTISING

We may use third-party advertising companies to serve advertisements for goods and services that may be of interest to you when you use Our site, based on Data relating to your access to and use of Our site on your device, as well as Data We receive from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on your browser. They may also use these technologies, along with the data they collect about your network usage, to recognize you from the various devices you use, such as mobile phones and laptops, and to make decisions about the ads you see. 

7. CHOICE AND ACCESS

You have choices regarding the use and disclosure of Your Personal Data by Us: 

  1. Opt out of receiving electronic communications from Us. If you no longer wish to receive marketing-related emails from Us in the future, you may opt-out via the unsubscribe link provided in the email. We will endeavour to comply with your request(s) as soon as practicable. Please note that if you opt out of receiving marketing-related emails from Us, We may still send you important administrative messages that are required to provide Our Services to you. 
  2. How you can access or change your Personal Data. If you wish to review, correct, update or delete Personal Data that you have previously disclosed to Us, you may do so by contacting Us. Please note that if You ask Us to delete the Personal Data that You have previously disclosed to Us, then this may affect Our ability to provide some or all of the Services to You. 

In sending us your request email, please clearly state in the email what Personal Data you wish to change. For Your protection, We may only carry out requests in relation to Personal Data associated with the email address You used to send Your request to Us, and We may need to verify Your identity before carrying out Your request. We will endeavour to comply with your request as soon as practicable. 

8. STORAGE PERIOD

We will retain Personal Data for as long as is necessary to fulfill the Data Processing Purposes unless a longer period of time is required or permitted under the laws and regulations (for 5 (five) years based on the applicable laws and regulations), or when You send a written request to Us to delete and destroy Your Data. We may destroy your Data by means of deletion, destruction, sanitization, or overwriting (subject to limitations in Our systems) which will be followed up with a notice that We have fulfilled Your request. Your written request constitutes Your acknowledgment that You will not hold Us accountable if we are unable / unable to comply with Your request for Services. In any event, We warrant that the Data that we destroy will cause the Data to no longer be used for any purpose. 

Please note that We have various obligations to retain the Data that You provide to Us, including to ensure that transactions can be processed appropriately, settled, returned or recharged, to help identify fraud and to comply with anti-money laundering laws and regulations and other laws and regulations applicable to Us and to Our financial service providers. Thus, in the event that You close Your Faspay Account, We will store certain Data to fulfill Our obligations. There may also be residual Data that may remain in Our database and other records, which will not be deleted to the extent permitted by applicable laws and regulations. 

9. FASPAY AS A DATA PROCESSOR

We may collect, use and disclose certain Personal Data about Customers when acting as a provider of User services. Our Users are responsible for ensuring that the Customer's privacy rights are respected, including ensuring appropriate disclosure regarding the collection and use of Our and third parties' data. To the extent that We act as a processor of the User's data, We will process the Personal Data in accordance with applicable regulations and/or the terms of Our agreement with the User and the User's lawful instructions. 

10. UPDATES TO THIS PRIVACY POLICY AND NOTICE

We may make changes to this Privacy Policy. The "Last updated" section at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will take effect when We publish the amended Privacy Policy on the Faspay website. You have an obligation to review this Privacy Policy periodically; You are bound by any changes to this Privacy Policy if you continue to use the Services after such changes are first posted. 

In the event of a security incident or breach of the confidentiality of personal data, We will respond to such incident or breach in accordance with our internal policies consistent with applicable data protection laws and regulations, which may include, among other things, sending timely notice to You and/or the relevant data protection authority. 

11. CONSENT AND ACKNOWLEDGMENT

By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and that you accept all of its terms. In particular, You understand and agree that We collect, use, share, disclose, store, transfer, and process Your Personal Data in accordance with this Privacy Policy. In circumstances where You provide Us with Personal Data relating to another individual (such as Personal Data relating to Your spouse, family member, friend, or other party), You represent and warrant that You have obtained the consent of such individual to, and hereby consent on behalf of such individual to, the collection, storage, use, disclosure, processing and deletion of Personal Data by Us. 

12. HOW TO CONTACT US

If you have any questions regarding the privacy policy, or have any suggestions related to privacy and Faspay services, please contact us via email customercare@faspay.co.id.