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Introduction

 

This Privacy Policy applies to the digital services jointly provided by PT Nex Teknologi Digital, PT Sumber Digital Teknologi, PT Sinar Digital Terdepan and their affiliates (“Nex”, “we”, “us” ours” “affiliate”), and sets out how we may (i) acquire; (ii) collect; (iii) process; (iv) analyze; (v) store; (vi) display; (vii) announce; (viii) transfer (ix) disseminate; (x) disclose; (xi) delete and (xii) utilize the User’s “personal data”, “personally identifiable information” or other personal information (collectively, “Personal Data”) in connection with User’s access to and use of Nex’s mobile application (“Nex”).

The utilization of Nex by you as the User confirms your approval and participation upon this Privacy Policy.

As described further in the Nex Terms and Conditions (“Terms and Conditions”), Nex is a mobile payments and financial services app designed by Nex for Users. Nex provides a gateway for registered Users to access electronic payment and other financial services. Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meaning ascribed to them in the Terms and Conditions

Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices.

1. What information is covered by this Privacy Policy?

 

This Privacy Policy covers all personal information processed by us which means information that (either alone or combined with other information) enables you to be identified directly or indirectly.

2. What personal information do we collect?

 

2.1 We collect the following personal information, whether from you and/or other publicly available sources:

  • Personal particulars of you or of other persons as provided by you or permitted access by you;

  • Sensitive personal information such as biometric identifiers (e.g. fingerprints and/or facial image) used for verification purposes;

  • Sensitive personal information when conducting checks to comply with applicable laws and regulations for the purposes of detecting and preventing financial crimes;

  • If you utilize and/or when a payment or transfer is made through the digital payment facility provided by us, if you are the payer or sender, you will provide us the information relating to the utilization, payment or transfer, including but not limited to the transfer and/or payment receiver details, the amount of payment paid, the type of payment card or account used, the name of the issuer of that payment card or account, the name of the holder for that payment card or account;

  • If you intend to add your payment card or account as a source of fund for payment in the Application, you will provide us information relating to the type of payment card or account registered, the issuer of that payment card or account, the name of the holder for that payment card or account, the identification number of that payment card or account and the verification code of that payment card or account and the expiration date of that payment card or account, as applicable;

  • Credit information, including but not limited to your credit standing and financial position, from national credit bureaus, credit evaluation service providers and online and other retailers, used for credit evaluation, risk management and credit modelling purposes; and

  • Other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.

2.2 Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with personal information, then that information is also considered personal information. The personal information which we collect may be provided by you directly or by third parties (for example: when you register or use Nex, when you contact our customer services, or you otherwise provide personal information to us). We may collect information in various forms and purposes (including purposes permitted under applicable law).

2.3. When you provide another person’s personal information to us, you confirm that you have notified that person of our collection of that person’s personal data and gotten the consent of that person for the collection, use and disclosure of that person’s personal information to be used as described in para (3) below.

3. How do we use your personal information?

 

3.1 We may (i) acquire; (ii) collect; (iii) process; (iv) analyze; (v) store; (vi) display; (vii) announce; (viii) transfer (ix) disseminate; (x) disclose; (xi) delete and (xii) utilize your information to:

  • Create, improve, administer and deliver products and services, benefits and privileges;

  • Provide you with our services, including but not limited to processing any of your transactions;

  • Enable our service providers, partners and affiliates, to provide you with the services as you have requested;

  • Communicate with you and to send you information in connection with the use of Nex;

  • Notify you of any updates to Nex or changes to the services available;

  • Process and respond to enquiries and feedback received from you;

  • Offer or provide services from our affiliates or partners;

  • Meet compliance requirements;

  • Perform financial crime risk management activity;

  • Collect any money owed to us;

  • Perform credit evaluations and obtain or provide credit references;

  • Enforce and defend the rights of a member of Nex;

  • Manage our relationship with you;

  • Enforcing obligations owed to us;

  • Administering benefits or entitlements in connection with our banking relationship with you, including the administration of loyalty rewards programmes, lucky draws, and/or sending gifts and awards;

  • Validate information and verify your identity and instructions, as well as to investigate any misuse of our services;

  • Conduct research and analytics; and

  • Enable us to comply with our obligations under any applicable law, including but not limited to responding to regulatory enquiries, investigations or directives, complying with regulatory filing, reporting, and licensing requirements, and conducting audit checks, due diligence and investigations.

  • For other notified purposes with your consent

 

3.2 We may record and keep track of your interactions with us including phone calls, face-to-face meetings, letters, emails, and any other kinds of communication, with or without the use of an automatic tone or other warning device. We may use these records to check your instructions to us, assess, analyze and improve our service, train our people, manage risk or for the other purposes described above. Notwithstanding the above, we are not obliged to make any note or recording, or maintain copies of any notes or recordings, and the failure to do so shall not in any way prejudice our rights.

 

3.3. We use cookies in our application to collect information about users of our application (for example, store users’ preferences and record session information). A cookie is a small text file that an application can send to our database, which stores certain information on your system. This information is shared with us so that we can provide a more personalised service to you. You can adjust the settings in your mobile device so that you will be notified when you receive a cookie. You may at any time disable the cookies by changing the settings on your browser or via your mobile device. However, by doing so, you may not be able to use certain functions or enter certain part(s) of our application.

4. Do we use your personal information for marketing?

 

We use certain parts of your personal information to personalise our marketing to you, so that you will be notified of events, promotional offers, products and services (whether provided by us or by our business partners) which you may be interested in. However, you may at any time inform us that you do not wish to receive such marketing information.

5. How do we share your personal information with third parties?

 

We may transfer your personal information with the following:

 

5.1 Nex, Partner and affiliates: We may share your personal information with our affiliates (our “Partner”), in order to open and manage your account(s) with us, to administer, develop and improve services and products, to provide you with customer support, to process your payments, understand your preferences, to perform risk management activities, to submit management reports and regulatory reports, and to meet other compliance requirements and conduct the other activities described in this Privacy Policy.

 

5.2 Service Providers: We may share your personal information with the following categories of service providers, who may be located in your country or in any other country:

  • co-brand partners where you apply for a product or hold a co-brand product;

  • infrastructure and Information Technology service providers, including cloud service providers;

  • marketing, advertising, and communications agencies;

  • credit bureaus and/or credit reference agencies;

  • external auditors, consultants, and professional advisers;

  • persons acting on your behalf, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks, exchanges, trade data repositories, and clearing houses and clearing and settlement systems;

  • financial institutions, fraud prevention agencies, trade associations, and debt recovery agents;

  • card associations, traders, merchants and other card services related third parties;

  • any introducing broker we provide instructions or referrals to or from whom we receive them; and

  • any trusted third party we use to provide services to you.

We will only provide our service providers with personal information which is necessary for the performance of their services. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy as well as applicable data protection laws.

 

5.3 Third parties permitted by law: Your personal information may be used and disclosed to comply with legal and regulatory requirements and requests, including with any national or international law enforcement, regulatory, governmental or judicial authority or to meet other obligations to which Nex or any permitted recipient of your personal information is subject.

This may include using the information to help detect or prevent crime (including terrorism financing, money laundering, and other financial crimes) and for tax reporting. We may also disclose your personal information to third parties in any country where the disclosure is legally required and/or where it is necessary to protect, enforce, or defend our rights or those of our employees and officers.

 

5.4 Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, joint venture, acquisition, disposition or transfer of shares or business or assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy. This includes any actual or potential participant or sub-participant relating to any of our obligations under any agreement between you and us or an assignee, novatee, or transferee of such agreement.

 

5.5 Other Third Parties

  1. persons whom you may have introduced to us or vice versa;

  2. any rating agency, business alliance partner, insurance company, issuer, insurance broker or direct or indirect provider of credit protection; and

  3. other third parties to whom you may have agreed to allow disclosure.

 

5.6 Nex may contain links to third party platforms that are not operated by us. We do not control nor accept liability or responsibility for these platforms and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party platforms to find out how they collect and use your personal information.

 

5.7 When you are using Nex and enable the fingerprints and/or facial recognition features in your mobile device for authentication purposes, please note that we do not store such biometric data. Unless otherwise notified to you, such data is stored in your mobile device and may also be stored by third parties, such as your device’s manufacturer. You agree and acknowledge that we are not responsible for any unauthorised access or loss towards such biometric data which is stored in your mobile device.

6. What are your rights?

 

6.1 You have the right to:

  • Access: request access to or a copy of the personal information about you historically that we are processing.

  • Rectification: request that we correct any inaccurate, outdated, incomplete or misleading personal information that we have processed about you.

  • No marketing: opt out from receiving marketing messages from us, at any time.

  • Withdrawal of Consent: if you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, with all accrued rights and obligations remaining fully reserved. If you withdraw your consent, depending on the nature of your request, we may not be in a position to continue providing our products or services to you.

  • Deletion: You may request that we delete or destroy or temporarily suspend the use of your personal information held by us, or convert it into the information which cannot be used to identify you.

  • File a complaint in the context of resolving any data protection dispute with us and the supervisory authority

 

You can make a request to exercise any of these rights in relation to your personal information by sending us a written request (see “How to contact us” below).

 

6.2 Your rights may be subject to conditions and exceptions under applicable laws. We may decline requests where our confidential business information or the privacy of others may be compromised or on any other reasonable basis, to the extent permitted by law to do so

7. How do we protect your personal information?

 

7.1. We have implemented technical, administrative, organisational and physical security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers that are required to know such information for the purposes described in this Privacy Policy.

 

7.2. While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification, and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as unlawful hackers. This is because of the inherent nature of the Internet as an open global communication vehicle and other risk factors.

 

7.3 You are responsible for keeping your account details confidential and you must not share your account details, including your password/PIN and One Time Password (OTP), with anyone and you must always maintain and be fully responsible for the security of the device that you use to access Nex and our services.

8. How long do we keep your personal information?

 

We will retain your personal data as long as necessary to serve the purposes for which it was collected, to comply with legal and regulatory requirements or where we may need it for our legitimate purposes such as to protect or enforce our legal rights, fighting fraud and financial crime, and dealing with any disputes or concerns that may arise. When we no longer need to use personal information, we will remove it from our systems and records or take steps to make it anonymous so that you can no longer be identified from it, subject to any data retention obligations under applicable laws.

 

Please note that there is still the possibility that some of your personal information might be retained by other parties, including by government institutions, in some manner. In the event we share your personal information to the authorised government institutions and/or other institutions that may be appointed by the government authorities or cooperates with us, you agree and acknowledge that the retention of your personal information by the relevant institutions will follow their respective policy on data retention. Information relayed through communications between users and service providers made other than through the use of Nex (such as by telephone calls, SMS, mobile messaging or other method of communication and collection of your personal information by our agent) may also be retained by some means. We do not encourage the retention of personal information by such means and we have no responsibility to you for the same. We shall not be liable for any such retention of your personal information. You agree to indemnify, defend and release us, our officers, directors, employees, agents, partners, suppliers, contractors and affiliates from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of your personal information.

9. A note on anonymous data

 

We may create, use, license or disclose personal information, provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that the personal information has been combined with similar data such that the original data forms a part of a larger data set.

10. How to contact us

 

If there are any questions or concerns regarding this Privacy Policy, please drop us an SMS or Whatsapp at the following number:

 

Customer Service
Tel: +62 811 2315 556
Email: customersupport@nexapp.co
Operating hours: 08:00 - 21:00 WIB daily

 

We reserve the right to change our Privacy Policy from time to time to ensure that this policy is consistent with any developments to the way Nex uses your personal data or any changes to the applicable Indonesian laws regarding data protection. If we decide to change our Privacy Policy, we will make available the updated policy on our app within 48 (forty eight) hours, before the new Privacy Policy becomes effective.

 

You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and that your continued use of Nex, communications with us, or access to and use of the services following any amendments to this Privacy Policy will constitute your acceptance to this Privacy Policy and all of its amendments. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time

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