Privacy Policy

Singapay wants to provide you with 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 very important to us. Therefore, we explain transparently how we collect, store and use your Personal Data as described below:

1. General

This Privacy Policy applies to services provided by PT Abadi Singapay Indonesia (“PT ASI” or “Singapay” or “We”) or otherwise known as explaining how we collect, use, store, transfer, protect and disclose User's “personal data” , “personally identifiable information” or other personal information (collectively, “Personal Data”) in connection with the User's access to and use of the Singapay mobile application (“Singapay Application”).

As explained more fully in the Terms and Conditions for Singapay Users ("Terms and Conditions"), the Singapay Application is an integrated service application designed by PT ASI for users. The Singapay Pay application is provided free of charge for registered users. Anyone can register to have an account on the Singapay Application with PT ASI which is a non-bank institution under the supervision of Bank Indonesia as the authority authorized to supervise the implementation of the payment system .

Users must provide updated User Personal Data to us in connection with the User's access and use of the Singapay Application from time to time. By agreeing to this Privacy Policy, the User states that he has understood and agreed to the provisions in this notice regarding the collection, use, storage, provision and disclosure of User Personal Data as regulated in this Privacy Policy.

If the User does not provide Personal Data to us, this may cause us to be unable to provide the Singapay Application services to the User or to comply with laws or regulations or guidelines issued by other 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 number issued by an authorized agency or authority (including KTP, SIM and Passport) or other identification issued by the government, photo, nationality, telephone numbers of Singapay users and non-users contained in the Singapay User's cell phone contact list, as well as biometric information (including but not limited to facial recognition), as well as other information that is direct or indirectly, either separately or together with other information, may be used to identify Users.

Please read this Privacy Policy carefully to ensure that as a User, you understand and agree to how we obtain, process, use, store and disclose User Personal Data. 

Unless otherwise defined in this Privacy Policy, capitalized terms have the same meaning as given in the Terms and Conditions.

2. Acquisition and Collection of Personal Data

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

1. Information obtained (directly or indirectly) when Users access the Singapay Application, relating to information about computers, telephone equipment, parts of other hardware, software and telecommunications networks used by Users to access and use the Singapay Application (including User's IP address, geographic location, browser/platform type and version , internet service provider, operating system, referral source/exit page, length of visit/usage, page views and any search terms the User uses) (“Device Information”).
2. Information obtained (directly or indirectly) when a User registers to create a Singapay Account includes the User's name, date of birth, address, telephone number, email address, photo, and identity card (including KTP, Driving License, and Passport) (“Registration Information ”).
3. Information obtained (directly or indirectly) during the User's use of 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 information or at other times as may be requested by Singapay to the User if needed from time to time.
5. The above Device Information, Registration Information and Account Information and other information can be accessed or collected (automatically or manually) when the User registers with a Singapay account as a Singapay Application user and/or during the User's use of the Singapay Application and Singapay Account. The above information that we obtain may be User 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 in excess of what we need to provide our services to Users, to perform the functions as set out in Section 3 of this Privacy Policy, to protect User's Singapay Accounts, comply with our legal obligations, protect our rights under the law, and to operate our business activities.

Singapay may collect User Personal Data from third parties (including agents, vendors, suppliers, contractors, partners and other parties who provide services to Singapay or other partners who collaborate with Singapay. In this case, the third party is responsible for obtaining approval from authorized parties is required for the collection and disclosure of User Personal Data to Singapay, and Singapay will process Personal Data depending on the consent obtained by the third party. In this case, Singapay will utilize User Personal Data for the purposes Singapay cooperation with these third parties. 

3. Use of Personal Data

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

1. Verifying the eligibility and/or suitability of User data to use the features and functions in the Singapay Application or any verification that Singapay deems necessary before providing services to Users or before Singapay registers Users including and not limited to the Know Your Customer process / KYC ).
2. Identify and process User Singapay Account registrations, as well as maintain and manage User registrations.
3. Process and manage Singapay User Balances.
4. Providing services for Users and customer services related 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 related services for purchases, imposing charge-backs , sending notifications about transactions and User bills and answer questions, input, complaints, demands or disputes from Users.
5. Providing services for Users related to the use of the Singapay Application by Users, namely to make it easier for Users to identify other Singapay Application Users when Users view the User's mobile phone address book via the Application
6. Improve and develop 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. Conduct research, statistical analysis or surveys, both verbally and in writing, to manage and protect our business including 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. Conduct analysis of trends, usage and other behavior (both individually and as a whole) that helps us to better understand how our Users and user groups access and use the Singapay Application and commercial activities conducted through the Singapay Application, including for the purpose of improving services and responses to customer questions and preferences.
9. Referring to obtaining User consent in accordance with applicable law as referred to in section 4 below, we can use Personal Data to provide direct marketing information to Users in connection with the services we offer and our affiliates and third parties who have been selected to use User Personal Data to contact Users, via telephone, short message (SMS), email ( e-mail ), post and fax.
10. Manage risks, check credit worthiness and ability to pay (solvency), or assess, detect, investigate, prevent and/or correct fraud or activities that have the potential to violate or violate laws and regulations and the interests of Singapay, or to protect the integrity our information technology platform.
11. Detect, investigate, prevent or correct violations of the Terms and Conditions, Privacy Policy, all Singapay internal policies applicable from time to time, industry standards, guidelines, relevant laws or regulations.
12. Make disclosures as may be required by the laws or regulations of any country that apply to us or our affiliates, government officials or third parties, including associations providing electronic money or other payment networks as well as other relevant industry associations. Disclosure may also be made in connection with a subpoena, decision and/or court order, order from an authorized law enforcement official in the context of an investigation, investigation, or other legal process or a requirement in any country that applies to us or our affiliates (including reporting requirements anti-money laundering and anti-terrorism financing).
13. Make a disclosure to prevent harm or financial loss to report any suspected illegal activity or to face any lawsuit or potential lawsuit filed against us or our affiliates.
14. Carrying out due diligence and other assessments or evaluations of actual or proposed mergers, takeovers, financing transactions or joint ventures.
15. Notify Users regarding any updates to the Singapay Application or changes to Singapay services.
16. Develop and improve the quality of applications to meet the needs and preferences of Singapay users regarding features that are owned or will be developed in the future by Singapay.
17. Monitor and analyze the activities, behavior and demographic data of Singapay Users including habits and usage of various services available on the Singapay Application.
18. Offer or provide services from partners or affiliates who collaborate 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 in order to resolve technical obstacles and operational problems that occur in the Singapay application.
21. Facilitate business asset transactions (which can be in the form of mergers, acquisitions, spinoffs /separations or asset sales) involving Singapay and/or Singapay affiliates.
22. For other legitimate business purposes such as protecting Users and other users of the Singapay Application from loss, protecting lives, maintaining the security of our products and systems and protecting our interests, rights and/or other property.
23. We may also use User Personal Data in other ways, which we will include with special notice at the time of collecting the data to be approved by the User.

 4. Disclosure of Personal Data

User Personal Data that we store will be kept confidential, but we may provide User Personal Data to the following parties (both within and outside the User's country of residence) for the purposes as regulated in Section 3 above:

1. Companies that are members of the Singapay group and companies that have affiliated relationships with members of the Singapay group.
2. Agents, contractors and third party service providers who collaborate with Singapay in providing our services to Users including to prevent fraud, bill collection, data entry, database management, promotions, marketing, research, surveys, customer service, technology services, product notifications and payment extension services and services.
3. Entities with whom we have business referral relationships or other commercial agreements include third parties and entities wholly or partially owned by PT ASI.
4. Merchants and other organizations, such as associations of electronic money operators, payment networks or financial institutions, to or through whom payments are made using Singapay, or other entities that allow the use of the Singapay Application by third party financial institutions, banks, acceptance agents , financing institutions, and others.
5. Third party service providers.
6. Professional advisors, law enforcement agencies, insurance companies, governments and other authorities or agencies to which PT ASI is obliged to make disclosures in accordance with needs, lawful requests, and applicable laws, regulations or commercial arrangements, including arrangements with card associations or payment networks or other relevant industry associations.
7. Entities involved in a merger, takeover, financing transaction or joint venture with us.

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

1. To improve the quality of services provided by Singapay to Users from time to time.
2. If required or permitted by applicable laws and regulations or upon official orders and/or requests from authorities, agencies, state institutions, and/or law enforcement officials.
3. For the purposes of legal proceedings in any form between Users and Singapay.
4. For audit purposes, both routine and incidental, as required from time to time;
5. For the purposes of processing permits, registration or recording required for Singapay business activities;
6. For all verification processes required before registering a User as a User, including the Know Your Customer process .

Singapay will not sell or rent User Personal Data to other parties. Apart from what is regulated above, Singapay can disclose and share User Personal Data for other purposes or with other parties, after obtaining the User's consent to disclose the Personal Data.

5. Security and Storage Measures

We take all reasonable and maximum possible steps including providing technical, administrative and physical protection to help protect User Personal Data that we process from the risk of loss, misuse and unauthorized access, disclosure, unwanted alteration and destruction. 

We will store and ensure that our service providers retain User Personal Data only as long as necessary for the purposes set out in this notice and in accordance with the requirements of applicable laws and regulations.

User Personal Data will only be stored as long as necessary to fulfill the purpose for which it was collected or as long as such storage is required or permitted by applicable laws and regulations.

For Users registered with Singapay, registration information and User Account information (if any) can be viewed and changed in the Singapay Application via the User Account, which is protected by a password, PIN code, or other security method. We remind Users not to disclose the User's password or PIN code or other security key to any party. Our employees, officers, agents and representatives do not know and will never ask for User passwords in unsolicited telephone communications or through unsolicited email. If the User uses a device that can be used by other people (public device), then the User must choose not to store the User's log-in information (for example: user ID and password) on that device. You are responsible for maintaining the confidentiality of your account details, including password, PIN code, and One Time Password (OTP) from anyone and are responsible for the security of the device you use.

6. 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. These services and websites may operate independently from us and may have their own privacy notices or policies, which we advise Users to read first before using their services or carrying out any activities on such websites. The provision of links to other websites and services is for informational purposes only. We do not provide any support or guarantee for the content and information contained in these links. For websites that Users visit that are not owned or controlled by us, we are not responsible for the content, privacy practices and quality of those services.

7. Changes to this Privacy Policy

Singapay holds the exclusive right to change, add, and/or revise notices and information related to this Privacy Policy from time to time, in which case Users will be asked to provide approval to the Privacy Policy that has been changed, added, and/or revised. If the User does not provide approval to the Privacy Policy which has been changed, supplemented and/or revised, then Singapay has full authority to stop providing services in the Singapay Application to the User. You agree that it is your responsibility to periodically review this Privacy Policy for the latest information regarding data processing and data protection practices.

8. Other Terms

1. This Personal Data Regulation is subject to, regulated and implemented in accordance with the Law of the Republic of Indonesia.
2. If a dispute arises in the interpretation and implementation of this Personal Data Regulation, the User and PT ASI agree to resolve it by deliberation. If within a period of 30 (thirty) calendar days the User and PT ASI cannot reach an agreement through deliberation, then the dispute will be resolved by referring to the Tangerang District Court.
3. We will implement an information security system that we consider adequate and in accordance with industry standards or statutory regulations. However, the transmission of information over communication channels is not completely secure and free from loopholes. Thus, any transmission of information by the User to us carries a security risk, in which case the risk is borne by the User. We do not guarantee the security of our database and we also do not guarantee that the data that Users provide will not be retained/interrupted while being sent to us.

9. Statement

By using the Singapay Application, the User acknowledges that the User has read and understands these Personal Data Regulations and agrees to the collection, use, processing, storage, disclosure and deletion of Personal Data as regulated in this Privacy Policy.

 10. Keeping Your Data Safe

Singapay is committed to protecting your Personal Data as our User where we try to implement the best possible technical measures, in accordance with standards or laws and regulations to protect the security of your Personal Data. However, as a User, you must understand that no system is completely secure. Therefore, as a User, you are obliged to implement steps to protect the User's Singapay Account by maintaining control of the Mobile Phone Number and Device used to access the Singapay Application, as well as using and keeping a strong and unique password and/or PIN code secret to prevent access. which is undesirable.

11. Storage, Access, Correction, Update and Deletion of Your Data

Singapay stores your Personal Data as a User as long as necessary to provide Singapay services and for legitimate and important business purposes, including:

1. In order to maintain the performance and quality of service on Singapay features;
2. In order to make business decisions based on the data you provide for the development of our products and service quality;
3. In order to resolve unresolved problems related to your account, such as chargebacks , refunds , or other disputes, we will store your Personal Data until the problem is resolved;
4. In order to fulfill our legal, tax, audit and accounting obligations, we will retain the necessary Personal Data for the period required under applicable law; And
5. Or for other purposes as mentioned above as long as it is necessary for our legitimate business interests, such as to prevent fraud or maintain your security as a Singapay User.

You have the right to request access to historical Personal Data, correct or update Personal Data or request deletion of Personal Data. In such cases, we will provide the information in the format we determine. 

12. Further information

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

PT ABADI SINGAPAY INDONESIA (SINGAPAY)

Foresta business loft 5, Lengkong Kulon Kec. Pagedangan, Tangerang Regency Banten 15331, Tangerang Regency, Banten 15332

Working Hours : Monday - Friday / 09.00 - 18.00 WIB

Telephone: 021 - 38929036

Email: info@singapay.id 

By agreeing to this Privacy Policy, you acknowledge that you have read and understand this Privacy Policy and agree to all the provisions contained therein. You have also given your consent to Singapay to collect, use, share, disclose, store, transfer or process your Personal Data in accordance with this Privacy Policy.

This Privacy Policy applies to the services provided by PT Abadi Singapay Indonesia (“PT ASI” or “Singapay” or “We”) and explains how we collect, use, store, transfer, protect, and disclose Users' "personal data," "personally identifiable information," or other personal information (collectively referred to as "Personal Data") in relation to Users' access to and use of the Singapay mobile application ("Singapay App").

As further detailed in the Terms and Conditions for Singapay Users ("Terms and Conditions"), the Singapay App is an integrated service application designed by PT ASI for users. The Singapay App is provided free of charge for registered Users. Anyone can register to create an account on the Singapay App with PT ASI, which is a non-bank institution under the supervision of Bank Indonesia, the authority responsible for overseeing payment system operations.

Users must update their Personal Data with us from time to time in connection with their access to and use of the Singapay App. By agreeing to this Privacy Policy, Users acknowledge that they understand and consent to the terms outlined in this notice regarding the collection, use, storage, provision, and disclosure of their Personal Data as set forth in this Privacy Policy.

If Users do not provide the required Personal Data to us, this may result in our inability to provide Singapay App services to them or comply with applicable laws, regulations, or guidelines issued by relevant authorities.

Personal Data includes but is not limited to name, address, place of birth, date of birth, occupation, phone number, fax number, bank account details, gender, identification number issued by authorized institutions or authorities (including ID card, driver’s license, and passport) or other government-issued identification, photos, nationality, phone numbers of both Singapay users and non-users contained in the mobile contact list of Singapay Users, as well as biometric information (including but not limited to facial recognition), and other information that, directly or indirectly, whether separately or together with other information, can be used to identify Users.

Please read this Privacy Policy carefully to ensure that, as a User, you fully understand and agree with how we collect, process, use, store, and disclose your Personal Data.

Unless otherwise defined in this Privacy Policy, capitalized terms have the same meaning as those given in the Terms and Conditions.

Singapay may obtain Users' Personal Data from various sources (e.g., from Users or through third parties) at any time, including but not limited to when Users access the Singapay App or conduct transactions using the Singapay App. This includes data related to:

1. Information obtained (directly or indirectly) when Users access the Singapay App, related to details about computers, mobile devices, other hardware components, software, and telecommunications networks used by Users to access and use the Singapay App (including Users' IP addresses, geographic locations, browser/platform types and versions, internet service providers, operating systems, referral sources/exit pages, visit duration/usage time, page views, and any search terms used by Users) (“Device Information”).

2. Information obtained (directly or indirectly) when Users register to create a Singapay Account, including name, date of birth, address, phone number, email address, photo, and identification documents (including ID card, driver's license, and passport) (“Registration Information”).

3. Information obtained (directly or indirectly) during Users' use of the Singapay App, including Users' bank account numbers, billing and shipping information, transaction data, and other details from checks or money orders (“Account Information”).

4. Information obtained when Users update their information or at any other time as may be requested by Singapay when necessary from time to time.

5. The above Device Information, Registration Information, and Account Information, along with other relevant data, may be accessed or collected (automatically or manually) during Users' registration with a Singapay account as a Singapay App user and/or throughout the use of the Singapay App and Singapay Account. The information we obtain may constitute Users' Personal Data. We have taken steps to ensure that we do not collect information (regardless of whether it is Personal Data or not) beyond what is necessary to provide our services to Users, perform the functions outlined in Section 3 of this Privacy Policy, protect Users' Singapay Accounts, comply with our legal obligations, safeguard our rights under the law, and operate our business activities.

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 collaborating with Singapay). In such cases, these third parties are responsible for obtaining the necessary consent from relevant authorities for the collection and disclosure of Users' Personal Data to Singapay. Singapay will process Personal Data based on the consent obtained by these third parties. In this regard, Singapay will utilize Users' Personal Data for the purposes of its collaboration with such third parties.

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 but not limited to:

1. Verifying the eligibility and/or accuracy of User data to use the features and functions within the Singapay App or for any verification deemed necessary by Singapay before providing services to Users, including but not limited to the Know Your Customer (KYC) process.
2. Identifying and processing the registration of Users' Singapay Accounts and maintaining and managing Users' registration.
3. Processing and managing Users' Singapay balances.
4. Providing services to Users and customer support related to the use of Users' Singapay Accounts, including facilitating payments for the purchase of goods and services, shipments, and other related services, handling chargebacks, sending notifications about transactions and bills, and responding to Users' inquiries, feedback, complaints, claims, or disputes.
5. Providing services related to Users' use of the Singapay App, making it easier for Users to identify other Singapay App Users when viewing their mobile phone address book through the App.
6. Enhancing and developing our offerings through research and the development of new functions for the Singapay App or other new products and services we may introduce from time to time.
7. Conducting research, statistical analysis, or surveys, whether verbal or written, to manage and protect our business, including IT infrastructure, measure the performance of the Singapay App and our other services, and ensure your satisfaction with our services.
8. Analyzing trends, usage, and other behaviors (individually or collectively) to better understand how Users and our user base access and use the Singapay App, as well as commercial activities conducted through the App, including improving services and responding to customer inquiries and preferences.
9. Subject to Users' consent as required by applicable law (as referenced in Section 4 below), we may use Personal Data for direct marketing purposes, providing Users with information about our services, our affiliates, and selected third parties. We may contact Users via phone, SMS, email, mail, or fax.
10. Managing risks, conducting creditworthiness and solvency checks, or assessing, detecting, investigating, preventing, and/or remedying fraud or activities that may violate applicable laws, regulations, or Singapay’s interests, as well as protecting the integrity of our IT platform.
11. Detecting, investigating, preventing, or addressing violations of the Terms and Conditions, Privacy Policy, internal policies of Singapay, industry standards, guidelines, laws, or relevant regulations.
12. Making disclosures as required by laws or regulations in any country applicable to us or our affiliates, government officials, or third parties, including electronic money service provider associations, other relevant payment network associations, and industry organizations. Disclosures may also be made in response to subpoenas, court rulings/orders, law enforcement orders for investigation, inquiries, or legal proceedings, or as required by law in any applicable jurisdiction (including anti-money laundering and counter-terrorism financing reporting obligations).
13. Making disclosures to prevent harm or financial loss, report any suspected illegal activity, or address any claims or potential claims against us or our affiliates.
14. Conducting due diligence and other assessments or evaluations related to actual or proposed mergers, acquisitions, financing transactions, or joint ventures.
15. Notifying Users about any updates to the Singapay App or changes to Singapay services.
16. Developing and improving the app’s quality to meet the needs and preferences of Singapay Users regarding existing or future features to be developed by Singapay.
17. Monitoring and analyzing User activity, behavior, and demographics, including habits and usage patterns of various services available in the Singapay App.
18. Offering or providing services from Singapay’s partners or affiliates to Users.
19. Sending information, advertisements, surveys, promotions, vouchers, and other relevant content deemed appropriate by Singapay for Users.
20. Providing technical assistance or resolving technical difficulties and operational issues within the Singapay App.
21. Facilitating business asset transactions (which may involve mergers, acquisitions, spin-offs, or asset sales) involving Singapay and/or its affiliates.
22. For other legitimate business purposes, such as protecting Users and other Singapay App users from harm, ensuring safety, maintaining the security of our products and systems, and protecting our interests, rights, and/or other properties.
23. We may also use Users' Personal Data in other ways, which we will notify Users of at the time of collection for their approval.

The Personal Data we store will be kept confidential. However, we may provide Users' Personal Data to the following parties (both within and outside the User’s country of residence) for the purposes outlined in Section 3 above:

1. Singapay Group Companies and Affiliates – Member companies of the Singapay Group and affiliated companies associated with the Singapay Group.

2. Agents, Contractors, and Third-Party Service Providers – Entities collaborating with Singapay to provide our services to Users, including fraud prevention, debt collection, data entry, database management, promotions, marketing, research, surveys, customer service, technology services, product and service notifications, and payment extension services.

3. Entities with Business or Commercial Agreements with Singapay – This includes third parties and entities that are wholly or partially owned by PT ASI.

4. Merchants and Financial Institutions – Organizations such as electronic money issuers, payment networks, and financial institutions that process transactions using Singapay, as well as third-party financial institutions, banks, payment agents, financing institutions, and other related entities.

5. Third-Party Service Providers – Entities providing services that support the operation of Singapay.

6. Professional Advisors, Law Enforcement, Insurance Companies, and Government Authorities – Entities to whom Singapay is required to disclose information in accordance with legal, regulatory, or commercial requirements, including payment network associations, industry organizations, and relevant authorities.

7. Entities Involved in Mergers, Acquisitions, or Joint Ventures with Singapay – Companies engaged in financial transactions involving Singapay.

Singapay may also disclose and share Users' Personal Data with the parties mentioned above for the following purposes:

1. To enhance the quality of services provided by Singapay to Users over time.

2. As required or permitted by applicable laws and regulations, or upon official request from authorities, institutions, state agencies, or law enforcement officials.

3. For 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. To process necessary permits, registrations, or records related to Singapay's business activities.

6. For verification processes required before registering Users, including Know Your Customer (KYC) procedures.

Singapay will not sell or rent Users' Personal Data to other parties. Apart from the disclosures outlined above, Singapay may disclose and share Users' Personal Data for other purposes or with other parties only after obtaining the User's consent.

We take all reasonable and maximum possible steps, including implementing technical, administrative, and physical safeguards, to help protect Users' Personal Data that we process from risks such as loss, misuse, unauthorized access, disclosure, alteration, and unintended destruction.

We will store Users' Personal Data and ensure that our service providers store it only for as long as necessary to fulfill the purposes outlined in this notice and in compliance with applicable laws and regulations.

Users' Personal Data will only be retained for as long as needed to fulfill the purposes for which it was collected or as required or permitted under applicable laws and regulations.

For Users registered with Singapay, registration information and Account information (if applicable) can be viewed and modified within the Singapay Application through the User Account, which is protected by a password, PIN code, or other security measures. We remind Users not to disclose their passwords, PIN codes, or any other security keys to anyone. Our employees, officers, agents, and representatives do not have access to and will never request Users' passwords through unsolicited phone calls or emails. If Users access their accounts from a shared or public device, they should choose not to save their login information (such as user ID and password) on that device. Users are responsible for maintaining the confidentiality of their account details, including passwords, PIN codes, and One-Time Passwords (OTP), and for ensuring the security of the devices they use.

The Singapay application may provide links to other websites and services (including applications operated by third parties) for Users' convenience and information. These services and websites may operate independently from us and may have their own privacy notices or policies. We recommend that Users read these policies before using their services or engaging in any activities on those websites. The provision of links to other websites and services is for informational purposes only. We do not endorse or provide any guarantees regarding the content and information contained in these links. For websites that Users visit that are not owned or controlled by us, we are not responsible for their content, privacy practices, or the quality of their services.

Singapay reserves the exclusive right to modify, add, and/or revise the notices and information related to this Privacy Policy from time to time. In such cases, Users will be required to provide consent to the updated, added, and/or revised Privacy Policy. If a User does not consent to the modified, added, and/or revised Privacy Policy, Singapay retains full authority to discontinue the provision of services within the Singapay application to the User. You agree that it is your responsibility to review this Privacy Policy periodically to stay informed about the latest updates regarding data processing and data protection practices.

1. This Personal Data Regulation is subject to, governed by, and enforced in accordance with the laws of the Republic of Indonesia.
2. In the event of any dispute regarding the interpretation and implementation of this Personal Data Regulation, the User and PT ASI agree to resolve it through deliberation. If, within 30 (thirty) calendar days, the User and PT ASI fail to reach an agreement through such deliberation, the dispute shall be settled by referring to the Tangerang District Court.
3. We will implement an information security system that we deem adequate and in compliance with industry standards or applicable regulations. However, the transmission of information through communication channels is not entirely secure and free from vulnerabilities. Therefore, any transmission of information by the User to us carries security risks, which shall be borne by the User. We do not guarantee the security of our database, nor do we guarantee that the data provided by the User will be completely uninterrupted or free from interference during transmission to us.

By using the Singapay Application, the User acknowledges that they have read and understood this Personal Data Regulation and agree to the collection, use, processing, storage, disclosure, and deletion of Personal Data as stipulated in this Privacy Policy.

Singapay is committed to protecting your Personal Data as our User by implementing the best possible technical measures, in accordance with industry standards and applicable regulations, to safeguard the security of your Personal Data. However, as a User, you must understand that no system is entirely secure. Therefore, you are responsible for taking necessary measures to protect your Singapay Account by maintaining control over your Mobile Number and Device used to access the Singapay Application, as well as using and keeping a strong and unique password and/or PIN confidential to prevent unauthorized access.

Singapay stores your Personal Data as a User for as long as necessary to provide Singapay services and for legitimate and essential business purposes, including:

1. Maintaining the performance and quality of services in Singapay’s features;
2. Making business decisions based on the data you provide for the development of our products and service quality;
3. Resolving any outstanding issues related to your account, such as chargebacks, refunds, or other disputes, where we will retain your Personal Data until such issues are resolved;
4. Complying with our legal, tax, audit, and accounting obligations, in which case we will retain the necessary Personal Data for the period required by applicable law; and
5. Other purposes mentioned above, as long as necessary for our legitimate business interests, such as fraud prevention or ensuring your security as a Singapay User.

You have the right to request access to your Personal Data history, make corrections or updates to your Personal Data, or request the deletion of your Personal Data. In such cases, we will provide the requested information in a format determined by us.