Kebijakan Privasi serta Syarat dan Ketentuan Telkomsel SmartPay

The Personal Information we collect and how we collect it varies; in general, this is outlined in the Telkomsel Privacy Policy (www.telkomsel.com/en/privacy-policy) and the Amartha Privacy Policy (https://amartha.com/kebijakan-privasi). In addition, by specifically applying for the Telkomsel SmartPay Service, we also collect your Personal Data, including: 

1. Data submitted by you, including the following: 
   1. Personal Information required to provide the Telkomsel SmartPay Service, namely, your name, National ID Number (NIK), place and date of birth, email address, gender, nationality, marital status, residential address, employment data and status, income, office address, self-portrait, ID card photo, emergency contact, mother's name, and User profiling and segmentation; 
   2. In addition to the Personal Information mentioned above, you have the option to provide us with additional personal data for account personalization purposes. 
2. Data recorded when you use Telkomsel Services and/or Telkomsel SmartPay Services, including but not limited to: 
   1. Location data or estimates thereof, such as IP address, Wi-Fi location, geolocation, and other location information; 
   2. Time-series data of each of your activities, including registration, login, transactions, and so on; 
   3. Usage data or preferences, including your interactions using the Services and selected settings. This data is obtained using cookies, pixel tags, and similar technologies that create and maintain unique identifiers; 
   4. Log data, including records on the server that receives data such as device information, device IP address, date and time of access, application features or pages viewed, application processes, and other system activity. 

In addition to those stated in the Telkomsel Privacy Policy (www.telkomsel.com/en/privacy-policy) and Amartha Privacy Policy (https://amartha.com/kebijakan-privasi), your Personal Data will be collected, recorded, and used for data analysis purposes to support your application and registration process for the Telkomsel SmartPay Service and to fulfill your obligations under that service (including for any financial service facilities provided by Financial Institutions collaborating with Telkomsel in the implementation and development of the Telkomsel SmartPay Service), ensuring that these activities are: 

1. Implementing Know Your Customer (KYC) principles and providing you with personalized information about the Telkomsel SmartPay Service; 
2. Providing services, evaluating, and developing the SmartPay Service from time to time; 
3. Processing and analyzing your Personal Information for the following purposes: 
   1. To assess and process your profile in connection with your financing and/or transactions; 
   2. Conducting verification and analysis in connection with your telecommunications and mobile phone services, your tax certificate, and/or your social security data; 
   3. Processing and analyzing your Personal Information in aggregate form for the purposes of eligibility for Telkomsel SmartPay Services, such as: telco score, location scoring, and advanced profiling. 
   4. Creating promotional materials, either through Telkomsel channels or through third parties collaborating with Telkomsel; 
4. Storing your Personal Information and the resulting data from its processing and analysis, either directly by Telkomsel and/or by Third Parties as stipulated in applicable laws and regulations for Credit Scoring and Lead Generation purposes; 
5. To carry out the mandates of laws and regulations. We recognize that your Personal Information is confidential and private, therefore we are committed to maintaining the confidentiality of such data. 

For purposes related to using the SmartPay Service, you provide your consent for the Personal Information collected by Us to be disclosed to Amartha, the government, or other parties authorized by law or cooperation agreements, in the following cases: 

1. Under applicable law or to respond to legal process, such as a search warrant, court order, or subpoena; 
2. To protect our safety, your safety, or the safety of others, or in the legitimate interests of any party in the context of national security, law enforcement, litigation, criminal investigations, or to prevent death or imminent physical harm; 
3. To investigate fraud or violations of the Terms and Conditions and Privacy Policy; 
4. If necessary, in connection with legal proceedings filed against Telkomsel, Amartha, its officers, employees, affiliates, customers, or vendors. 
5. To establish, exercise, protect, defend, and enforce our legal rights. 
6. To share data with our business partners and other third-party affiliates legally bound to Telkomsel. We will, in good faith, only provide it based on a confidentiality agreement or data usage cooperation agreement and in aggregate form. If we share non-aggregated data, we will take the best efforts to protect your data, such as masking, implementing a confidentiality agreement after signing, or providing additional consent by providing you with notice before your Personal Information is disclosed to a business partner or becomes subject to a different privacy policy, to ensure the confidentiality of your Personal Information. 
7. To the extent permitted by applicable laws and regulations, to other third parties, including financial institutions, both banks and non-banks, online lenders (Peer-to-Peer or "P2P" lending), available credit information bureaus, any legally available third-party identity databases, any financial institutions, and any competent government authorities; 
8. Collaborating with our affiliates to improve your experience on this SmartPay Service, which will only be carried out in accordance with the processing purposes as previously stated, or to protect your interests, and subject to a data management collaboration agreement with us; 
9. In the event of a merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or part of our business by and/or to another company, for the purposes of such transaction. These actions are protected by a confidentiality agreement between us and the relevant third party; 
10.  To carry out the activities described in the Purposes of Collection and Use of Personal Data section. 

Links to Other Websites, Devices, Apps, and Features. The Services may provide the ability to link to other websites, devices, apps, and features, which may operate independently from us and may have their own privacy notices or policies, which we encourage you to review. To the extent that we do not own or control any linked websites, devices, apps, or other features, we are not responsible for their content, use, or privacy practices. 

We are committed to collecting, processing, and storing your Personal Information with the best possible protection for as long as necessary to provide the SmartPay Service. Some of your Personal Information may also be managed, processed, and stored by third parties who collaborate with us, both within and outside Indonesia, to maintain the performance of the SmartPay Service while complying with applicable legal obligations regarding access and effective oversight. 

We will retain the Personal Information as specified for as long as you continue to use the SmartPay Service and/or in accordance with applicable laws. During this period, we may update your data monthly. 

You have certain rights under laws and regulations, which we have generally outlined in the Telkomsel Privacy Policy (www.telkomsel.com/en/privacy-policy) and the Amartha Privacy Policy (https://amartha.com/kebijakan-privasi). Please take a moment to read and review these privacy policies. 

You, as a User, hereby declare and agree as follows: 

1. You guarantee that all data provided in written or other forms to use the SmartPay Service is truly yours and has not been obtained from personal information belonging to a third party without valid authorization. Therefore, any matters arising in connection with the provision and accuracy of such data are your full responsibility; 
2. If your application for financial services is approved by Amartha, you fully understand that such services are your full responsibility, and your entire payment history under the agreement with Amartha will be reported to banking and/or financial institutions and/or relevant government authorities in accordance with applicable laws and regulations; 
3. By agreeing to this Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and agree to all its terms. Specifically, you agree and grant us permission to collect, process, analyze, store, disclose, correct, and delete your personal data in accordance with this Privacy Policy; 
4. You warrant that you have the legal capacity to take legal action under applicable laws, including, if required, obtaining consent from your (parent) or guardian in accordance with applicable laws.