MOPAY PLATFORM PRIVACY POLICY

1. INFORMATION WE COLLECT

We collect personal and non-personal ("Information") from Users:

• Information that may identify Users but is not limited to full name, gender, phone number, email address, password, financial information or other relevant information, biometric information (including facial recognition), internet protocol address;
• Information automatically collected from Users' devices and services provided by Mopay; and
• Information that we collect from third parties in various forms and types as permitted by applicable regulations and/or laws, one of which is identity verification information.
• Subject to the above terms, Users are deemed to have agreed to provide each correct and accurate Information and not mislead, and by doing so, Users have the right to obtain more information about changes to the Information provided by Users.

2. USE OF THE INFORMATION WE COLLECT

We may use Information for the following purposes:

• Identify Users and register Users as users, and to manage, maintain, and/or validate User Accounts;
• Processing and facilitating orders and payment transactions made by Users, including transactions made using Mopay's payment system and services offered on the Mopay Platform, as applicable;
• Provide Users with information on the Mopay Platform and how to use it;
• Evaluate, analyze, improve and develop our products and services, analyze and monitor User accounts, use aggregate and compiled data to prepare analytical reports for internal development purposes;
• Communicate with and deliver information to Users, including updates to the Mopay Platform or changes to our services;
• To detect, investigate and prevent things that threaten security, fraud, and illegal activities and other illegal activities to protect Users and Mopay;
• Send marketing communications and promotions directly and information about special offers or promotions to Users if Users have given permission to receive these communications at any time if Users do not wish to receive it; and/or
• For other purposes permitted by applicable laws and regulations.

3. DISCLOSURE OF THE INFORMATION WE COLLECT

We may disclose or share Users' Information with affiliates and other parties for the following purposes and to the extent permitted by applicable laws and regulations (the parties receiving such Information shall act fairly and not disclose further Information from what is needed for the intended purpose):

• pursuant to applicable laws and regulations or as required by applicable laws and regulations; or in accordance with requests, orders, guidelines or instructions from government authorities;
• for the purposes between Users and us, or between Users and other parties, in connection with, or relating to the Mopay Platform, in accordance with applicable law or outside of User legal processes;
• if we share User Information with third parties, such as information technology companies for technical and operational maintenance purposes; payment processing providers that facilitate payments made through the Mopay Platform; and marketing data storage service providers in databases used for marketing purposes, and other service providers that we direct to. If we share Users' Information with such third parties, we will ensure contractual, technical, and organizational measures to ensure that User Personal Information is only used for the specific purposes described in this Privacy Policy. Third parties may only access User Information as required by contractual obligations with the Mopay Platform and applicable regulations.
• On the Mopay Platform, Users can be given the option to share certain Information with third parties or other users. Once Users choose to share their Information through features on the Mopay Platform, then Users will be giving us permission to manage Information belonging to Users, and we will not be responsible for the continuity of Information that has been provided by Users to third parties.

4. INFORMATION SECURITY

We will, upon our best efforts, take adequate protection measures to ensure the confidentiality and security of User Information based on Law No. 27 of 2022 on Personal Data Protection, and/or other applicable regulations. We will, at our best efforts, apply security technical measures, physical, and organizations appropriate to protect personal data and the destruction of the intentional or accidental, loss, access, alteration, disclosure and all forms of processing that violate the applicable law (including, but not limited to, unnecessary collection) or further processing.

5. INFORMATION STORAGE

Information collected by us will be stored and/or processed by third-party service providers (if any), and we will at our best efforts ensure that third-party service providers will only store the data as long as necessary to fulfill its acquisition, and as long as applicable law and applicable regulations require us to retain it. If we are no longer required to retain User Information for the purpose of processing the information, and retention is no longer required for legal or business purposes, then we will stop storing Information, and remove such Information that is stored in our account as long as User accounts are active and/or as long as required by applicable laws and regulations.

6. CHILDREN'S POLICY

Our services are not intended for children, so we limit who can use below 17 years of age or below the age of majority as required by applicable law. Users must be aware and intentionally will not provide any information that is related to children. We are unable to identify whether a child has provided Information to us without the Know Your Customer (KYC) process. If we identify a child providing Information to us, we will take steps to remove such Information as soon as possible.

7. AMENDMENT TO THIS PRIVACY POLICY

We may, at our own discretion, review and modify the Privacy Policy from time to time, to ensure that this policy is consistent with our future developments and/or changes to applicable law or regulations. If we decide to modify this Privacy Policy, we will give notice to all Users of these changes through a general announcement on the Mopay Platform, or to the email address recorded in the User Accounts. Users are responsible for regularly accessing the Mopay Privacy Policy specifically to get the latest information about data processing and our data protection practices, and the fact that Users continue to use the Mopay Platform, as well as communication with us, following any amendment to this Privacy Policy shall constitute acceptance of the Users for all such changes.

8. ACKNOWLEDGEMENT AND CONSENT

By receiving the Privacy Policy, Users acknowledge that Users have read and understood this Privacy Policy and Users accept all its terms. Specifically, Users agree to authorize us to collect, use, disclose, store, transfer, or otherwise process your Information in accordance with this Privacy Policy.

9. HOW TO CONTACT US

If the User has any questions regarding this Privacy Policy or the User wants to get access and/or make corrections to User Information, please contact us at:

Email : [email protected]

Phone : +62 21 555 0199