Overview

1. Investree is committed to protect and respect your privacy.
2. This Privacy Policy applies to all people and entities that access this Site. By accessing and / or using the services available or through the Site, you hereby acknowledge that you have read and agree to the terms of this Privacy Policy (along with the Terms of Use), our Cookie Policy, and any other documents that referred above).
3. Privacy Policy (together with our Terms of Use, our Cookie Policy, and any other documents referred to in this Privacy Policy) is designed to help you understand how we collect, use, disclose and / or process the Personal Data that you have provided to us, and help you make informed decisions before giving your Personal Data to us. Read the following carefully to understand our views and habits regarding your Personal Data and how we will treat them.

Definition

1. "Investree" has the same meaning as specified in the Terms of Use.
2. "The Investree Group" has the same meaning as specified in the Terms of Use.
3. "Cookie Policy" refers to the cookie policy of the IInvestree Site.
4. "Interactive Services" has the same meaning as specified in the Terms of Use.
5. "Personal Data" means information or data that can be used directly or indirectly to identify an individual as a person.
6. "Product" has the same meaning as specified in the Terms of Use.
7. "Selected Third Parties" refers to the third parties stipulated in article 4.5 below.
8. "Service" has the same meaning as specified in the Terms of Use.
9. "Site" has the same meaning as specified in the Terms of Use.
10. "Site Content" has the same meaning as specified in the Terms of Use.
11. "Terms of Use" refers to the Terms of Use on this site.
12. "Third Party Content" has the same meaning as specified in the Terms of Use.
13. "Third Party Sites" has the same meaning as specified in the Terms of Use.
14. "Users" has the same meaning as specified in the Terms of Use.
15. "We" and "Our" have the same meaning as specified in the Terms of Use.
16. "You" and "Your" have the same meaning as specified in the Terms of Use.

Information Collection

1. From time to time, Investree may collect information and data about you, including information and data:
   • that it is given by you or given by anyone authorized by you;
   • in relation with each of your visits to our Site; and
   • from other third parties permitted by you and publicly available sources including credit rating agencies or bureaus.
2. Through you, Investree can also collect information and data about family members, friends, beneficiaries, lawyers, shareholders, beneficial owners, attorneys, people under trustees, trustees, your guarantor, other guarantee providers and other individuals (collectively all of the above who are individuals, "Relevant Individuals").
3. In this case, Investree may collect the following information and data stated in articles 3.1 and 3.2 as follows:
   • Any information or data about you and / or relevant individuals who can identify you or the relevant individual, including but not limited to name, date of birth, ID card, passport or other identification number, address, email address, telephone number, contact details, financial and credit card information, personal descriptions and photos, product and service portfolio information, transaction patterns and behavior, financial background, funding history, educational background and population data;
   • Every information and data about you and / or relevant individuals is provides and / or given to us while accessing our Site and carrying out any activities on our Site. For example, your registered username for the Site, search results and history for Products and Services on our Site, history of Product submission, transaction records for Services and Products provided through our Site, records of participation in any Interactive Services on our site, and your answers to questions intended for security verification;
   • Any information and data about you and these relevant individuals is provided and / or given to us in the course of maintaining a relationship between you and us including an account review report and correspondence record with you by telephone or by email;
   • Every information and data about you collected in connection with each of your visits to our Site includes:
     1. technical information, including the Internet Protocol (IP) used to connect your computer to the Internet, your login information, browser type and version, time zone settings, browser type and version of plug-in, operating systems and platforms;
     2. Site visit information, including all Uniform Resources Locators (URL) clickstream to, through and from our Site (including date and time); the products you see or look for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-over), and methods used to move from that page and any telephone numbers used to dial numbers our customer service; and
     3. Information and data from cookies or other technologies used on our Site. For more information about cookies and these technologies and the purposes for which we use them, see our Cookie Policy.
   • Any information and data about you collected by us when you participate in our events, such as parties, seminars, contests or awards programs, which may include photos, video recordings and your voice;
   • Any information and data about you that we receive if you use any other website operated by us, our affiliates and subsidiaries or other services provided by us, our affiliates and subsidiaries. In that case, we will notify you and obtain your consent to collect information or data about you with the relevant Privacy Policy contained in other websites operated by us.
   • Any information and data about you that we receive from selected Third parties (specified in article [4.5] below);
4. Information and data about you and the relevant individuals referred above in article [3.3] are collectively part of Personal data.

Use and Disclosure of Information and Personal Data

1. If considered necessary and appropriate by the Investree and in accordance with applicable laws, rules and regulations, Personal Data may be used and disclosed by the Investree and / or the Investree Group for the following purposes:
   1. Provide access to you and facilitate the use of our Site and ensure that Site Content, Products, Services, Interactive Services, Third Party Content and Third Party Sites are displayed in the most effective way for you and your Device;
   2. Provide you with information, Site Content, Products, Services and Interactive Services that you request from us and access to Third Party Sites and Third Party Content;
   3. Carry out our obligations arising from each contract held between you and us;
   4. Provide you with information about other Products and Services that we offer that are similar to the Products and Services that you have purchased or asked for;
   5. Give to you, or allow Selected Third Parties to provide information about Products or Services to you that we feel might be interesting to you. If you are already a User, we will only contact you via email, SMS or telephone to provide Information about Products and Services that are similar to those you have previously considered, funding or utilizing. If you are a new customer, and if you agree to disclose your Personal Data to Selected Third Parties, we (or Selected Third Parties) can contact you via email or SMS to provide information about the Product or Service;
   6. Notify you of changes to the Site, Site Content, Products, Services, Interactive Services, Third Party Content and Third Party Sites;
   7. Managing our Site and for its internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   8. Improve our Site to ensure that Site Content, Products, Services, Interactive Services, Third Party Content and Third Party Sites are delivered in the most effective way for you and your Device;
   9. Allow you to participate in Interactive Services and other interactive features of our Site, Products and Services, if you choose to do so;
   10. Apply and review the security and protection measures on our Site so as to keep our Site safe and secure;
   11. Assess or understand the effectiveness of our advertisements and third party advertisements on our Site and on other third party websites, and to deliver relevant advertisements to you;
   12. Make suggestions and recommendations for you and other users of our site about products, services or products and services of third parties that may be of interest to you or them;
   13. Make a decision related to the opening or continuation of the User's account and the creation, provision or continuation of the Service (-Service) and Products (-Products) besides maintaining the accuracy of the information "recognize your customer" and conduct anti-money laundering checks , credit and background;
   14. Provide, operate, process and manage the account (s) of Users, Service (-Services) and Product (-Products) or manage applications for Users (-Account), Service (-Services) and Product (-Products ), every transaction (including money transfer transactions), and maintain the quality of services and train staff;
   15. Carry out activities related to the provision of user accounts, services (products) and products (products), including subscriptions or subscription proposals for product (products) or service (services) (both offered or issued by Investree or others) and provision of research reports or materials for analysis;
   16. Provide services and support related to Products, including but not limited to, providing management or administrative support or acting as intermediaries / nominees / agents in connection with your participation in Product (-Products);
   17. Provide or give access to materials related to products such as bid documents, research reports, products profiles, fact sheets, term sheets or other materials related to products;
   18. Fulfills domestic and foreign legal, regulatory and compliance requirements that apply to the Investree and Investree Group under applicable laws (including anti money laundering and tax obligations applicable to the Investree and Investree Group, and disclosures on every exchange effect, the court, government authority, supervisory authority or regulator in accordance with guidelines, regulations, orders, instructions or relevant requests from these organizations) and comply with any applicable international agreements or agreements with or between foreign and domestic governments that applies to Investree and Investree Group;
   19. Check the identity and / or authority of your attorneys who contact the Investree or the Investree Group or can be contacted by the Investree or the Investree Group and to carry out or respond to requests, questions or instructions from the audited powers or other parties in accordance with security procedures we apply;
   20. Conduct risk assessment, statistical analysis and planning and trends, including carrying out data processing, statistical analysis, credit, risk and anti money laundering, creating and managing credit assessment models, conducting credit checks and reviews and other backgrounds, and keeping your history credit and your authorized attorney (regardless of whether there is a direct connection between the authorized attorney and the Investree or Investree Group) for current and future reference;
   21. Monitor and record electronic calls and communications with you for the purpose of recording, quality, training, investigation and prevention of fraud;
   22. Detect, prevent, investigate and prosecute crimes and fraud including assisting in every crime investigation by the authority that is relevant to you, a Relevant Individual or someone else;
   23. Implement (including, but not limited to, billing the amount owed to the Investree and / or the Investree Group) or defend the rights of the Investree or the Investree Group, which comes from the contract or otherwise;
   24. Conduct the internal management to operate control and management information systems and carry out internal audits or permit the external audits;
   25. Allow recipients of the actual or proposed rights of the Investree, or participants or sub-participants of the rights of the Investree in connection with you, to evaluate transactions intended to be objects of transfer, participation or sub-participation;
   26. Comply with contractual arrangements by or among autonomous industries, industry groups, industry provider associations or other similar entities with Investree or Investree Group; and
   27. Manage the Investree relationship with you, which may include providing information to you or relevant individuals, about products and services of the Investree or Investree Group, if specifically approved or if permitted under applicable laws and regulations;
   28. To market the financial products or services or related to loans through various communication modes including letter, telephone, SMS, fax, e-mail, internet, market research, and designing or filtering similar products or services including by conducting market research, data analysis , and surveys;
   29. Comply with any obligations, requirements, policies, procedures, assessments or arrangements for sharing the data and information in the Investree or Investree Group and the use of other data and information in accordance with each of the Investree Group's programs to complete the sanctions or prevention or detecting money laundering, terrorist funding or other illegal activities.
2. We can combine any information and data, regardless of how the information and data is provided to us or collected by us, and use information or data that is combined for the purposes specified in article [4.1] above.
3. We may also use and disclose Personal Data for other purposes related to any of the above as stipulated in articles 4.1 and 4.2, which normal people will consider appropriate to the situation.
4. As we aim to collect, use, disclose or process your Personal Data depending on the circumstances at that time, these objectives may not appear in the article above. However, we will notify you of these other objectives when requesting your consent for the collection of such Personal Data, except the processing of your Personal Data without your consent permitted by law.
5. We can also share Personal Data with Selected Third Parties including:
   1. Business partners, suppliers and sub-contractors for the implementation of each contract that we hold with them or you;
   2. Advertisers and advertisement networks that need data to select and provide relevant advertisements to you and others. We do not disclose information about individuals that can be identified to advertisers, but we can provide them with aggregate information about our Users (for example, we can tell them that 500 men aged under 30 years click on their advertisements on certain days). We can also use the aggregate information to help advertisers reach the type of audience they want to be targeted. We can use information or data collected from you to enable us to fulfill the wishes of our advertisers by displaying their advertisements to targeted audiences;
   3. Analysis providers and engines searchers that help us in improving and optimizing our site;
   4. Prospective seller or business buyer or asset if we sell or buy a business or any asset, in this case we can transfer your Personal Data to the buyer or the seller as part of the transaction;
   5. Any such organization or person, if we are under an obligation to disclose or share your Personal Data to comply with any legal obligations, or to implement or apply our Terms of Use, our Cookie Policy, and other agreements, or to protect rights , assets, or security of the Investree and the Investree Group, our customers, Users or others. This includes exchanging information with other companies and organizations for the purpose of fraud protection and credit risk reduction;
   6. The third party agents, contractors or service providers that provide administration, postal delivery, telemarketing, telecommunication direct sales, call centers, business processes, travel, visas, knowledge management, human resources, data processing, information technology, computers, payments, debt collection, credit reference or other background checks or other services to the Investree or Investree Group in connection with the business operations of the Investree or Investree Group;
   7. A person or entity that is part of the Investree Group even though only to the extent necessary to fulfill the relevant Permitted purposes/objectives;
   8. The bank is interested in or withdrawal in connection with each check or equivalent that is processed by the Investree or the Investree Group;
   9. Financial institutions with which you own or apply to have business related to each Product and / or Service;
   10. An individual or entity that has an investment or an entity or entity that is obliged or required to make disclosures in accordance with the legal process or based on the requirements of the law, regulations, court orders inside or outside the country or agreements that are binding or valid for Investree or Investree Group and any government authority, inside or outside the country, or between two or more government authorities inside or outside the country, or any disclosure based on and for the purpose of guidelines or instructions given or issued by law enforcement agencies, regulations, government agencies, tax authorities, law enforcement agencies or other authorities, or autonomous regulations from industry group or associations required or expected by financial service providers or stock exchanges to be fulfilled by the Investree or Investree Group, or any disclosures in accordance with each contract or other commitments from Investree or the Investree Group with legal institutions, regulations, government agencies, taxes, law enforcement agencies or other authorities, or autonomous or industrial groups or associations from providers of financial services, or stock exchanges, all of which may be inside or outside Indonesia including disclosure to court proceedings, tribunal courts, and / or legal, regulatory, tax and government agencies, regardless of whether the legal process, obligations, requests, requirements, agreements or guidelines are currently available or made in the future;
   11. Financial institutions, process agents, or other parties who will be involved in money transfer transactions or any banking / financial activities;
   12. The recipient of the actual or proposed transfer from the Investree or Investree Group, or the participant or sub-participant or the recipient of the transfer of the rights of the Investree or the Investree Group in connection with you or other relevant individuals, all or part of the asset or business from Investree or any Investree Group;
   13. the party that gives or submits to provide a guarantee or guarantee to a third party recipient of the guarantee or guarantee your obligations or those of any Relevant Individual.
6. In this case, the purpose of the use and disclosure of information and data about you referred to this article 4 collectively hereinafter called as "Objectives Allowed".

Personal Data and Credit Reference Agency

1. Investree or the Investree Group can, by itself and / or as your agent, provide relevant information and data about you and the Relevant Individual to credit reference agencies for the purpose of updating your credit record in the customer's credit database from the institutions. In this case, relevant information and data about you and the relevant individuals will be related to the product (s) and / or service (or services) held by you and the relevant individuals (whether as borrowers, providers of mortgage rights). , guarantor or guarantee provider and whether with your name and the name of the Relevant Individual itself or with other people) and this information and data will include:
   1. Full name;
   2. Capacity related with the Product (as a borrower, provider of mortgages, guarantor or guarantee provider, and whether by his own name or by name with other people);
   3. dentity number (for example, identity card number, passport or identity card/KTP);
   4. Date of birth;
   5. Correspondence address;
   6. Account or reference number related with each Product;
   7. Type of product held and / or used;
   8. Account status (for example, active, closed, deleted (other than due to bankruptcy decisions), deleted because of a bankruptcy decision);
   9. Trends and status of payments (for example, the payments for all or part, current or at the end of the period);
   10. Account closing date, if any, related to each Product;
   11. Date of product use; and
   12. General information about the account and information about each material standard, if any, related to material standards.
2. For the purpose of determining your credit risk when you submit for each Product or Service, the Investree or Investree Group can access and obtain from credit reference agencies personal information and accounts or records of you and the Relevant Individual (including information about the calculation amount facilities / loans) held by any credit reference institution in the relevant jurisdiction.
3. Investree or Investree Group and Relevant Individuals may also from time to time access personal information and accounts or records of you and the Relevant Individual (including information about the calculation of liability) stored by the credit reference agency for the purpose of reviewing one of the following things in relation to the Product provided to you or a third party whose obligations are guaranteed by you:
   1. Increasing the amount of credit;
   2. Tightening credit (including credit cancellation or decreasing credit amount);
   3. Giving additional products; or
   4. Occupying or implementation of a regulatory scheme related to you or any third party whose obligations are guaranteed by you.
4. Investree or the Investree Group may also obtain credit reports about you from credit reference agencies in considering each request from you to register and upload a Product on our Site for subscriptions. In this case, if you want to access the credit report about you, the Investree will provide you with contact details from the credit reference agency that is related to you to get the report independently.

Administration and Management of Your Personal Data

1. We will make reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by Investree to make decisions that affect you, or disclose to other organizations. However, this means that you must also notify us of any changes to your Personal Data that you initially provided to us. We will not be responsible for relying on inaccurate and incomplete Personal Data resulting from you not notifying us of any changes to your Personal Data that you initially provided to us.
2. We will also place reasonable security arrangements to ensure your Personal Data is sufficiently protected and safe. Appropriate security arrangements will be made to prevent access, collection, use, disclosure, copying, change, leakage, loss, damage and / or unauthorized changes to your Personal Data. However, we do not assume any responsibility for any unauthorized use of your Personal Data by third parties that are entirely caused by factors beyond our control.
3. We will also place the steps to ensure that your Personal Data which is under control or under our control is destroyed and / or made anonymous as soon as possible when it is deemed reasonable to assume that (i) the purpose of the Personal Data is collected no longer fulfilled by storing such Personal Data; and (ii) storage no longer needs to be done for legal purposes or any other business.
4. If your Personal Data will be transferred from any country where you access this Site, we will comply with applicable laws in doing so.

The Right to Refuse Use of Personal Data for Marketing Purposes

1. You have the right to ask us not to process your Personal Data for marketing purposes. We will notify you and ask for your consent before we use your Personal Data for that purpose or if we intend to disclose your Personal Data to any third party for that purpose. You can use your right to refuse processing by giving a sign on the related form that we use to collect your data. Even after you give your consent to Personal Data that will be used for marketing purposes, you can, at any time after that, withdraw your consent by contacting us at [email protected]

Link to Other Sites

1. Our site may, from time to time, contain links to Third Party Sites and websites from our network of partners, advertisers, affiliates or subsidiaries. If you follow a link to one of these websites, you need to know that the website can have or do not have their own privacy policy and that we do not accept responsibility or liability for these policies or the absence of these policies. Read this policy before you submit any information including your Personal Data on the website.

Access to Information

1. You have the right to request from us the Personal Data about you which stored by the Investree. If you want to access, update or change or delete any information that you provide to us, contact us at [EMAIL ADDRESS] to get help. Each access request can be charged a fee of [the amount charged] to meet our costs in providing detailed information that we have about you to you.
2. In exceptional circumstances, Investree may refuse your access to your Personal Data but we will provide you with an explanation of the reason (reasons) that prevent us from doing so under applicable law. These extraordinary conditions include but are not limited to:
   1. The investigating authority or government agency objects to the fulfillment of customer requests by Investree;
   2. Information may, in the exercise of authority and / or reasonable assessment of Investree, affect the life or security of an individual; and
   3. Data is collected in connection with investigations into breach of contract, suspicion of fraudulent activities or violations of law.

Changes to Our Privacy Policy

1. Any changes that we make to our future Privacy Policy will be posted on this page and, if necessary, notified to you via email. Please often recheck to see updates or changes to our privacy policy.

Underage Children

1. The Investree cannot distinguish the age of people who access and use the website. If an underage child (according to applicable law) has given his Personal Data to the Investree without the consent of the parent or guardian, the parent or guardian must contact Investree to delete the relevant Personal Data and delete the name of underage children from the list of customers .

Recognition

1. You acknowledge that if you do not provide relevant information or data or withdraw approval in connection with the collection, use and / or disclosure of relevant information or data as described in the Privacy Policy, Investree has the opportunity not to be able to open or continue a User account, or make or provide or continue with each Product and Service, or continue to allow you to use or access our Site, Site Content, Products, Services or Interactive Services. The Investree or Investree Group will inform you of the consequences of withdrawing the agreement if you tell us about your desire to withdraw your agreement.
2. You guarantee to the Investree and the Investree Group that if you or your attorney is responsible for providing any information or data related to anyone to the Investree and the Investree Group, or providing any such information or data to the Investree and the Investree Group, you have notified and obtained approval from the person(s) concerned to allow the Investree and / or the Investree Group to collect, use and / or disclose information related to the person(s) concerned as described in this Privacy Policy.
3. You agree that you have obtained the consent of all such Relevant Individuals so that any information or data from Relevant Individuals can be processed, stored, transferred or disclosed in and to any country as deemed by the Investree and the Investree Group in accordance with the law which applies to Permitted Purposes. The data can also be processed, stored, transferred or disclosed in accordance with law and practice, local rules and regulations (including any requests based on government regulations, actions and orders) in these countries / jurisdictions.
4. In accordance with the Terms of Use, Cookie Policy and [Master Agreement], you agree that Investree may change and modify the provisions of this Privacy Policy from time to time and bring it after notifying you of the amended Privacy Policy, content the content thereof will change, diversify and complete the Terms of Use, Cookie Policy and [Master Agreement], the agreements and / or arrangements mentioned above will take effect from the date specified in the amended Privacy Policy, and without prejudice to the foregoing, access / use or continuation of your use / use of the Site, Site Content, Products, Services, Interactive Services after such changes must also be considered as your acceptance and approval of these matters.

Contact

Questions, comments and requests regarding this Privacy Policy are accepted and can be directed to the Data Investree Protection Officer at the following address: Data Investree Protection Officer
[email protected]

Last updated on November 15, 2015.