Key Updates
- Update the names, addresses and contact information of entities disclosed under this Policy.
PT Neo Fintech Indonesia (Registered Address: Gedung B1, Floor 3, Jl. Pluit Selatan Raya No. 2, Pluit, Penjaringan, North Jakarta 14450, DKI Jakarta) and its affiliated companies (hereinafter referred to as "Neo" or "we") are committed to protecting and respecting your privacy. Therefore, we developed a Privacy Policy that covers how we collect, use, disclose, transfer and store your personal data when you use our websites, mobile applications or services. Carefully read and understand our privacy practices before using our products (or services) or submitting your personal data.
This policy will help you understand the following:
I. Definitions
II. How We Collect and Use Your Personal Data
III. How long we keep your personal data
IV. How We Disclose Your Personal Data
V. How We Protect Your Personal Data
VI. Your Rights Regarding Your Personal Data
VII. Cara Kami Memproses Data Pribadi Anak-Anak
VIII. How to Transfer Your Personal Data Worldwide
IX. How This Privacy Policy Is Updated
X. Lainnya
I. Definitions
An "Affiliated Company" is a company associated with Neo due to common ownership or control.
"Third Parties" are companies or persons with whom there is no related relationship arising from common ownership or control with Neo (e.g., non-affiliated companies) or other unrelated persons. Third parties may be financial or non-financial companies, or people other than you and Neo.
"Personal Information" is information related to an identified or identifiable person.
II. How We Collect and Use Your Personal Data
Neo collects data for efficient operations and to provide you with the best product experience. Our channels for collecting personal data may include: (1) you provide us with your data directly, (2) we record certain data about how you interact with our products, and/or (3) we obtain certain data about you from third parties.
- Personal data we collect
(1) Information directly provided by you
When you create and register a Neo account or to further complete a personal profile, we may ask you to provide a nickname and mobile phone number to set up the account or personal profile.
(2) Layanan penggunaan informasi
In addition to the information you provide, we may also collect information about your use of our services through software on your device and other means. For example, we may collect:
l Device information — such as device name, device model, region and language settings, device identification number (UUID), hardware status and information on the device, usage habits, IP address, operating system version, and settings of the device used to access the service, to provide account login services and ensure account security.
l Log information - device error log information, to maintain service stability.
l We may collect your device identification number (UUID) to obtain data statistics, in order to provide better service to you.
l We may collect your country/region, to provide you with the appropriate language.
III. How Long We Keep Your Personal Data
Our retention period for personal data is the minimum time necessary to realize the purposes for which it was collected unless a longer retention period is required by law. After the above storage period expires, we will delete or anonymize your personal data.
IV. How We Disclose Your Personal Data
- At times Neo may provide certain personal information to affiliated companies and strategic partners who collaborate with Neo to provide products and services. Your information will not be shared with third parties for their own marketing or commercial purposes.
(1) Affiliated Companies: We may share your personal information with Neo affiliated companies. We will only share personal data that is necessary in accordance with the purposes stated in this Privacy Policy. If affiliated companies wish to change the purposes for which they process personal information, they will request your authorization and consent again.
(2) Sharing with authorized partners: to realize the objectives stated in this Policy, some of our services will be provided by our authorized partners. We may share some personal data with our partners to provide better services and user experiences. Third party service providers are also used to provide you with customer service. For example, when you log in to your Neo account on a third-party Application, we may share your mobile number with the third party, to provide account login services.
(3) In the event of a merger, acquisition or bankruptcy liquidation, if it involves the transfer of personal data, we will require the new company or organization that acquires your personal data to comply with this Privacy Policy, otherwise we will require the company or organization to request your authorization and consent again.
We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only share personal data that is necessary for the provision of such services. Our partners are not permitted to use personal data shared with them for any other purposes.
- We will only disclose your personal data publicly under the following circumstances:
(1) Once we have obtained your explicit consent;
(2) Disclosure in accordance with law: we may also disclose your personal data publicly if required to do so by law, such as to comply with a subpoena or other legal process, legal action or government agency, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
V. How We Protect Your Personal Data
- We have taken reasonable practical and technical measures to protect information collected in connection with the service. Please note, however, that although we have taken reasonable measures to protect your information, no website, Internet transmission, computer system, or wireless connection is absolutely secure.
- We have taken security measures in accordance with industry standards to protect the personal data you provide and prevent it from access, public disclosure, unauthorized use, modification, damage or loss. We take all reasonable practical measures to protect your personal data. Specifically:
(1) We will de-identify your personal data to reduce the risk of being identified by other organizations or individuals based on that personal information. We use SSL to encrypt various services. We periodically review practices related to the collection, storage and possession of information (including physical security measures), to prevent unauthorized access of various systems.
(2) We only allow our employees and personnel Neo authorized service companies that require personal data to process them to access such personal data, and they are subject to strict contractual confidentiality obligations. If they fail to fulfill these obligations, they will be held liable or their relationship with Neo may be terminated.
(3) The security of your information is very important to us. Therefore, we strive to ensure the security of your personal data and implement measures such as full security encryption during storage and transmission to prevent your information from unauthorized access, use or disclosure. Meanwhile, no one can access certain contents of some encrypted data except the user himself.
(4) When we send and store special categories of personal data, we will use security measures such as encryption.
- If a personal data security incident occurs, in accordance with legal and regulatory requirements, we will immediately notify you of basic information regarding the situation and its possible consequences, response measures we have taken or will take, suggestions for you to implement preventive and risk reduction measures, remedial measures for you, and others. We will notify you in a timely manner by email, post, telephone, push notification, etc. about related situations. If it is not possible to notify each personal data subject individually, we will issue a notification using reasonable and effective methods. At the same time, we will take the initiative to report the handling of personal data security incidents in accordance with regulatory requirements.
VI. Your Rights Regarding Your Personal Data
Neo will respect your legal rights to personal data. Below are the rights you have under the law, and what Neo does to protect those rights. Please note that for security reasons, we may ask you to verify your identity before processing your request.
- The right to be informed: Neo publishes this Privacy Policy to keep you informed about what we do with your personal data. We strive to be transparent in how we use your data.
- Access rights: If you want to access your personal data, you can log in to your account and access the information you provided when registering a Neo account.
- Right to rectification: If you discover there is an error with your personal data that we process, you have the right to ask us to make corrections. You can correct your information by contacting us at avantoindonesia@gmail.com.
- Right to erasure: You can submit a request to us to delete personal data if we have no legal reason to continue processing and storing it. You can delete your information by contacting us at avantoindonesia@gmail.com.
- The right to restrict processing: You have the right to ask Neo to restrict how we process your personal data. This means we are allowed to store the data but not process it further. We retain sufficient data to ensure that we honor your requests in the future. You can exercise these rights by contacting us at avantoindonesia@gmail.com.
- Right to data portability: To the extent permitted by law and regulation, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format. For example, if you decide to switch to a new provider, this will allow you to easily move, copy or transfer your personal information between our IT systems and their systems in a safe and secure manner, without affecting its use. You can exercise these rights by contacting us at avantoindonesia@gmail.com.
- Right to object: You have the right to object to Neo processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for statistical purposes. You can exercise these rights by contacting us at avantoindonesia@gmail.com
- Right to withdraw consent: If you have given us consent to process personal data but later change your mind, you have the right to withdraw consent at any time, and Neo must stop processing your data. You can exercise these rights by contacting us at avantoindonesia@gmail.com.
- The right to object to automated individual decision-making: You have the right to object to decisions based solely on automated processing, including profiling. If this decision significantly affects your legal rights, you can exercise those rights by contacting us at avantoindonesia@gmail.com.
- Right to lodge a complaint: You have the right to lodge a complaint with the data protection authority of the country where you are located about how we handle or process your personal data.
We will respond and reply to your above request as soon as possible, initial processing will usually take place within 3 days of receiving your request.
VII. Cara Kami Memproses Data Pribadi Anak-Anak
- Our products, websites and services are primarily adult-oriented. Young children should not create their own user accounts. We treat anyone under the age of 18 (or the equivalent minimum age in the relevant jurisdiction) as a child.
- If we become aware that a child's personal data has been collected, we will delete the relevant data as soon as possible.
VIII. How to Transfer Your Personal Data Worldwide
- In principle, personal data collected and produced is stored in Singapore.
- However, we provide products and services through our resources and servers worldwide. This means that to ensure the uniqueness of your account so that it can be used globally without being duplicated, after obtaining your authorization and consent, and after your personal data (i.e., mobile phone number and username) has been de-identified, such data may be transmitted to or accessed from countries/territories outside the jurisdiction of the location where you use the product or service.
- Data protection laws in those jurisdictions may be different or even non-existent. In such circumstances, we will ensure that your personal data receives adequate protection. For example, we will ask for your consent for cross-border transmission of your personal data, or implement security measures such as encryption, de-identification before transferring data across borders.
IX. How This Privacy Policy is Updated
We reserve the right to update or modify this Privacy Policy from time to time. We will send you update notifications through various channels. If we make material changes to our Privacy Policy, we will notify you by email (sent to the email address specified in your account) if you provide an email address, otherwise we will notify you by posting a notice on this website or within our tools before the changes take effect.
This Privacy Policy allows adjustments, but we will not reduce your rights under this Privacy Policy without your written consent.
X. Lainnya
If you have questions, complaints or suggestions regarding this Privacy Notice or our privacy management procedures, you can contact us via the means listed below. We will verify your identity and provide a response within the time limits specified in accordance with local laws and regulations. The deadline for submitting responses can be extended if necessary, due to factors including the complexity of the request, the large number of individual requests, and technical availability.
Our email address: avantoindonesia@gmail.com