Version Update Notice
The latest version of this policy has been updated. Please read this policy carefully before continuing to use the Platform.
Welcome to the Platform! The Platform is developed, operated, and made available to you (hereinafter referred to as "you") by PT Neo Fintech Indonesia and its affiliates (hereinafter referred to as "we", "us", or "our"), with registered address: Gedung B1, Lantai 3, Jl. Pluit Selatan Raya No. 2, Pluit, Penjaringan, Jakarta Utara 14450, DKI Jakarta, as a venue for you to use Avanto services (hereinafter referred to as the "Platform").
In the course of your use of our products and services, we may collect and use your personal information. In this policy, "personal information" or "personal data" means any information that can, alone or when combined with other information, identify an individual natural person.
Through this policy, we explain to you how we process your personal information, the purposes for which we collect, use, and disclose your personal information while you use the Platform, your rights regarding your personal information, and the security measures we implement to protect personal information.
Please read this policy carefully before using the Platform so that you understand our practices for collecting, using, and protecting your personal information. If you tap "Agree" to enable the Platform, this means you clearly and expressly understand the collection and use of information described below, as well as the rights you hold.
This policy will help you understand the following:
- How we collect and use your personal information
- How we store and retain your personal information
- How we share, transfer, and disclose your personal information
- How we protect your personal information
- How you exercise your rights as a data subject
- Third-party service providers and their services
- How we protect children's personal information
- How this personal information protection policy is updated
- Contact us
Contents
1. How we collect and use your personal information
The information we collect depends on the features/services you actually use, the environment in which you interact with us, and the choices you make, including your privacy settings and the features/services you use. Because of differences in market country/region, system/application version, and application installation/download conditions on devices, the features/services provided by this application may vary. Therefore, the features/services actually provided, together with the corresponding personal information processing and permission invocation, shall be subject to the final product you use.
Please note that you are not required to provide personal information to us; however, if the personal information you choose not to provide is necessary for the application to deliver the related services, we may be unable to provide those services or to respond to and resolve issues you encounter. We collect personal information so that we can operate more efficiently and provide you with the best experience. Below we explain in detail the types of personal information we collect, and the reasons and purposes for collecting and using it.
Channels through which we collect personal information include:
• personal information you provide directly to us;
• related information we obtain while you use this application; and/or
• personal information about you that we obtain from third parties.
To avoid doubt and for transparency regarding personal information processing, if this policy expressly states that certain personal information is stored only locally, that information is collected and processed only on your device and is not uploaded to our servers, and therefore is not subject to this policy.
Please note: if you provide personal information of another person, ensure that you have obtained the consent of the relevant data subject.
1.1 Account services
To use Avanto services, you must register for and log in to an account first. Before registering, please read carefully the Account Privacy Policy. After you fully understand and agree to our processing of your personal information in accordance with that privacy policy, you may create and log in to your account. We collect this information to provide complete account services and to help you manage data generated from your use of Avanto.
1.2 Avanto services
Avanto services are provided by PT Neo Fintech Indonesia. Before applying to use Avanto services, please read carefully the Avanto Privacy Policy and ensure that you fully understand and agree to the processing of your personal information by the Avanto service provider in accordance with that privacy policy.
1.3 Cookies and similar tracking technologies
At present, our provision of these services to you does not involve Cookies or similar tracking technologies.
2. How we store and retain your personal information
2.1 Retention period
We will retain your personal information for the shortest period necessary to provide products/services as required by applicable laws and regulations. When any retention period ends or other conditions for deletion are met, we will delete or anonymize your personal information, except where otherwise required by laws and regulations.
If we discontinue part or all of our products or services for special reasons, we will notify you in a timely manner and cease collection and processing of personal information related to those products or services, and will delete or anonymize the personal information we hold in relation to those products or services, except where otherwise provided by laws and regulations.
2.2 Storage location
As a company operating globally, we provide products or services through resources and servers in various regions. To ensure service quality (for example, processing speed), while complying with local data protection laws, we may store users' personal data based on the sales region of the device or its configuration settings. Our data centers are located in France, the United States, Singapore, India, and Indonesia. This means your personal information may be transferred to, or accessed from, jurisdictions outside the country/region where you use the products or services.
You understand that risks under different data protection legal frameworks may differ. In such circumstances, we will take steps to ensure that the data we collect is processed in accordance with this policy and applicable law, and that your personal information receives protection equivalent to that in the country/region where you use the products or services—for example, by requesting your consent to cross-border transfer of personal information, implementing encryption or de-identification, or entering into necessary data transfer/sharing agreements with data recipients before cross-border transfer.
3. How we share, transfer, and disclose your personal information
As required by law, your personal information may from time to time be shared with the following companies or organizations (for example, our affiliates and strategic partners to jointly provide products or services). We will, through agreements or other appropriate measures, require third parties to apply comparable confidentiality and security measures when processing personal information.
(1) Affiliates: To facilitate our provision of services to you, your personal information may be shared with our affiliates. We will share only necessary personal information. If we or an affiliate changes the purpose of use and processing of personal information, we will seek your consent again.
(2) Authorized partners: Solely for the purposes stated in this personal information protection policy, certain of our services may be provided by authorized partners. We may share some of your personal information with partners to provide services and improve user experience. We currently do not share your personal information with third-party partners.
(3) Other organizations in mergers, acquisitions, or bankruptcy liquidation. In the event of a merger, acquisition, or bankruptcy liquidation involving transfer of personal information, we will require the new company or organization holding your personal information to remain bound by this privacy policy; otherwise, we will require that entity to seek your consent again. If no transfer of personal information occurs, we will notify you adequately and delete or anonymize all personal information under our control.
(4) Any party to whom you authorize us to disclose your personal information.
(5) Any party required by law to receive disclosure, for example where we are required to respond to a court subpoena, legal process, litigation, or mandatory request of a government authority, or where we believe disclosure of your personal information is necessary to protect our rights, ensure your safety or that of others, investigate fraud, or respond to government requests.
4. How we protect your personal information
The security of your personal information is very important to us. We implement reasonable technical, managerial, and physical security measures to protect your personal information from unauthorized access, theft, disclosure, alteration, or loss. We periodically review our security measures in light of available new technologies and methods.
5. How you exercise your rights as a data subject
We respect your rights regarding your personal information and strive to protect your control over your data. We provide various means for you to manage privacy and personal information more conveniently. Please note that settings may differ across device models, operating systems, and software versions; we may also adjust settings to optimize your experience. The management paths below are for reference only. If you have questions about how or through which channels to exercise related rights, contact us as disclosed in "Contact us" below.
5.1 Right to be informed
We inform you through publication of this policy how we process and protect your personal information. You may periodically review this policy, receive email or SMS regarding policy updates, or contact us as disclosed in this policy to understand the collection and use of your personal information.
5.2 Right of access
You may inquire about or access your personal information directly through our product or service interface.
5.3 Right to rectification
If you find that personal information we process about you is inaccurate or incomplete, you have the right to request that we correct or complete it. For some personal information, you may correct or modify it on the relevant feature page of the product or service.
5.4 Right to erasure
For personal information generated during your use of this application and stored by us, you may submit a request through the "Contact us" channel at the bottom of this policy. We will process it in accordance with applicable laws, regulations, and supervisory requirements.
5.5 Right to change the scope of consent or withdraw consent
Each service function requires certain basic personal information (see the collection and use section above). You may change the scope of your consent to our continued collection of personal information or withdraw consent by deleting information, disabling device permissions, or changing related product/feature settings.
5.6 Right to obtain a copy of personal information
You have the right to request that we provide you with a copy of the personal information you have provided, or transfer such copy to a third party you designate, by contacting us as set out in "Contact us", subject to applicable laws and regulations.
5.7 Right to restrict or delay processing
Data subjects have the right, in accordance with the purposes of personal data processing, to request restriction or delay of processing of personal data. You may contact us through the channels in "Contact us" to exercise this right.
5.8 Right to lodge a complaint
You have the right to lodge a complaint with us through the channels disclosed in "Contact us".
You also have the right at any time to lodge a complaint with the competent supervisory authority or bring proceedings before a court of competent jurisdiction. However, we hope to resolve your concerns first; therefore, please contact us directly in the first instance.
6. Third-party service providers and their services
Some of our features/services may contain links to third-party websites, products, and services. This policy does not apply to websites, products, and services provided by those third parties—for example, when you tap a card in this application and are redirected to a third-party application or website.
Please read carefully the personal information protection policies and related terms of third-party site operators or service providers before accessing their features/services.
7. How we protect children's personal information
We attach great importance to our obligations and responsibilities to protect children's personal information and strive to create a healthy online environment for children. We regard anyone under 18 years of age (or the equivalent minimum age of full legal capacity in the relevant jurisdiction) as a child.
This application is not directed at children and we do not provide services to children. Avanto business conducted through this application may identify user age through identity verification. We do not actively collect, store, use, transfer, or disclose children's personal information, and do not use children's personal information for marketing purposes. If you are a child, a parent/guardian of a child, or discover that information we process may include children's personal information, contact us as provided in this policy; we will endeavor to delete related data as soon as possible.
8. How this personal information protection policy is updated
We reserve the right to update or modify this privacy policy from time to time. For material changes, we will notify you in an appropriate manner and state the latest update date at the beginning of this policy.
The latest version of this personal information protection policy applies to our processing of your personal information and takes effect from the update date.
9. Contact us
If you have any questions, suggestions, or complaints regarding this policy or personal information protection, contact us at:
Our email address: avantoindonesia@gmail.com
We will complete identity verification and respond to your request within the period required by applicable local laws and regulations. Given the complexity and volume of individual requests and technical limitations, this period may be extended where necessary.