TREASURY PRIVACY POLICY

A. BACKGROUND

Effective June 23th, 2023

This Privacy Policy describes how PT Indonesia Logam Pratama( hereinafter referred to as, “Treasury”, “We”, “Us”, or “Our”) collect, store, use, process, retain, transfer, disclose and protect your Personal Information in connection with your access to use of the Apps Treasury.

We are a commodity trading platform which includes but is not limited to the physical Gold trading. We are also the first digital Gold trading platform that has obtained a license from BAPPEBTI on the 13th of December 2021, based on the Head of BAPPEBTI Decree Number 001/BAPPEBTI/P-ED/12/2021 concerning Approval as a Physical Digital Gold Trader to PT Indonesia Logam Pratama and Certificate of Approval as a Physical Digital Gold Trader Number 001/BAPPEBTI/P-ED/12/2021. This guarantees the safety of the transaction made by you as Treasury User.

We are committed to ensuring that in collecting and using the information provided to us or information about visitors of Web Treasury (as described below), we do so in accordance with the provisions of the applicable laws regarding the protection of personal data in Indonesia
This Privacy Policy explains our method of collecting, using, processing, retaining, transfering, disclosing and protecting the Personal Information that we have acquired from you. For further information, please contact: [email protected].

B. SCOPE OF PRIVACY POLICY

This Privacy Policy is applicable for the use of every transaction that you make through the Web and Apps Treasury which includes buying, selling, printing and transferring, including when you request information from us or use other services from us, or as a result of your relationship with one or more of our official partners, or as a result of a working relationship with us, or against any information collected by third parties.
This Privacy Policy also applies to all of our websites and online services, including the following:

• Web Treasury, with the address at www.treasury.id (including the content based on the sub-domain of this website);
• Apps Treasury, which you can download or have downloaded from the App Store of Playstore; and
• Web Treasury, Apps Treasury, or our other online services created or maintained by us from time to time where this Privacy Policy appears.

We may need to obtain certain details from you through our online services if, for example, you intend to transact through the Web Treasury, register to use our application, or join and participate in various programs that we do or will do in the future. Our online services make use of cookies and similar technologies.

This Privacy Policy does not describe our consumer confidentiality obligations, but these obligations are described in the agreement and terms and conditions of using our online services.

C. COLLECTING PERSONAL INFORMATION

General

We will collect personal information directly from you for identification purposes. We may also collect personal information from third parties, such as competent authorities, your company, other organizations with whom you have contact, government agencies, credit reporting agencies, recruitment agencies, information or service providers, publicly available records and other parties. the third described in the ‘Disclosure of Your Information’ section below. If we collect information from third parties, we will verify that information based on different sources of information that are legally known in Indonesia.

We will handle any unwanted information in accordance with the Laws and Regulations of the Republic of Indonesia, including destroying or de-identifying (anonymity) when it is mandatory for us to do so based on the Laws and Regulations of the Republic of Indonesia

We may collect recent personal information and history which includes  but not limited to your name, contact details on your mobile phone, identification, organization, employment relationship, position held IP address, location information, device data (such as IMEI number and the names of the applications that you have installed on your device), and details of questions/complaints about you. We may also collect personal information about your other relationships with us, including any contact we have with you by telephone, email or online. It is necessary for you to know that any sharing of your personal information with us is carried out by taking into account all the Terms and Conditions of all the features contained in the Apps Treasury

Where it is not necessary for the Personal Information to be associated with you, we will use reasonable endeavors to remove the means by which the Personal Information can be associated with you as an individual before disclosing or sharing such information

We will not sell or lease your Personal Information.

Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information if we notify you and we have obtained your consent for the disclosure or sharing.

 

Online Service

If you use our Online Services, we may collect information in the following ways:

• Information that you provide by completing forms (this includes information that you provide to us when registering for our online services, subscribing to our services, participating in further programs and services);
• Information that you provide to us if you contact us, for example reporting a problem with our online service or asking a question or feedback; and
• Details of visits made to our online services, including but not limited to the amount of network traffic received, connection activity records (logs) (including, where available, IP addresses and locations of devices connected to online and online services as well as information and pointers and identification other technical details about the device and nature of the visit) and from where the data was accessed.

In order to make purchases, sales, storage, printing and various transactions available through our online services, you must provide a number of personal information, which includes but not limited to:

• Full Name
• Email Address
• Mobile Number
• Bank Account
• ID Card Photo
• Selfie with ID Card Photo
• NPWP
• Family Card (for additional heirs)
• Complete Address for Shipping

We advise you to provide factual information. We don’t hold any responsibilities or any liabilities for any loss that arises from the incorrect information provided.

D. USE OF PERSONAL INFORMATION

We use and process your personal information to provide and improve our services to you, for example:

• Facilitate the transactions that you make with us through our online services, including for the purposes of payments that you make in connection with the implementation of the Gold transaction;
• Manage and carry out our obligations in connection with the legal engagement that exists between you and us through our online services;
• Carry out monitoring activities on transactions that exist or have been carried out by you through our online services;
  Ensure that content from our online services is presented in the most effective and secure manner for you and your device and settings;
• Regularly provide you with information and services, including those related to transactions that you will or have done, that you have requested from us or which we feel may interest you as permitted by the laws and regulations of the Republic of Indonesia, applicable laws , and measure the success and effectiveness of services to improve the services we offer to you and other recipients;
• Maintain and develop our relationship with you;
• For developing, enhancing, and providing services and features in Treasury;
• For research, planning, service development, security or risk management purposes;
• For the maintenance and updating of our records;
• Carry out obligations arising from any agreement made and agreed between you and us in connection with Gold transactions;
  Facilitate the operation of our internal business activities, including meeting the requirements stipulated in the laws and regulations of the Republic of Indonesia, our legal and professional obligations;
• Provide flexibility for you to use or access interactive features or secure areas on our website, if you choose to do so;
  Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing and/or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our information technology platform;
• Detecting, investigating, preventing or remediating violations of the Terms and Conditions, any applicable internal Treasury services policies, relevant industry standards, guidelines, laws or regulations;
• Making such disclosures may be required by any law or regulation of any country applicable to us or our affiliate, government official or other third party, including any card association or other payment network.  Disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement in any country applicable to us or our affiliate (including anti-money laundering and counter-terrorist financing reporting requirements);
• Making any disclosure to prevent any harm or financial loss, to report any suspected illegal activity or to deal with any claim or potential claim brought against us or our affiliates;
• Enabling any due diligence and other appraisals or evaluations for actual or proposed merger, acquisition, financing transactions or joint ventures;
• Any other legitimate business purposes, such as protecting you and other users of TreasuryApp from losses, protecting lives, maintaining the security of our systems and products, and protecting any of our other rights and/or properties.

We cannot do such things without your personal information. For example, we are unable to effectively provide our services to you.
Based on applicable data protection regulations, we have the principle of caution to ensure that your personal information is accurate and up-to-date. Therefore, we request that you notify us of changes to your information to [email protected]

E. DISCLOSURE OF YOUR INFORMATION

We have database rights in the information collected. We do not sell or pass on this information. As a company that officially cooperates with our partners who support us to provide the best service to you, we may allow our partners/partners to access your information in accordance with the Indonesian personal data protection laws in providing our services or conducting our business activities.
In addition, subject to Indonesia’s personal data protection laws, we may exchange your personal information with third parties when:

• You have previously acknowledged and given written consent to us to share your personal information by agreeing to every pop-up notification that appears when your consent to accessing your personal data is required as stated in point 3 (COLLECTING PERSONAL INFORMATION);
• We have an obligation under the laws and regulations of the Republic of Indonesia to do so (for example, to comply with provisions regarding anti-money laundering, terrorism financing, fraud prevention, etc.) or protect our rights and interests, property or safety of Treasury, our users or others;
• Every, or substantially all, Treasury assets are combined with or acquired by a third party, or We expand or reorganize Our business activities, in which case Your personal information may become part of the assets transferred or combined or We may need to transfer your information to a newly established entity or third parties with which our business activities will be carried out;
• We provide anonymous statistical information about Web Treasury users and related usage information to reputable third parties, including search engine and analytical site operators; or
• We use third party service providers to provide services that involve data processing, for example archival services, audits, reference checking, professional advisors (including legal, accounting, financial and business consultants), mailing houses, delivery, technology, websites, research, banking, payments, data processing, insurance, forensics, litigation assistance, marketing and security.

Some of the third parties with whom we will share personal information may be located outside of Indonesia, your country or the country in which the data is provided (collectively, the “jurisdiction of origin”), including countries where our partner, partner and affiliate offices are located. When such third party will be subject to privacy and confidentiality obligations, in the event that such obligation is an obligation under law, you acknowledge that such obligations may differ from the provisions of the privacy protection laws under the Laws and Regulations of the Republic of Indonesia Indonesian law from jurisdiction origin. In that case We are not responsible for enforcing the laws of Indonesia’s jurisdiction of origin, and you cannot seek compensation under those laws

F. SECURITY

Transmission of information over the internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services; any transmission is at your own risk. Once we receive your information, we will take reasonable steps to use security procedures and features to try to prevent unauthorized access, modification or disclosure. For example, electronic communications via insecure web platforms including WhatsApp, may not be secure, virus free or delivered successfully. If you communicate with us using an insecure web platform, you run the risk that the communication between us may be intercepted, not received, delayed, corrupted or received by people other than the intended recipient

We take reasonable steps to securely store information whether in electronic or physical form, including the following:

• We store information in an access controlled place or in an electronic database that asks for logins, passwords and pin numbers.
• We require third party data storage providers to meet appropriate information security industry standards.
  All staff and third party service providers who have access to confidential information are subject to confidentiality obligations.
• All staff who have access to confidential information are required to know about the protection of personal data under Indonesian personal data protection laws for the purpose of preventing failure to protect personal data and We ask third party service providers who have access to confidential information to do the same.
• Subject to Indonesia’s personal data protection laws, the data we collect from you may be transferred to, and stored in, a destination outside the jurisdiction of origin.
• Data collection may also be processed by staff operating outside the home jurisdiction who work for us or our partners or for one of our suppliers or our partners.

You can help us to maintain information security; please remember that any username or password or PIN number associated with the Web Treasury of our website is personal to you and should not be shared with anyone. You should stop using your username, password and PIN number and notify us immediately if you suspect that someone else may be using it.

G. COOKIES

Our online services use cookies and other similar technologies, for example, to distinguish you from other users when you browse Web Treasury or use our online services and also to make us improve our online services.

H. THIRD PARTY SITES

In addition to our online services, which we control directly, we may also use and provide links to websites controlled by third parties.

If you use or follow a link to any of these third party websites, please be aware that these websites have their own privacy policies and we are not responsible for any of their use of information about you.

I. YOUR RIGHTS

Some of our online services may provide registered users with the facility to directly access and update certain profile information.

Indonesia’s personal data protection laws give individuals the right to access, modify and delete their personal information. If you wish to request a copy of your data and wish to change or delete the information about you that we store, please contact us as specified below.

We will notify you in writing if there is a failure to protect the confidentiality of your personal data in our electronic system within 14 days from when we become aware of the failure.
At any time if you choose to stop receiving promotions, programs and the latest information from us, please use the “unsubscribe” option contained in emails or other materials.

J. STATUS OF PRIVACY POLICY

By using our online services, we assume we have received your agreement to the terms of this Privacy Policy.

The practice of managing technology and information continues to evolve. Therefore We may need to change this Privacy Policy in the future. Accordingly, we recommend that you review this page regularly to ensure that you are aware of any changes to any of its terms.

K. CONTACT AND MORE INFORMATION

To find out more about Treasury, please visit: www.treasury.id.

If you have questions about this Privacy Policy, or would like to make a written complaint about how we handle your personal information, please contact our service personnel via: [email protected].

If you make a privacy complaint, we will respond so you know how your complaint is being handled. We may request additional details from you, consult with others and maintain records of your complaint.