The website https://www.komodocash.com (“Site”) and the Komodo Cash online platform (“Komodo Cash”) are owned by Komodo Cash Limited and operated by PT TERBIT FINANCIAL TECHNOLOGY (“we”, “us” or “our”).
Defined terms used in this Policy but not defined herein shall have the same meaning as in the Terms and Conditions.
Please read this Policy carefully. By accessing and using this Site, you confirm that you have read, understood and agree to be bound by this Policy in its entirety and to give your explicit consent to the collection, use and disclosure of your personal information as set out in this Policy. If you do not accept the terms of this Policy or at any time you change your mind and no longer want us to collect or process any of your personal information, then you must stop using or accessing this Site.
We respect your right to privacy and are committed to responsible information handling practice
1. Collecting your personal information
We will collect personal information about you via a number of different means including when you:
- submit it to us (including submission via the Site);
- visit the Site;
- carry out transactions via the Site or in connection with the services provided to you or requested by you via the Site; and
- contact us (whether in writing, by email, phone or any other means).
2. Personal information we collect
2.1. We automatically track and collect the following information when you visit our Site: (i) your IP address; (ii) the type of computer you are using; and (iii) the type of Web browser you are using (collectively “Traffic Data”). Traffic Data is helpful for marketing purposes and for improving your experience on the Site.
2.2. As well as your personal details (such as name, address, telephone number, and email address), we will collect details of the transactions you complete and your Bank Mandiri account details used to make or receive transfers when using Komodo Cash.
2.3. There may be occasions where we will supplement the information you provide with information from external third parties or from other publicly available sources.
2.4. We may also collect anonymized details about visitors to the Site for the purpose of collating aggregate statistics for reporting purposes and to calculate referral fees. However, no single individual will be identifiable from the anonymized details we collect or disclose for these purposes.
3. Using your information
We may use the personal information we obtain about you for the following purposes:
- to verify your identity in order to prevent and detect crime, including fraud, and money laundering, including by using scoring methods;
- to allow for binding legal obligations to be created between a Purchaser Member and a Qualified Seller pursuant to a Sale & Purchase Agreement governing the terms on which a Purchaser Member purchases a RN from the Qualified Seller;
- to allow for binding legal obligations to be created between Qualified Sellers and the Facilitator to the Terms and Conditions and Facilitation Agreement relevant to Qualified Sellers;
- to allow for binding legal obligations to be created between Purchaser Members and the Facilitator pursuant to the Terms and Conditions and Facilitation Agreement relevant to Purchaser Members;
- to update the records we hold about you from time to time;
- to carry out statistical analysis and market research;
- to manage and improve the Site and to develop and improve Komodo Cash and our services and products;
- to personalise our services to you including by identifying products and services which you may be interested in;
- where you have given us your consent, to contact you (including by SMS and e-mail) with products and services which we think may interest you;
- where you have given us your consent by virtue of your dashboard settings or otherwise, to disclose your personal information to carefully selected third parties so that they may contact you (including by SMS and e-mail) with products and services which they think may interest you;
- to assess your application for qualification; and
- to validate details on application and documents provided.
4. Disclosure of information
4.1. In the course of providing our services we may need to disclose your personal information to those third parties, as well as other companies within the Facilitator’s group as follows:
- to other members of the Site for the purposes of providing and administering the Komodo Cash and the relevant services;
- to specialist third party services providers supporting the provision of our services;
- to companies which assist us in providing our services, including IT support and professional services, and to companies performing certain functions on our behalf, including to verify the information you provide;
- to a third party if it acquires all (or substantially all) of our businesses and/or assets in connection with the acquisition;
- where we are required to do so by applicable law or by a governmental body, regulatory authority or law enforcement agency with competent jurisdiction; and
- where we consider that such disclosure is necessary to protect, defend or enforce our rights under the Terms and Conditions or any other agreements we have entered into with you. Some of these third parties may be located overseas so we may be required to transfer your information outside of the country where it was collected.
4.2. We will not disclose, sell or rent your personal information to any third party unless you have expressly consented to this. If you do consent but later change your mind, you may contact us or change your settings in the “My Account” section of the Dashboard and we will cease any such activity. Please allow a reasonable period of time for your preferences to be updated.
5. Disclosure of Qualified Seller personal information
5.1. Where you wish to become a Qualified Seller on Komodo Cash, in addition to the uses set out in section 4 above, we may disclose the personal information we obtain about you to:
- fraud prevention agencies, where it will be recorded by them, and supplied to other organizations to perform similar checks, trace your whereabouts and recover debts you owe;
- Purchase Members who have purchased your RN pursuant to a sale and purchase agreement, in order for binding legal obligations to be created between you and those Purchaser Member(s);
- other members of Komodo Cash if required to enforce the terms of any agreement you have entered into;
- For the avoidance of doubt, we will not disclose any personal details or contact numbers of any directors, commissioners, shareholders or employees of any business, or any other data used in the verification of the identities that is relevant to you to other Komodo Cash members.
6. Disclosure of transaction information to Komodo Cash users
We will share transactional information with other users of Komodo Cash as and where is relevant but this information will not include your postal address, bank account or payment details. Please note that where you become a Purchaser Member on Komodo Cash your full name and domicile address will be disclosed to the relevant Qualified Seller in the Sale and Purchase agreement you enter into and vice versa. We are not responsible for any misuse of this transactional information by Komodo Cash members. If you are concerned about the use of your personal information by any other member of Komodo Cash please let us know.
7. Legal compliance
7.1. We may need to share your personal information with third parties in order to comply with our legal obligations including for fraud prevention and anti-money laundering purposes, and also when:
- we check details on applications for future financings or other facilities;
- there is a possibility of legal disputes between Purchaser Members and Qualified Sellers.
7.2. If you give us false or inaccurate information or we suspect or identify fraud, we will record this and disclose the details to fraud prevention agencies and / or the local authorities. We and other organizations may access and use from other countries the information recorded by fraud prevention agencies.
- Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site. They do not gather information about you that could be used for marketing purposes or remembering where you’ve been on the Internet.
- Analytical/performance cookies. They allow us to collect information about how you use our Site, such as, how you move around our Site and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our Site works, understand what interests our users and measure how effective our advertising is.
- Functionality cookies. These are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and remember your preferences and improve your visit.
- Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed.
8.2. Generally, cookies which are strictly necessary for the operation of the Site will expire when you leave the Site and close your web browser session. Other cookies may be more permanent or may not expire unless you actively delete them. You can find out more about how to manage cookies and remove them from your computer at the attached link http://www.aboutcookies.org/
8.3. If you want to reject any of the cookies that we use, then you will need to change your website browser settings. Please note that doing so may impact your ability to access certain parts of the Site and may impact your user experience.
8.4. You can always cleanup these cookies from your browser. Please note it will delete all cookies from other programs. For more information on this please follow your browser guidelines.
Whilst we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.
10. Access to your personal information
10.1. If you want to know what information we hold about you we will provide you with that information on receiving a written request from you. We may require you to verify your identity and, if applicable, specify what personal information you require in order to process the request.
10.2. We reserve the right to charge a reasonable administration fee for handling such requests. Please note that depending on the nature of your request it may take us time to process it.
11. Third party sites
12. Changes to our Policy
We reserve the right to modify or amend this Policy from time to time. You are advised to check this Policy periodically to ensure that you are aware of and are complying with the current version. Changes are binding on users of the Site and will take effect immediately on posting of the revised documentation on the Site. You agree to be bound by such variation and your continued use of this Site shall constitute your acceptance of such variation. We will indicate on the Site that the Policy has changed. You accept that by doing so, we will have provided you with sufficient notice of such change.
This Policy has been prepared and made in both English and Bahasa Indonesia. In the event of a conflict between the English language version and the Bahasa Indonesia version, the English version shall prevail for all purposes and supersede all discrepancies in language.
14. Any questions?
If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us using the details below.
Email address: firstname.lastname@example.org