- PT Alami Fintek Sharia ("ALAMI") is an Information Technology-Based Joint Funding Service Provider Company (“LPBBTI”) Information Technology-Based Money Lending Services that provides, manages, and operates LPBBTI Information Technology-Based Borrowing-Lending Services based on the principles Sharia and is part of PT Alami Teknologi Sharia and all of its affiliates which are members of the ALAMI Group (“ALAMI Group”).
- ALAMI complies with and complies with the laws and regulations in force in Indonesia as well as sharia provisions in all of its operational activities, including but not limited to the provisions of the Financial Services Authority Regulation Number 10 concerning Information Technology-Based Co-Funding Services ("POJK 10"), Law Number 27 of 2022 concerning Personal Data Protection ("UU PDP") and Fatwa of the National Sharia Council – Indonesian Ulema Council Number 117/DSN -MUI/II/2018 (“Fatwa 117”).
- LPBBTI with Sharia principles ("Services") is a financial service to bring together Funders and Beneficiaries in the context of providing financing facilities in the rupiah currency directly through an electronic system using the internet network.
- This service is provided by ALAMI, carrying out its internal policies, regulations, and procedures. ALAMI reserves the right to change its policies, regulations, and procedures from time to time at its discretion.
- This service is provided and provided by ALAMI through the ALAMI Platform.
- Platform is (a) a website and/or mobile from a website created, owned, and operated by ALAMI which can currently be accessed at the URL p2p.alamisharia.co.id and its changes from time to time; and/or (b) the mobile application from p2p.alamisharia.co.id which is created, owned and operated by ALAMI, including iOS and Android and its changes from time to time.
- The Consumer Service Team is ALAMI's internal team whose job is to serve the Platform in relation to the management of User's Personal Data.
- User’s Personal Data is data about an individual ALAMI User who is identified or can be identified individually or combined with other information either directly or indirectly through electronic or non-electronic systems.
- Processing is an action by ALAMI which includes obtaining, collecting, processing, analyzing, storing, repairing, updating, displaying, announcing, transferring, disseminating, disclosing, deleting and/or destroying User's Personal Data with due observance of the applicable laws and regulations.
- a party can prove that the party legally has the User's Personal Data prior to its disclosure by that party and was not obtained from the Disclosing Party or other parties who are bound by an obligation to maintain the confidentiality of information obtained from the Disclosing Party;
- The User's Personal Data has been publicly known without violating the applicable law;
- Has become publicly known information, not due to violation by the Receiving Party or its Representative;
- User’s Personal Data is legally obtained by other parties without confidentiality restrictions from other sources;
- The User's Personal Data is required to be disclosed by court order, court decision, arbitral decision, government agency, government official or according to applicable law; and/or
- User's Personal Data that can be proven in writing has been developed independently by the party receiving it without using the Confidential Information disclosed by the disclosing party.
The scope or scope of the definition of Personal Data includes all data, information, and documents of visitors, Users, and/or parties related to the User, User patterns or habits in accessing the Platform, risk profiles, financing portfolios, history of searching or using services and history of transactions that Users have made on Platform, and information related to other patterns or habits including data, information and related documents or their derivatives related to the use of the Platform by Users, including but not limited to User's Personal Data which: User patterns or habits in accessing the Platform, risk profiles, financing portfolios, history of searching or using services and history of transactions that Users have made on Platform, and information related to other patterns or habits including data, information and related documents or their derivatives related to the use of the Platform by Users, including but not limited to User's Personal Data which:
- required or obtained by ALAMI from Users or submitted, disclosed, downloaded or submitted by Users through Platform or ALAMI resources;
- obtained and/or obtained from a third party with the consent of the User;
- collected by ALAMI when Users participate in events organized by ALAMI, such as celebration, seminars, workshops, competition programs or awards, or any other events, which include all documentations in the form of pictures, video recording, and/or Users’ voice;
- must be submitted or have been given by the User in accordance with the provisions of the Membership Agreement and/or Financing Agreement or voluntarily from time to time.
ALAMI has the right to carry out Processing User's Personal Data in the framework of or related to (“Purposes”):
- To manage the accuracy of the information that Users provide;
- Assessment, analysis, verification, validation or examination of (i) requests or applications for obtaining financing; (ii) the process or application for registration as a Financing Provider; and/or (iii) User profile;
- Fulfillment of ALAMI's rights and obligations based on legal provisions and statutory regulations, Membership Agreement, Authorization Agreement and/or Sharia Financing Agreement;
- Execution and supervision of the implementation of the Membership Agreement, Authorization Agreement and/or Financing Agreement;
- Implementation of ALAMI and/or ALAMI Group operational activities from time to time in good faith;
- Survey, research, evaluation, development and/or marketing of products and/or services by ALAMI and/or ALAMI or related interested parties that may be appointed by ALAMI and/or ALAMI Group;
- To provide information in the form of (among other things) the latest news about ALAMI, promotional materials, registration process, and/or other information related to ALAMI products and/or services to Users through personal communication media, including but not limited to Electronic Mail (e-mail) and/or WhatsApp.
- Study the behavior of visitors and Users of Information Technology-Based Co-Funding Services; and
- Law enforcement and ALAMI's compliance with legal provisions and laws and regulations.
- banks, credit rating bureaus, agents, partners, or other supporting service providers, including but not limited to banking services, billing, fund transfer, administration, correspondence, telecommunication, telephone center, business process, travel, visa, knowledge management, human resources, data processing, information technology, computers, payment, collection of debts, checking credit references, or security or other services of interest while bound by a confidentiality responsibility for User's Personal Data;
- Individuals and/or entities that are other third parties related to or part of the ALAMI Group and are responsible for the confidentiality of User's Personal Data for certain purposes;
- Individuals and/or entities, including but not limited to the Financial Services Authority, courts, prosecutors, police, and other government institutions either on ALAMI's initiative or as required by legal provisions and statutory regulations, directives, instructions, or policies of government institutions or officials;
- Any party or candidate for transfer from ALAMI or transfer from ALAMI in relation to the Financing Recipient, or all or part of ALAMI's assets or business; and/or
- parties that provide or propose to provide guarantees or third party guarantees to guarantee or maintain the obligations of the Financing Beneficiary.
- Processing of User's Personal Data is carried out by ALAMI Employees and/or assigned Employees who are under the auspices of the ALAMI Group and have obtained an Assignment Letter from ALAMI's Management.
- ALAMI has the right to carry out Processing User's Personal Data in the framework of or related to (“Purposes”):
Methods of Obtaining, Collection, and Storage of Personal Data.
ALAMI users are committed to processing Personal Data in accordance with the principles of Personal Data Protection including
- Conducted in a limited and specific manner, legally valid and transparent;
- Done in accordance with the Purpose;
- Done by guaranteeing User rights;
- Accurate, complete, not misleading, up-to-date, and accountable;
- Done by protecting the security of User's Personal Data from unauthorized access, unauthorized disclosure, unauthorized modification, misuse, destruction, and/or removal of User's Personal Data;
- Done by notifying the purposes and activities of the Processing, as well as the failure to protect the User's Personal Data;
- Destroyed and/or deleted based on the User's request or based on the applicable laws and regulations; and/or
- Conducted responsibly and can be proven clearly.
- ALAMI has the right to Process the User's Personal Data (encrypted) from and/or through Platform, telephone, obtained from ALAMI tools, systems or resources, from third parties based on User approval (including but not limited to institutions or bureaus credit rating), affiliates or related parties or representatives of ALAMI, or accessed by ALAMI or submitted by Users through or obtained from systems, hardware (hardware), software (software) or equipment (devices) that ALAMI or Users use or are involved in utilization ALAMI Services or Platforms.
- Storage of User's Personal Data by ALAMI is as long as the User is registered on the ALAMI Platform until the request for deletion or destruction of User's Personal Data by the User is made provided that all of ALAMI's and User's obligations have been fulfilled. ALAMI will carry out this storage according to its policy or discretion, either through the ALAMI system or other party systems, servers or databases, or other third-party service providers who cooperate with ALAMI ("Third Party Appointment For Storage of Personal Data") while still prioritizing the confidentiality of Personal Data User.
- ALAMI users are committed to processing Personal Data in accordance with the principles of Personal Data Protection including
Representations and Warranties
- Users hereby declare and guarantee that all information and User's Personal Data that is disclosed and submitted to ALAMI is true and accurate.
- Users hereby declare and guarantee that they will comply with and comply with all provisions of laws and regulations in the financial services sector, including but not limited to taking the necessary actions in accordance with the provisions of laws and regulations in the financial services sector.
ALAMI's Commitment to User's Personal Data
- ALAMI can provide information regarding the Processing of User's Personal Data in a transparent and easily understood by the User through the Consumer Service Team.
- ALAMI carries out the Processing of User's Personal Data by complying with and complying with the applicable laws and regulations.
Limitations and Compensation
ALAMI is committed not to trading the User's Personal Data to any party and includes making reasonable efforts that each of its employees is not involved in buying and selling the User's Personal Data to anyone. However, ALAMI is not responsible for losses suffered by Users in any form including the risk of loss resulting from or related to the Personal Data including failure to protect the confidentiality of Personal Data, submission, access, acquisition, processing, storage or use or transfer thereof, including disputes, investigations, audit, law enforcement, and any investigation process, which is not proven to be caused by or involving ALAMI and/or ALAMI Group or employees, representatives, attorneys, affiliates or other related parties of ALAMI and/or ALAMI Group ("Losses and Legal Issues"). For the sake of clarity, legal certainty, and transparency:
- ALAMI and/or ALAMI Group will not provide compensation, respond, and cannot be involved, along with their employees, subsidiaries, affiliates, or representatives, for any claims, demands, demands or statements whatsoever arising from or related to Losses and Legal Issues submitted without including definite calculations that have been quantified, accurate and accountable for real and direct damages (factual and direct damage) that Users experience, along with evidence that can be accepted by courts or related judicial institutions regarding errors or omissions ALAMI and/or ALAMI Group based on Articles 1865 and 1866 of the Civil Code, Article 164 Het Herziene Indonesisch Reglement and Article 5 paragraph 1 of Law Number 11 of 2008 concerning as amended by Law Number 19 of 2016 concerning Information and Electronic Transactions;
- ALAMI is not responsible for the accuracy (except for Personal Data that has been verified by ALAMI in accordance with its policies), legality, legality and completeness of User's Personal Data and is not obliged to notify User or any party about this unless legally required; and
- ALAMI is not responsible for violations of User law or the rights of any third parties due to or related to obtaining or providing Personal Data. In the event that there is an Appointment of a Third Party for the Storage of Personal Data, then the User cannot sue, request compensation, or any benefit from ALAMI or any employee, proxy, affiliate, or related party of ALAMI in the event of a breach of confidentiality or failure to protect the confidentiality of Personal Data or Losses. and Legal Issues involving, caused, or carried out by third parties who hold the Personal Data concerned. However, ALAMI will still make reasonable efforts to notify the User regarding the breach of confidentiality when ALAMI finds out about it from the third party.
User's Right of User's Personal Data
- The User can submit a request to ALAMI for the purpose of completing, updating, and/or correcting data errors and/or inaccuracies Personal User changes previously obtained or submitted to ALAMI.
- Users can access and obtain a copy of their own User's Personal Data.
In the event that the User wants termination or cancellation as an ALAMI Platform User, then;
- Users can apply for termination of processing, delete and/or destroy User's Personal Data to ALAMI; and/or
- the User submits a request to withdraw the consent to process the User's Personal Data that has been submitted to ALAMI.
- Users can submit objections to ALAMI if there is a discrepancy with the actual profile of the results of Processing User's Personal Data which is carried out automatically by ALAMI.
- Users can submit delays and/or restrictions on User's Personal Data if the Processing is outside the purpose of processing User's Personal Data.
User rights as stated in points (a) to (e) will be followed up in accordance with ALAMI's internal procedures, the stages of which are as follows:
- Applications submitted by Users to complete must be submitted via telephone, electronic mail (e-mail), and/or live chat to ALAMI via the Consumer Service Team;
- The Consumer Service Team verifies the application within a period of no more than 3 (three) working days after receiving the request submitted by the User;
- The Consumer Service Team provides information to the User regarding whether or not the application is approved after verification;
- ALAMI carries out the request submitted by the User within a period not exceeding 3 (three) working days after the Consumer Service Team informs the User that the request has been approved; and
- the Consumer Service Team will immediately convey to the User the results of the implementation of the User's request.
- In the event that the Personal Data provided to ALAMI is Personal Data belonging to a minor (i.e. under 18 years of age), then the parent or guardian of the child can request the deletion of the Personal Data in question by sending a request to ALAMI by following the procedure previously mentioned.