1. General Terms
    1. PT ALAMI Fintek Sharia ("ALAMI") is a Company which provides, manages, and operates an Information Technology-Based Lending Services (LPMUBTI) with sharia principles and is part of PT Alami Teknologi Sharia and all of its affiliates who are members of the ALAMI Group (“ALAMI Group”)
    2. ALAMI is subject to and complies with the prevailing laws and regulations 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/POJK.05/2022 concerning Information Technology-Based Lending Services ("POJK") 77") and Fatwa of the National Sharia Council – Indonesian Ulema Council Number 117/DSN-MUI/II/2018 (“Fatwa 117”)
    3. Information Technology-Based Lending Services with sharia principles (“Services”) is a financial service to connect financing funders with financing beneficiaries in order to provide financing services in the currency of Indonesian Rupiah directly through an electronic system using internet network connection.
    4. 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.
    5. This service is provided and given access by ALAMI through a Platform owned by ALAMI.
    6. This Privacy Policy is binding, and by continuing to use this site, Users of ALAMI Platform acknowledge that they have read, understood, and agreed to any and all content of this Privacy Policy, Cookie Policy, and Terms of Use.
    7. ALAMI Platform is (a) web site and/or mobile application from web sites that is created, owned, and operated by ALAMI, which at the moment can be accessed at and its changes of web address from time to time, and/or mobile application from which is created, owned, and operated by ALAMI, including its iOS and Android version, as well as its changes from time to time.
    8. “Customer Services Team” means ALAMI internal team whose task to provide services to ALAMI Platform Users related to Users’ Private Information management.
  2. Specific Terms

    This Privacy Policy forms part of the ALAMI Platform User Policy (“User Policy”). The use of every feature and / or service available on the ALAMI Platform is a form of express consent from the User to this User Policy and Privacy Policy. Therefore, please read this Privacy Policy carefully to ensure that the User fully understands before registering, accessing and / or using the ALAMI Platform. This Privacy Policy applies binding, is deemed to have been read, understood and approved by all Users. Users also represent and guarantee that the Personal Data that Users provide to ALAMI is true, complete, legally obtained and the User has the full right to provide it to ALAMI.

  1. ALAMI is committed to protect and respect your privacy. We ensure the privacy of Users’ Personal Information as stipulated in this Privacy and Policy and we will not use Users’ Personal Information for purposes other than to provide financing service facilities, and carrying out operational activities, services provision, and operations of ALAMI Platform in accordance to the Privacy Policy set out in this page, with the exception of the following condition
    1. Private Information that is legally owned by a certain party, that is not received from Disclosing Parties, or other parties bound by obligation to protect the privacy of that Private Information,
    2. Private Information that has been known by the general public, without offending any legal constitution in effect,
    3. Private Information that has become Public Information, and not as a result of any violation of Receiving Parties or its Representatives,
    4. Private Information obtained legally from other parties without being bound by non-disclosure clauses with other parties.
    5. Private Information requested to be disclosed by a Court order, Court judgment, arbitrary judgment, government institution, government officials, or required to be disclosed by law, and/or
    6. Private Information which has been developed by Receiving Parties, and is capable to be proven in writing, without reference to any any Confidential Information disclosed by Disclosing Parties.

    ALAMI has the right to obtain, collect and store Personal Data (encrypted) from and / or through the ALAMI Platform, telephone, obtained from ALAMI tools, systems or resources, from third parties based on User consent (including but not limited to credit rating agencies or bureaus ), 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 using ALAMI Services or ALAMI Platform.

  2. The Scope of Private Information definition encompasses any and every data, explanation, information and documents of visitors, Users and/or any other parties related to Users (family, partners, colleagues, employees, companies, directors, representatives, owners, guarantors, main funders, suppliers, other guarantors, and other related parties), patterns or habits from Users in accessing ALAMI Platform, risk profile, financing provision portfolio, browsing or services usage history or transaction history from Users in ALAMI Platform, and any other related information on other patterns or habits including data, information, and related documents or its derivatives related to the use of ALAMI Platform by its Users, including but not limited to:

    1. required or received by ALAMI from Users atau or given, disclosed, uploaded or proposed by Users through ALAMI Platform or ALAMI resources;
    2. received and/or obtained from a third party with the consent of the User, among others for the purpose of verification, creditworthiness assessment and fraud prevention, provision of marketing and payment services, and other third parties (see Point B.3 below for further details regarding with disclosure to third parties);
    3. 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;
    4. obtained or accessed legally by ALAMI based on internal policies and procedures from ALAMI related to ALAMI Services as long as Users are still bound by this Privacy Policy, and/or
    5. obligated to be disclosed or provided by Users in pursuant to the policy of Subscription Agreement and/or Financing Agreement or voluntarily from time to time.
  1. ALAMI reserves the right to request, obtain, collect, manage, store, and use Users Personal Information for the purpose of or related to the purpose of:

    1. Manage the accuracy of information provided by Users;
    2. Manage User registration, and to manage, verify, deactivate, or manage User accounts.
    3. Offer and provide Users with ALAMI features or services through the ALAMI Platform.
    4. Conduct an assessment, analysis, verification, validation or examination of (i) if the User is a Financing Recipient or a prospective Financing Recipient, ALAMI will verify and / or validate the User's identity and background, creditworthiness assessment and the amount of loan we can provide to Users and completing User requests in connection with applications or applications for obtaining financing; (ii) the process or application for registration as a Financier; and / or (iii) User profiles, for the purpose of developing policies, models and risk management structures used by ALAMI.
    5. Fulfillment of ALAMI's rights and obligations based on the provisions of laws and regulations, Membership Agreement, Power of Attorney Agreement and / or Sharia Financing Agreement.
    6. Implementation, management and supervision of the agreements that Users have signed through the ALAMI Platform, including, among others, Membership Agreements, Authorization Agreements and / or Financing Agreements.
    7. Implementation, maintenance and provision of ALAMI operational activities from time to time.
    8. Survey, research, evaluation, market research, product development and / or improvement, promotion, updating of features, uses, products and / or services provided by ALAMI and/or ALAMI Group or related interested parties who may be appointed by ALAMI and/or ALAMI Group.
    9. Checking, responding to, resolving and conducting supervision or monitoring of questions, problems, comments or complaints submitted by Users to the Customer Service Team.
    10. Communicating with Users in connection with the ALAMI Platform through various media such as in-app notifications, electronic mail, telephone, short message service (SMS), short message chat service in the application (in-app messaging / push notifications), and social media.
    11. Understand, study and analyze data, usage patterns or behavior of visitors and users in relation to the needs and preferences for providing ALAMI Platforms.
    12. Law enforcement and ALAMI compliance with legal provisions and statutory regulations. This includes but is not limited to responding to regulatory inquiries, investigations, or complying with filing and reporting requirements or conditions according to statutory regulations and including exchanging information with other companies and organizations for the purpose of fraud protection and / or protection against crime).
    13. Internal administrative processes such as auditing and taxation.
    14. Any other purposes that we notify to you at the time of getting your consent.
    15. (Taken together, these are the “ Goals ”).

In order to achieve the above Objectives and with due observance of the responsibility for proper security with respect to security, confidentiality, protection of User Personal Data, ALAMI can store, process and use User Personal Data set out in this Privacy Policy, and to use it, or disclose it to third parties in the following cases:

  1. ALAMI may disclose User Personal Data that is relevant and reasonably needed to companies or ALAMI's business partners who assist ALAMI in carrying out activities to provide the ALAMI Platform, including activities related to information processing, data centers, banking services, billing, sending funds, electronic wallets, electronic money , administration, correspondence, telecommunications, telephone centers, business processes, travel, visas, knowledge management, human resources, information technology, computers, payment partners, debt collection and collection partners, or security or other services that are concerned with as long as they are bound by a responsibility for the confidentiality of User Personal Data;
  2. ALAMI may disclose User Personal Data which is relevant and reasonably needed to companies or third parties to do something for and on behalf of ALAMI, including companies or institutions that provide Know Your Customers (KYC) or Customer Due Diligence (CDD) services, credit assessment bureaus or Credit Information Management Institutions, or other service providers for credit service assessment purposes, which will only use User Personal Data in accordance with this Privacy Policy.
  3. ALAMI may disclose User Personal Data relating to the Receiver of Financing as part of the Service. This information can be disclosed to the Lenders listed on the ALAMI Platform and can be used by them in determining the loan provision to the Financing Beneficiary.
  4. ALAMI may disclose User's Personal Data to affiliated parties or companies, subsidiaries, and / or entities that are other third parties related to or part of ALAMI which helps ALAMI in carrying out the activities of providing the ALAMI Platform, including but not limited to ALAMI Group, professional consultants, internal, external auditors and partners Similar service providers are in charge of the confidentiality of User Personal Data
  5. Individuals and / or entities, including but not limited to the Financial Services Authority, courts, prosecutors, police, government institutions and other law enforcement agencies either on the initiative of ALAMI or as required by laws and regulations, directions, instructions or institutional policies of the government, government officials or law enforcement agencies.
  6. Each party or prospective transferee from ALAMI or transfer from ALAMI in connection with the Financing Recipient, or all or part of ALAMI's assets or business in connection with corporate actions in the form of mergers, acquisitions, debt financing, sale of assets, or similar transactions.
  7. parties that provide or propose to provide guarantees or third party guarantees to guarantee or maintain the obligations of the Financing Beneficiary.

ALAMI only retains Personal Data for a limited period of time as long as ALAMI needs it to fulfill the purposes for which it was collected, unless required by law. Storage of Personal Data by ALAMI is for at least 5 (five) years in accordance with the provisions of 15 paragraph (3) of the Regulation of the Minister of Communication and Information Technology Number 20 of 2016 concerning Protection of Personal Data in Electronic Systems. ALAMI will do this storage at its discretion or discretion, either through ALAMI systems or other party systems, servers or databases or other third party service providers who cooperate with ALAMI ("Third Party Designation For Personal Data Storage") while maintaining the confidentiality of User Personal Data and compliance with this Privacy Policy

ALAMI has the right to submit offers and/or information regarding products and services from ALAMI and its subsidiaries, and/or affiliates within the scope of the ALAMI Group, via electronic and/or written in accordance with the applicable laws and regulations either through Application, User's personal communication media or Website as a part of promotional needs or service improvement.

  1. Users hereby represent and warrant that all information and Personal Data disclosed and submitted to ALAMI are true and accurate.
  2. User hereby declares and guarantees that the User has obtained all the necessary approvals from related parties, in the event that the User discloses, submits information and Personal Data belonging to the related party for the purpose of utilizing the ALAMI Service and hereby agrees on behalf of that individual for the acquisition, collection, processing, storing and disclosing their Personal Data by ALAMI, so that ALAMI can obtain, collect, process, store and disclose such Personal Data for the Purposes as described in Article 2 of this Privacy Policy.
  1. ALAMI and/or ALAMI Group is committed not to trade User Personal Data to any party, and includes making reasonable efforts that every employee is not involved in the sale and purchase of User Personal Data to anyone. However, ALAMI and/or ALAMI Group is not responsible for any loss suffered by Users in any form including the risk of loss caused or related to such Personal Data including failure to protect the confidentiality of Personal Data, submission, access, acquisition, processing, storage or use or transfer, including disputes, investigations. , any audits, law enforcement and investigation processes, which are not proven to have caused or involved ALAMI and/or ALAMI Group or ALAMI's employees, representatives, attorneys, affiliates or other related parties ("Losses and Legal Matters"). For the sake of clarity, legal certainty and transparency:
    1. ALAMI and/or ALAMI Group will not compensate, respond and cannot be involved, along with employees, subsidiaries, affiliates or representatives, for any claims, demands, requests or statements whatsoever arising from or related to Losses and Legal Issues submitted without including a definite calculation that has been quantifiable, accurate and can be accounted for for real and direct damages (factual and direct damage) experienced by the User, along with evidence that can be received by a court or related judicial institution regarding ALAMI and/or ALAMI Group errors or omissions 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 Electronic Information and Transactions;
    2. ALAMI and/or ALAMI Group 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
    3. ALAMI and/or ALAMI Group is not responsible for any violation of User laws or any third party rights resulting from or related to the acquisition or provision of Personal Data. In the event that there is a Third Party Appointment for Personal Data Storage, the User cannot sue, ask for any compensation or benefit from ALAMI and/or ALAMI Group or employees, proxies, representatives, affiliates or related parties in the event of a breach of confidentiality or failure to protect the confidentiality of Personal Data or loss. and Legal Issues involving, caused or committed by third parties holding the Personal Data concerned or any event beyond ALAMI and/or ALAMI Group reasonable control including but not limited to computer hacking, unauthorized access to computer data and storage devices, computer crashes, security breaches and encryption, poor quality of your Internet or telephone service, and so on. However, ALAMI will still make reasonable efforts to notify Users of the breach of confidentiality when ALAMI finds out about it from the third party.

If the User intends to access information about User Personal Data registered on the ALAMI Platform, the User can contact the Customer Service Team. We will immediately handle User requests to a reasonable extent after we verify User identity appropriately and in accordance with the mechanisms as stated in this Privacy Policy.

  1. To ensure the accuracy, up-to-dateness and use of User's Personal Data, Users can submit requests to ALAMI at any time for the purpose of changing, adding, updating and / or deleting Personal Data that has previously been obtained or given to ALAMI.
  2. The deletion of Personal Data by ALAMI will be carried out in the event that the User withdraws his consent for the processing of his Personal Data and / or in the event that the User asks ALAMI to delete the related Personal Data, subject to the prevailing laws and regulations if ALAMI is required to store Personal Data Certain for legal purposes.
  3. Users agree that adding, updating and / or deleting Personal Data may affect access to the ALAMI Platform and / or Services that Users can use or may result in ALAMI being unable to provide Services to Users. Please also note that deleting the mobile application will not result in the termination of User's use of the ALAMI Platform and / or Services or utilization of User Personal Data. In addition, please also note that even though there are additions, updates and / or deletions of Personal Data that will be recorded in our database, ALAMI can store all information that Users provide for archiving, prevention of fraud and abuse, analytics, fulfillment of legal obligations, or other purposes. ALAMI believes that ALAMI has a valid reason to do so.
  4. Changes, additions, updates and / or deletions of Personal Data as referred to in letters (a) and (b) above will be followed up in accordance with ALAMI's internal procedures, the stages are as follows:
    1. Requests for changes, additions, updates and / or deletions of Personal Data by Users must be submitted by telephone, electronic mail (e-mail) and / or live chat to ALAMI through the Customer Service Team;
    2. The Customer Service Team verifies the application within a period of not more than 3 (three) working days after receipt of the request for amendments, additions, updates and / or deletions;
    3. The Consumer Service Team provides information to the User regarding whether or not the application is approved after verification;
    4. ALAMI makes changes, additions, updates or deletions of the requested Personal Data within a period of not more than 3 (three) working days after the Customer Service Team informs the User that the request for amendments, additions, updates or deletions has been approved; and
    5. The Consumer Service Team will notify Users regarding changes, additions, updates, or deletions of Personal Data that have been made.
  5. We are very careful in protecting the privacy of data owners who are under 18 (eighteen) years of age. In the event that the Personal Data provided to ALAMI is Personal Data belonging to a minor (i.e. under 18 years of age), the parent or guardian of the child can request deletion of the Personal Data in question by sending a request to ALAMI by following the procedures as previously stated .

ALAMI may review, change or update the Privacy Policy on this page from time to time. If necessary changes or updates will be notified in advance or after via notification, email and / or through other means to the User. Continuous access and / or use of the ALAMI Platform and the absence of written notification by the User to Us regarding User objections to changes or updates made is a form of acceptance and approval of the User for changes or updates to this Privacy Policy.

Users are advised to read carefully, thoroughly and thoroughly and check each of the provisions set out in this Privacy Policy from time to time to find out any changes or updates made in this Privacy Policy. Users are responsible for always understanding the changes or updates that we make from time to time. The Privacy Policy shall take effect from the date of such change or renewal.

This Privacy Policy was last modified or updated on 25 April 2022