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  1. General Terms
    1. PT Alami Fintek Sharia ("ALAMI") is an Information Technology-Based Joint Funding Service Provider Company (“LPBBTI”) that provides, manages, and operates LPBBTI on the Sharia principles.
    2. 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”).
    3. 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.
    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 provided by ALAMI through the ALAMI Platform.
    6. 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.
    7. This Privacy Policy is binding, deemed to have been read, understood, and agreed to by all Platform ALAMI
    8. 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.
    9. 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.
  2. Specific Terms
    1. Scope
      1. ALAMI is committed to seeking to protect the confidentiality of Users' Personal Data in accordance with the provisions of this Privacy Policy and not to use the User's Personal Data for any purpose other than to provide financing facilities and carry out operational activities, provide services, services, and operate the Platform ALAMI is in accordance with the provisions of this Privacy Policy, provided that these matters do not apply to User’s Personal Data which:
        1. 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;
        2. The User's Personal Data has been publicly known without violating the applicable law;
        3. Has become publicly known information, not due to violation by the Receiving Party or its Representative;
        4. User’s Personal Data is legally obtained by other parties without confidentiality restrictions from other sources;
        5. 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
        6. 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.
      2. 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:
        1. required or obtained by ALAMI from Users or submitted, disclosed, downloaded or submitted by Users through Platform or ALAMI resources;
        2. obtained and/or obtained from a third party with the consent of the User;
        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. 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.
    2. COLLECTED PERSONAL DATA
      1. ALAMI has the right to collect User Personal Data to provide services to Users, including but not limited to:
        1. Data or information that can personally identify an individual, including but not limited to name, address, phone number, email address, photo, transaction information, and other information required for the provision of services to Users and/or compliance aspects with the relevant authorities;
        2. Data or information provided to and received by ALAMI while Users access and engage in any activities on the ALAMI Platform, including but not limited to username, password, search history, transaction history for services conducted through the ALAMI Platform, received service history, participation history, interactive service history, responses to verification questions;
        3. Data or information received by ALAMI from third parties that have partnered with ALAMI to provide services to Users;
        4. Other data and/or information required by ALAMI to provide services to Users while adhering to applicable legal provisions.
      2. The above purposes remain the basis for ALAMI to carry out Processing User’s Personal Data regulated in this Privacy Policy, and to use it, submit it or disclose it in good faith to
        1. 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;
        2. 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;
        3. 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;
        4. 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
        5. parties that provide or propose to provide guarantees or third party guarantees to guarantee or maintain the obligations of the Financing Beneficiary.
      3. 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.
    3. Purpose
      1. By registering on the ALAMI Platform, User acknowledge and give consent to ALAMI to process the Personal Data provided by User for or related to ALAMI's operational activities and providing service access to User while adhering to applicable laws and regulations, including but not limited to ('Purposes'”):
        1. To manage the accuracy of the information that Users provide;
        2. 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;
        3. Fulfillment of ALAMI's rights and obligations based on legal provisions and statutory regulations, Membership Agreement, Authorization Agreement and/or Sharia Financing Agreement;
        4. Execution and supervision of the implementation of the Membership Agreement, Authorization Agreement and/or Financing Agreement;
        5. Implementation of ALAMI and/or ALAMI Group operational activities from time to time in good faith;
        6. 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;
        7. 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 ALAMI's official electronic communication media.
        8. Study the behavior of visitors and Users of Information Technology-Based Co-Funding Services; and
        9. Law enforcement and ALAMI's compliance with legal provisions and laws and regulations.
      2. The above purposes remain the basis for ALAMI to carry out Processing User’s Personal Data regulated in this Privacy Policy, and to use it, submit it or disclose it in good faith to
        1. 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;
        2. 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;
        3. 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;
        4. 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
        5. parties that provide or propose to provide guarantees or third party guarantees to guarantee or maintain the obligations of the Beneficiary; and/or
        6. Other parties that may support ALAMI's operational activities and the provision of service access to User while complying with applicable laws and regulations.
    4. Methods of Obtaining, Collection, and Storage of Personal Data.
      1. ALAMI users are committed to processing Personal Data in accordance with the principles of Personal Data Protection including
        1. Conducted in a limited and specific manner, legally valid and transparent;
        2. Done in accordance with the Purpose;
        3. Done by guaranteeing User rights;
        4. Accurate, complete, not misleading, up-to-date, and accountable;
        5. 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;
        6. Done by notifying the purposes and activities of the Processing, as well as the failure to protect the User's Personal Data;
        7. Destroyed and/or deleted based on the User's request or based on the applicable laws and regulations; and/or
        8. Conducted responsibly and can be proven clearly.
      2. 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.
      3. In providing Services on the ALAMI Platform and based on the access granted by the User, ALAMI will only access the camera, microphone, and location on the User's device to obtain the User's Personal Data.
      4. 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.
    5. Representations and Warranties
      1. Users hereby declare and guarantee that all information and User's Personal Data that is disclosed and submitted to ALAMI is true and accurate.
      2. 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.
      3. c. The User hereby declares and guarantees that they have obtained all necessary approvals from the relevant parties as mentioned in point 1 letter b of this Privacy Policy, in the event the User discloses, submits information, or Personal Data of the mentioned party for the purpose of utilizing ALAMI's services, allowing ALAMI to obtain, collect, process, store, and use the Personal Data for the Purposes as outlined in Article 3 of this Privacy Policy.
    6. ALAMI's Commitment to User's Personal Data
      1. ALAMI has implemented the ISO 27001:2013 standard as a commitment to protect and maintain the security of information and User Personal Data.
      2. ALAMI will only process User's Personal Data in accordance with the Purposes referred to in this Privacy Policy.
      3. If there are purposes and objectives other than those specified in this Privacy Policy, ALAMI will convey this explicitly, legally, has been determined, and will not process User's Personal Data except based on User's consent.
      4. 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.
      5. ALAMI carries out the Processing of User's Personal Data by complying with and complying with the applicable laws and regulations.
      6. ALAMI is committed to exerting utmost effort in addressing and resolving User complaints pertaining to issues or indications of violations of user rights related to information and/or User Personal Data. Complaints can be formally submitted through the designated Complaint Service as outlined in the Term Of Use.
    7. 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:
      1. ALAMI will not provide compensation, respond, and cannot be involved, along with employees, subsidiaries, affiliates, or representatives, for any claims, demands, requests, or statements arising from or related to Losses and Legal Issues filed without including a precise calculation that has been quantified, accurate, and accountable for the actual and direct losses that Users experience, along with evidence acceptable to the court or relevant judicial institution regarding the fault or negligence of ALAMI based on Articles 1865 and 1866 of the Civil Code, Article 164 of the Revised Indonesian Regulation, and Article 5 paragraph 1 of Law Number 11 of 2008 concerning Electronic Information and Transactions, along with its amendments from time to time; and
      2. 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
      3. ALAMI are not responsible for any legal violations by Users or any third-party rights arising from or related to the acquisition or provision of Personal Data. In the event of the appointment of a third party for Personal Data storage, Users cannot demand, claim compensation, or any benefits from ALAMI, including employees, agents, representatives, affiliates, or related parties of ALAMI in the case of a breach of confidentiality or failure to protect the confidentiality of Personal Data or Losses and Legal Issues involving, caused, or committed by the third party storing the respective Personal Data or any events beyond ALAMI's reasonable control, including but not limited to computer hacking, unauthorized access to computer and storage devices, computer crashes, security and encryption breaches, poor quality of Internet or telephone services from you, and others. However, ALAMI will still reasonably attempt to notify Users of such confidentiality breaches when ALAMI becomes aware of them from the third party.
    8. User's Right of User's Personal Data
      1. 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.
      2. Users can access and obtain a copy of their own User's Personal Data.
      3. In the event that the User wants termination or cancellation as an ALAMI Platform User, then;
        1. Users can apply for termination of processing, delete and/or destroy User's Personal Data to ALAMI; and/or
        2. the User submits a request to withdraw the consent to process the User's Personal Data that has been submitted to ALAMI.
      4. 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.
      5. 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.
      6. 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:
        1. 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;
        2. 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;
        3. The Consumer Service Team provides information to the User regarding whether or not the application is approved after verification;
        4. 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
        5. the Consumer Service Team will immediately convey to the User the results of the implementation of the User's request.
      7. 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.
    9. USER RESPONSIBILITY FOR USER PERSONAL DATA
      1. Information such as the username, password, PIN, and OTP will be required for login, user device activation, and execution of any transactions deemed necessary by ALAMI for authentication purposes. Users must ensure the specification, establishment, and use of strong and unpredictable passwords and PIN, such as avoiding using easily guessable information like birth dates and addresses. The use of passwords and PIN as mentioned above will be considered as negligence on the part of the User, who will be fully responsible for the security and confidentiality of all uses of the ALAMI Platform.
      2. Users are entirely responsible for the confidentiality and security of their information and User Personal Data, as this information holds the same validity as written instructions signed by the User and will be treated as explicit authorization by the User for ALAMI to conduct transactions through the ALAMI Platform.
      3. Users are advised not to disclose their information and User Personal Data to any other parties. Users guarantee and indemnify ALAMI from any claims, liabilities, demands, and lawsuits from any party (including the User themselves). Furthermore, Users are responsible for the risks and/or losses arising from the unauthorized or illegal use of the User's account on the ALAMI Platform, username, OTP, PIN, and/or password by other parties.
      4. Users must promptly inform ALAMI if they suspect or indicate any unauthorized or illegal misuse of access to the User's account on the ALAMI Platform by other parties.
    10. Privacy Policy Changes
      ALAMI may make changes or updates to the User's Agreement to the Privacy Policy on this page from time to time and if such changes or updates are required, they will be notified by e-mail and/or by other means to the User. Furthermore, the User is considered to have agreed in the event that there is no objection and/or written rejection of the intended change no later than 3 x 24 hours from the submission of the intended change and/or update.
This Privacy Policy was last amended or updated on 15th July 2024