- PT ALAMI Fintek Sharia ("ALAMI") is a Company which provides, manages, and operates an Information Technology-Based Lending Services (LPMUBTI) with sharia principles based on Indonesian Financial Services Authority (OJK) Regulation No. 77/POJK.01/2016 regarding Information Technology-Based Lending Services (“POJK 77”) and the Fatwa of National Sharia Board – Indonesian Council of Ulama No. 117/DSN-MUI/II/2018 (“Fatwa 117”)
- 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.
- 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 given access by ALAMI through a Platform owned by ALAMI.
- 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 p2p.alamisharia.co.id and its changes of web address from time to time, and/or mobile application from p2p.alamisharia.co.id which is created, owned, and operated by ALAMI, including its iOS and Android version, as well as its changes from time to time.
- “Customer Services Team” means ALAMI internal team whose task to provide services to ALAMI Platform Users related to Users’ Private Information management.
- 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,
- Private Information that has been known by the general public, without offending any legal constitution in effect,
- Private Information that has become Public Information, and not as a result of any violation of Receiving Parties or its Representatives,
- Private Information obtained legally from other parties without being bound by non-disclosure clauses with other parties.
- 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
- 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.
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:
- required or received by ALAMI from Users atau or given, disclosed, uploaded or proposed by Users through ALAMI Platform or ALAMI resources;
- received and/or obtained from third parties with the consent of Users;
- 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;
- 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.
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:
- Manage the accuracy of information provided by Users;
- Manage User registration, and to manage, verify, deactivate, or manage User accounts.
- Offer and provide Users with ALAMI features or services through the ALAMI Platform.
- 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.
- 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.
- Implementation, management and supervision of the agreements that Users have signed through the NATURAL Platform, including, among others, Membership Agreements, Authorization Agreements and / or Financing Agreements.
- Implementation, maintenance and provision of ALAMI operational activities from time to time.
- Survey, research, evaluation, market research, product development and / or improvement, promotion, updating of features, uses, products and / or services provided by ALAMI or related interested parties.
- Checking, responding to, resolving and conducting supervision or monitoring of questions, problems, comments or complaints submitted by Users to the Customer Service Team.
- 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.
- Understand, study and analyze data, usage patterns or behavior of visitors and users in relation to the needs and preferences for providing ALAMI Platforms.
- 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).
- Internal administrative processes such as auditing and taxation.
- Any other purposes that we notify to you at the time of getting your consent.
(Taken together, these are the “ Goals ”).
- 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;
- 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.
- 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, professional consultants, internal, external auditors and partners Similar service providers are in charge of the confidentiality of User Personal Data
- 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 NATURAL or as required by laws and regulations, directions, instructions or institutional policies government, government officials or law enforcement agencies.
- 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.
- parties that provide or propose to provide guarantees or third party guarantees to guarantee or maintain the obligations of the Financing Beneficiary.
- Users hereby represent and warrant that all information and Personal Data disclosed and submitted to ALAMI are true and accurate.
ALAMI 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 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 or ALAMI's employees, representatives, attorneys, affiliates or other related parties ("Losses and Legal Matters"). For the sake of clarity, legal certainty and transparency:
- ALAMI 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 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;
- 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 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 or ALAMI's 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's 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.
- 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.
- 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.
- 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.
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:
- 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;
- 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;
- The Consumer Service Team provides information to the User regarding whether or not the application is approved after verification;
- 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
- The Consumer Service Team will notify Users regarding changes, additions, updates, or deletions of Personal Data that have been made.
- 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 has the right to obtain, collect and store Personal Data (encrypted) from and / or through the NATURAL Platform, telephone, obtained from NATURAL 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 NATURAL, or accessed by NATURAL or submitted by Users through or obtained from systems, hardware (hardware), software (software) or equipment (devices) that NATURAL or Users use or are involved in using NATURAL Services or NATURAL Platform.