1. Brief Overview
- KreditPro is committed to protecting and respecting your privacy.
- This Privacy Policy applies to all individuals and entities accessing this website. By accessing and/or using the services available through the site, you acknowledge that you have read and agree to the terms of this Privacy Policy (along with the Terms of Use), our Cookie Policy, and any other documents referred to herein.
- This Privacy Policy (along with our Terms of Use, Cookie Policy, and any other documents referred to in this Privacy Policy) is designed to help you understand how we collect, use, disclose, and/or process the Personal Data you have provided to us, and to assist you in making informed decisions before providing your Personal Data to us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
2. Definitions
- "KreditPro" means the same as defined in the Terms of Use.
- "Cookie Policy" refers to the cookie policy owned by KreditPro Site.
- "Interactive Services" means the same as defined in the Terms of Use.
- "Personal Data" means information or data that can be used directly or indirectly to identify an individual who is a natural person.
- "Products" means the same as defined in the Terms of Use.
- "Selected Third Parties" refers to the third parties specified in Article 4.5 below.
- "Services" means the same as defined in the Terms of Use.
- "Site" means the same as defined in the Terms of Use.
- "Site Content" means the same as defined in the Terms of Use.
- "Terms of Use" refers to the Terms of Use on this website.
- "Third Party Content" means the same as defined in the Terms of Use.
- "Third-Party Sites" means the same as defined in the Terms of Use.
- "Users" means the same as defined in the Terms of Use.
- "We" and "Our" means the same as defined in the Terms of Use.
- "You" and "Your" means the same as defined in the Terms of Use.
3. Information Collection
- From time to time, KreditPro may collect information and data about you, including information and data:
- provided by you or anyone authorized by you;
- related to any of your visits to our Site; and
- from other third parties authorized by you and publicly available sources, including credit rating agencies or bureaus.
- Through you, KreditPro may also collect information and data about family members, friends, beneficiaries, attorneys, shareholders, beneficial owners, attorneys-in-fact, guardians, trustees, your guarantors, other providers of guarantees, and other individuals (collectively, all such individuals referred to as "Relevant Individuals").
- In this regard, KreditPro may collect the following information and data as stated in sections 3.1 and 3.2:
- Any information or data about you and/or the Relevant Individuals that can identify you or the Relevant Individuals, including but not limited to name, date of birth, ID card, passport or other identification numbers or details, address, email address, telephone number, contact details, financial and credit card information, personal description, and photo, information on product and service portfolios, transaction patterns and behaviors, financial background, funding history, educational background, and population data;
- Any information and data about you and/or the Relevant Individuals generated and/or provided to us during your access to our Site and any activities performed on our Site. For example, your registered username for the Site, search results and history for Products and Services on our Site, transaction records for Services and Products provided through our Site, records of participation in any Interactive Services on our site, and your responses to security verification questions;
- Any information and data about you and the Relevant Individuals received during the course of maintaining the relationship between us and you, including account review reports and correspondence records with you via telephone or email;
- Any information and data about you collected in connection with any of your visits to our Site, including:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- site visit information, including all Uniform Resources Locators (URLs) clickstream to, through, and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, information about page interaction (such as scrolling, clicks, and mouse-overs), and methods used to exit the page and any phone number used to call our customer service number; and
- information and data from cookies or other technologies used on our Site. For more information about cookies and these technologies and their purposes, see our Cookie Policy.
- Any information and data about you collected by us when you participate in events we organize, such as parties, seminars, contests, or awards programs, which may include your photos, video recordings, and voice;
- Any information and data about you that we receive when you use any other website operated by us, our affiliates, and subsidiaries, or other services provided by us, our affiliates, and subsidiaries. In such cases, we will notify you and obtain your consent for the collection of information or data about you with the relevant Privacy Policy contained in the other website operated by us.
- Any information and data about you that we receive from Selected Third Parties (as defined in Article [4.5] below);
- The information and data about you and the Relevant Individuals mentioned in sections [3.3] above collectively constitute Personal Data.
4. Use and Disclosure of Personal Data
- When deemed necessary and appropriate by KreditPro and in accordance with applicable laws, rules, and regulations, Personal Data may be used and disclosed by KreditPro and/or KreditPro for the following purposes:
- to provide access to you and facilitate the use of our Site and ensure that Site Content, Products, Services, Interactive Services, Third-Party Content, and Third-Party Sites are displayed in the most effective manner for you and your devices;
- to provide you with the information, Site Content, Products, Services, and Interactive Services you request from us and access to Third-Party Sites and Third-Party Content;
- to perform our obligations arising from any contracts entered into between you and us;
- to provide you with information about other Products and Services we offer that are similar to the Products and Services you have purchased or inquired about;
- to provide you, or allow Selected Third Parties to provide you, with information about Products or Services that we believe may be of interest to you. If you are already a User, we will only contact you via email, SMS, or phone to provide information about Products and Services similar to those you have previously considered, funded, or used. If you are a new customer, and if you agree to disclose your Personal Data to Selected Third Parties, we (or Selected Third Parties) may contact you via email or SMS to provide information about Products or Services;
- to notify you about changes to our Site, Site Content, Products, Services, Interactive Services, Third-Party Content, and Third-Party Sites;
- to manage our Site and for its internal operations, including troubleshooting, data analysis, testing, research, statistical purposes, and surveys;
- to enhance our Site to ensure that Site Content, Products, Services, Interactive Services, Third-Party Content, and Third-Party Sites are delivered in the most effective manner for you and your devices;
- to enable you to participate in Interactive Services and other interactive features of our Site, if you choose to do so;
- to implement and review security measures on our Site to keep it safe and secure;
- to assess or understand the effectiveness of our advertisements and third-party advertisements on our Site and other third-party websites and to deliver relevant advertisements to you;
- to make suggestions and recommendations to you and other Users of our Site about Products, Services, or third-party products and services that may interest you or them;
- to make decisions related to the opening or continuation of User account(s) and the creation, provision, or continuation of Service(s) and Product(s), as well as to maintain the accuracy of your "Know Your Customer" information and conduct anti-money laundering, credit, and background checks;
- to provide, operate, process, and manage User account(s), Service(s), and Product(s) or manage applications for User account(s), Service(s), and Product(s), any transactions (including money transfers), and maintain service quality and train staff;
- to conduct activities related to the provision of User account(s), Service(s), and Product(s), including subscriptions or proposed subscriptions to Products or Services (whether offered or issued by KreditPro or others) and the provision of research reports or materials for analysis;
- to provide services and support related to Products, including but not limited to administrative or management support or acting as nominee or agent in connection with your participation in Products;
- to provide or grant access to materials related to Products, such as offering documents, research reports, product profiles, term sheets, or other materials related to products;
- to comply with legal, regulatory, and compliance obligations at home and abroad applicable to KreditPro and KreditPro under applicable laws (including anti-money laundering and tax obligations applicable to KreditPro and KreditPro, and disclosures to any stock exchange, court, government authority, regulatory authority, or other regulator as per the guidelines, regulations, orders, instructions, or relevant requests from these organizations) and to comply with any applicable international or intergovernmental agreements or agreements with foreign and domestic governments applicable to KreditPro and KreditPro;
- to verify the identity and/or authority of your representatives contacting KreditPro or KreditPro or who can be contacted by KreditPro or KreditPro and to implement or respond to requests, inquiries, or instructions from verified representatives or other parties according to our applicable security procedures;
- to perform risk assessments, statistical analyses, and planning, including conducting data processing, statistical, credit, risk, and anti-money laundering analyses, creating and managing credit assessment models, conducting other credit and background checks, and storing your and your valid representatives' credit history (regardless of whether there is a direct relationship between such valid representatives and KreditPro or KreditPro or not) for current and future reference;
- to monitor and record calls and electronic communications with you for record-keeping, quality, training, investigation, and fraud prevention purposes;
- to detect, prevent, investigate, and prosecute crimes and fraud, including assisting in any criminal investigation by relevant authorities against you, Relevant Individuals, or others;
- to enforce (including, but not limited to, collecting amounts owed to KreditPro and/or KreditPro) or defend the rights of KreditPro or KreditPro arising from contracts or otherwise;
- to conduct internal management for operating control and management information systems and conduct internal or permit external audits;
- to enable the actual or potential assignees of KreditPro, or participants or sub-participants of the rights of KreditPro in relation to you, to evaluate the intended transaction to be the object of assignment, participation, or sub-participation;
- to comply with any obligations, requirements, policies, procedures, assessments, or arrangements for sharing data and information within KreditPro or KreditPro and the use of other data and information in accordance with any KreditPro program for sanction compliance or the prevention or detection of money laundering, terrorist financing, or other unlawful activities.
- We may combine any information and data, regardless of how it was provided to us or collected by us, and use the combined information or data for the purposes specified in section [4.1] above.
- We may also use and disclose Personal Data for other purposes related to any of the above as specified in sections 4.1 and 4.2, which are considered appropriate in the circumstances.
- As the purposes for which we may collect, use, disclose, or process your Personal Data depend on the circumstances at the time, these purposes may not appear in the above sections. However, we will notify you of these other purposes when requesting your consent for the collection of such Personal Data, except where processing of your Personal Data without your consent is permitted by law.
- We may also share Personal Data with Selected Third Parties, including:
5. Personal Data and Credit Reference Agencies
- KreditPro or KreditPro may, on its own and/or as your agent, provide relevant information and data about you and the Relevant Individuals to credit reference agencies for the purpose of updating your credit records in the credit customer database of those agencies. In this case, the relevant information and data about you and the Relevant Individuals will be related to the Products and/or Services held or used by you and the Relevant Individuals (whether as borrowers, mortgagors, guarantors, or providers of guarantees, and whether in your and the Relevant Individuals' own name or jointly with others) and this information and data will include:
- full name;
- capacity in relation to the Product (as a borrower, mortgagor, guarantor, or provider of guarantees, and whether in your own name or jointly with others);
- identification number (e.g., identity card number, passport, or national ID);
- date of birth;
- correspondence address;
- account or reference number relating to each Product;
- type of Product(s) held and/or used;
- account status (e.g., active, closed, removed (except due to bankruptcy), removed due to bankruptcy);
- payment trends and status (e.g., payments made in full or in part, current or at the end of the period);
- account closing date, if any, relating to each Product;
- date of usage of the Product; and
- general information about the account and information on any material default, if any, related to the material default.
- For the purpose of determining your credit risk when you apply for any Product or Service, KreditPro or KreditPro may access and obtain from credit reference agencies personal information and account or record information about you and the Relevant Individuals (including information about the amount calculations of facilities/loans) held by any credit reference agency in any relevant jurisdiction.
- KreditPro or KreditPro and the Relevant Individuals from time to time may also access personal information and account or record information about you and the Relevant Individuals (including information about the calculations of the mortgages) held by credit reference agencies for the purpose of reviewing any one of the following in relation to existing Products provided to you or third parties whose obligations are guaranteed by you:
- an increase in credit amount;
- credit tightening (including cancellation of credit or reduction of credit amount);
- provision of additional Products; or
- placement or implementation of arrangements relating to you or any third party whose obligations are guaranteed by you.
- KreditPro or KreditPro may also obtain credit reports about you from credit reference agencies in considering any application from you to register and upload a Product on our Site for subscription. In this case, if you wish to access such credit report about you, KreditPro will provide you with the contact details of the relevant credit reference agency to obtain the report independently.
6. Administration and Management of Your Personal Data
- We will make reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by KreditPro to make decisions that affect you, or disclosed to another organization. However, this means that you must also inform us of any changes to your Personal Data that you initially provided to us. We will not be responsible for relying on inaccurate and incomplete Personal Data that is caused by your failure to inform us of any changes to your Personal Data that you initially provided to us.
- We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secure. Appropriate security arrangements will be taken to prevent unauthorized access, collection, use, disclosure, copying, alteration, leakage, loss, damage, and/or alteration of your Personal Data. However, we do not assume any responsibility for any unauthorized use of your Personal Data by third parties that is wholly attributable to factors beyond our control.
- We will also put in place measures to ensure that your Personal Data under our control or in our possession is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which the Personal Data was collected is no longer being served by the retention of the Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
- If your Personal Data is to be transferred out of any country in which you access this Site, we will comply with applicable laws in doing so.
7. Right to Refuse the Use of Personal Data for Marketing Purposes
You have the right to request us not to process your Personal Data for marketing purposes. We will inform you and seek your consent before using your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can exercise your right to refuse such processing by indicating on the relevant form we use to collect your data. Even after you have given your consent for the Personal Data to be used for marketing purposes, you may, at any time after that, withdraw your consent by contacting us at support@KreditPro.id.
8. Links to Other Sites
Our Site may, from time to time, contain links to Third-Party Sites and websites of our network partners, advertisers, affiliates, or subsidiaries. If you follow a link to any of these websites, please note that these websites may or may not have their own privacy policies, and we do not accept any responsibility or liability for these policies or the absence of these policies. Please check these policies before you submit any information, including your Personal Data, to these websites.
9. Access to Information
- You have the right to request from us the Personal Data about you held by KreditPro. If you wish to access, update, or change or delete any information you provided to us, contact us at [EMAIL ADDRESS] for assistance. Any access request may be subject to a fee of [amount charged] to cover our costs in providing details of the information we hold about you to you.
- In exceptional circumstances, KreditPro may refuse your access to your Personal Data but we will provide you with an explanation of the reasons preventing us from doing so based on applicable law. Such exceptional circumstances include but are not limited to when:
- Authorities conducting investigations or government bodies object to KreditPro's compliance with customer requests;
- The information can, in the exercise of KreditPro's reasonable authority and/or judgment, affect the life or security of an individual; and
- Data is collected in relation to an investigation into contract breaches, suspicion of fraudulent activities, or violations of the law.
10. Changes to Our Privacy Policy
Any changes we make to our Privacy Policy in the future will be posted on this page and, if necessary, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
11. Minors
KreditPro cannot distinguish the age of individuals accessing and using its website. If an individual under the age of minority (as determined by applicable law) has provided their Personal Data to KreditPro without the consent of their parent or guardian, that parent or guardian should contact KreditPro to delete the relevant Personal Data and remove the name of the underage individual from its customer list.
12. Acknowledgment
- You acknowledge that if you do not provide the relevant information or data or withdraw consent in relation to the collection, use, and/or disclosure of the relevant information or data as described in the Privacy Policy, KreditPro may not be able to open or continue your User account, or create or provide or continue any Products and Services, or continue to permit you to use or access our Site, Site Content, Products, Services, or Interactive Services. KreditPro or KreditPro will inform you of the consequences of such withdrawal if you notify us of your desire to withdraw your consent.
- You warrant to KreditPro and KreditPro that if you or your agent are responsible for providing any information or data relating to anyone to KreditPro and KreditPro, or providing such information or data to KreditPro and KreditPro, you have notified and obtained the consent of the relevant individual(s) to allow KreditPro and/or KreditPro to collect, use, and/or disclose information relating to the relevant individual(s) as described in this Privacy Policy.
- You agree that you have obtained consent from all the Relevant Individuals so that any information or data of the Relevant Individuals can be processed, stored, transferred, or disclosed in and to any country as deemed by KreditPro and KreditPro to comply with the laws applicable for the Permitted Purpose. The data can also be processed, stored, transferred, or disclosed in accordance with local laws and practices, regulations, and regulations (including any requests based on government regulations, actions, and orders) in that country/jurisdiction.
- In accordance with the Terms of Use, Cookie Policy, and [Parent Agreement], you agree that KreditPro may change and modify the provisions of this Privacy Policy from time to time and subject to notification to you of the amended Privacy Policy, the contents of it will likewise amend, diversity, and supplement the Terms of Use, Cookie Policy, and [Parent Agreement], those agreements and/or arrangements set out above will apply from the date specified in the amended Privacy Policy, and without prejudice to the foregoing, your access/use or continued access/use of the Site, Site Content, Products, Services, Interactive Services after such change shall also be deemed as your acceptance and agreement on those matters.
13. Contact
Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to the KreditPro Data Protection Officer at the email address support@KreditPro.id.