TERMS AND CONDITIONS FOR THE DANA USERS

In using the electronic money service of DANA, the Users agree to bind themselves and comply with the “Terms and Conditions for DANA Users” as follows:

I. DEFINITION

1. DANA shall mean the service mark of server-based electronic money service created by:

PT Espay Debit Indonesia Koe (DANA,www.dana.id) the authorised licensee of DANA mark already obtaining permit from Bank Indonesia (no. 18/262/DKSP/Srt/B dated February 29th, 2016) to operate server-based electronic money services.

2. DANA Account shall mean electronic money account opened by the Users which is saved in the DANA electronic server.

3. Escrow Account is collection account of fund with partner bank registered in DANA.

4. Electronic Money shall mean the value of money registered and saved in the server/DANA account. The fund of electronic money shall be collected in the Escrow Account and can be used by the Users to do any transaction using DANA social-banking application.

5. Merchant shall mean any parties either those of institution, company or individual serving the transaction using the DANA account in DANA application.

6. Handphone Number (HP) shall mean cellular/smartphone number in use by the Users to access the DANA service in in DANA social-banking application.

7. User shall mean the user of DANA and owner of DANA account.

8. Telecommunication Device (Device) shall mean smartphone, handset, PC tablet, or any other telecommunication device which technology supports the DANA service and using the Operating System (OS) of Android and IOS including any other operating system that shall be existing in the future which is possible for the Users to be able to use the DANA services.

9. PIN (Personal Identification Number) shall mean personal identification number for the Users to do the transaction in DANA.

10. Transaction shall mean transaction that can be made by the Users through the DANA service, among others Pay Friends*, Ask for Money*, Payment Transaction, purchase of pulsa, payment of bills, transfer of money and any other transaction that shall be developed in the future. * Pay Friends and Ask Money Services will follow.

11. Top-up Transaction shall mean balance top up transaction into the DANA account.

12. Payment Transaction shall mean goods and/or services payment transaction in Merchant using the DANA application.

13. Customer Service (CS) shall mean operation team performed by employee of DANA in giving service support via email and/or phone.

14. Deactivation shall mean the temporary DANA account closing process. We will provide the ability later.

15. Agent shall mean any third party cooperating with the DANA and acting on behalf of DANA in giving DANA services.

16. PIN shall mean collection of characters used by the DANA application users to support their identity verification to the security system.

II. GENERAL CONDITIONS

1. DANA is a mobile based electronic money services that can be used by the User through their Handphone.

2. All Users with Handphone number from any operator either postpaid or prepaid can be the DANA Users.

3. All Users being the customers of partner bank can be the DANA Users.

4. All Users that have not yet become the customer of partner bank (non-Bank User) can also become the DANA User. The Top-up process for the non-Bank User can be made through cash payment in the store of payment agent of DANA or Virtual Account Payment with Bank service.

5. The Users shall, to access the DANA services, download and install the BBM application in their Handphone and then make activation through the said DANA application which should be located in Discovery Tab in BBM APP.

6. Every Handphone number can only be used for 1 (one) DANA account.

7. DANA Service consists of 2 (two) types namely Registered type (namely with nominal value limit of balance until Rp10.000.000) and Unregistered type (namely with nominal value limit of balance until Rp1.000.000) according to regulation of Bank Indonesia.

8. User may make any Transaction if the electronic money balance existing in the DANA account is sufficient.

9. Maximum limit of transaction in 1 (one) calendar month is Rp20.000.000 (twenty million rupiah).

10. The following points shall be fulfilled to be able to use the DANA Services:

1. Handphone Number must be active (not blocked)

2. data network and sufficient pulsa (for pre-paid customers) or sufficient credit limit (for post-paid customers).

11. User and PIN:

1. PIN (Personal Identification Number) shall be needed to make any Transaction as validity or verification that the Transaction is really made by the User.

2. PIN can be changed by the User through DANA application.

3. For resetting of PIN, the User shall be guided in DANA contact the DANA Customer Service team.

4. User shall keep confidential the PIN and shall be fully responsible for the security of PIN.

5. Unless stipulated otherwise, PIN can be change with any other authentication method or facilities that are provided by DANA or any other party cooperating with the DANA and the said authentication method or facility are already approved by DANA.

III. ACTIVATION OF DANA

The Users of DANA may open the first DANA account by way of:

1. Downloading the BBM application directly through Handphone they own as available at Google Play store (for Android) and Apple-App Store (for iOS), and then:

a. After installation of BBM application, the User may make activation process through DANA application located in the Discovery tab by following the direction and providing information, among others:

i. Account Name of User;

ii. PIN (6 digits) which is determined by the User;

b. After successful activation process, the User may access the DANA services.

IV. TRANSACTION WITH DANA

The DANA Users may make the following transaction:

1. Top up = topping up the balance of DANA account

2. Purchase or reloading pulsa

3. Payment of bills

4. Shopping in merchant or purchasing goods/services

5. Checking balance and history of financial transaction to a maximum of the last 180 days.

V. TOP-UP TRANSACTION

Top-up/electronic money payment shall mean the process of adding the balance into the DANA electronic money.

There are some method for Top-up namely as follows:

a) Via

Top-up via ATM shall mean process of adding the balance into the DANA electronic money through ATM machine.

Top-up via ATM can be made by the same method as you do the inter-bank transfer. The difference is that the account number of destination is your own Handphone number which is already registered as DANA electronic money in DANA application.

Top-up via ATM can be made in the same method as the interbank transfer via ATM, for example:

1. insert your ATM card into the ATM machine

2. Select the menu of “Transfer”

3. Select the menu of “Transfer to the other Bank”

4. Insert DANA Code of “8206” in BNI and your Handphone number (10-12 number) for example: 8206 081212345678

Note:

a. 8206 = DANA Code in BNI bank

b. 081212345678 = your Handphone number

5. Choose the amount of rupiah that you want to transfer, for example 50.000. Click “yes/Ok”

Fee :

Switching fee = Rp6.500 +

Administration fee = 0 (Currently DANA should provide the promotion to user and don’t charge any admin fee but it may be changed in the future)

FOR EXAMPLE : The User A wants to top up of Rp50.000 from bank Mandiri. DANA User A shall add of Rp50.000. The balance of bank Mandiri of User A will be decreasing of Rp56.500, with breakdown as follows: top up of Rp50.000 + Administration fee of Rp0 + ATM Switching fee of Rp6.500.

NOTE :

Switching fee = FREE if the User makes top up process using ATM card of Bank Permata in ATM belonging to Bank Permata

b) via internet Banking

Top-up via Internet Banking shall be the process of adding balance into your DANA electronic money using the internet banking user ID/Password/Token that you own in the partner bank.

The requirement for Top-up via Internet Banking is that your account with partner bank is registered as internet banking user ID.

In some banks for example BCA, there shall be required the special registration to be able to do the Top-up process via BCA klikpay. You can contact the nearest BCA Customer Service or make online registration in www.klikbca.com

NOTE:

According to the banking regulation that DANA does not save the data of userID/password/token either temporarily or permanently in the system owned by PT EDIK. The validation process shall be made directly by the banking by way of redirecting the SCREEN of internet Banking belonging to the Partner Bank to the screen of DANA social-banking application.

Top-up via Internet Banking can be made using the following step:

1. Insert your “Partner Bank”, where your account number is registered as internet banking user.

2. Select Bank Channel (usually internet banking IB)

3. Insert total amount of Rupiah that you want to top up to your DANA electronic money.

4. click the “Process”

5. Insert the userID/password/token asked by the partner bank.

NOTE:

a. At this step, the transaction process is already taken over by the banking system. DANA application will obtain the transaction status of “Successful” or “Failed” from the partner Bank. If the transfer from your account with the partner bank to the collection account belonging to DANA is successful, then the Partner Bank shall send the status of “Successful” to DANA application in real-time and online basis. If the transfer process has failed due to technical reason or your balance is not sufficient then the Partner Bank shall send the status of “Failed”

b. If the transfer is successful (your balance with the partner bank will be decreased) but your balance in the DANA electronic money has not yet increased, then you may contact us. The Customer Service contact number is available at Contact Us on the website.

Fee:

See the table of administration fee (page 7)

a) Via SMS Banking

Top-up via SMS Banking is the process of adding the balance into your DANA electronic money using the facility of SMS Banking that you own in the partner bank.

As requirement for Top-up via SMS Banking is your account with the partner bank is registered as:

a. Customer of SMS Banking (details, please contact Customer Service with Partner Bank)

b. your SMS Banking is registered with the status of “FINANCIAL” (for certain partner bank, requiring that the special registration for SMS banking can be used to transact or only check balance, for example in Bank Mandiri, the details can contact Customer Service with Partner Bank)

c. your SMS Banking Number is registered in DANA Social-banking application (click: Setting > Registered SMS Banking)

Top-up via SMS Banking can be made by following these steps:

1. Insert your “Partner Bank), where your account number is registered as SMS Banking (financial)

2. Select Bank Channel (usually SMS Banking)

3. Insert the total amount of Rupiah that you want to top-up into your DANA electronic money.

4. Partner Bank shall send the Token via SMS

5. Insert the Token that you receive via SMS into the available menu

Fee.

See table of administration fee (page 7)

NOTE :

Telco Operator shall charge the token delivery fee via SMS. The fee shall be determined directly by the Telco Operator

The followings are table of administration fee for Top-up:

No.

Bank Name

Top up

Fee

1

All Banks

ATM

Rp0*

2

Bank BCA

Internet Banking, SMS Banking

Rp0*

3

Bank BNI

Internet Banking, SMS Banking

Rp0*

4

Other Bank

Internet Banking

Rp0*

*Note: Administration fee above shall be subject to change at anytime without prior notice to the user

VI. BALANCE IN DANA ACCOUNT

1. The electronic money balance saved in the DANA account:

a) shall not obtain interest in any form whatsoever due to not constituting savings as referred to in Law regarding Banking and Law regarding Sharia Banking;


and

b) shall not be guaranteed by the Deposit Insurance Corporation as set out in Law regarding Deposit Insurance Corporation.

2. User may check the balance DANA electronic money balance through the DANA application or through any other facilities including the facility provided by the third party connected with the DANA service.

VII. WITHDRAW BANK TRANSFER

Withdraw is a Feature of tcashing out DANA Balance to Bank Account registered by DANA User insofar the bank is listed in DANA Application.

The amount of withdraw balance is determined by DANA User with condition : minimum amount is Rp50.000 and maximum amount Rp1.000.000 per day.

DANA is not responsible for error of inputting bank information registered by the DANA User insofar DANA can identify that the account number and the bank is correct.

Withdraw bank account fee will be charged to the DANA User and it will be deducted from DANA Balance when withdraw is processed.

DANA User can check the status of twithdraw transaction inside DANA Application.

DANA will refund back if the withdraw fails.

DANA is not responsible if there's an issue on the bank side and the bank cannot process the withdraw DANA Balance if DANA already successfully send the transfer instruction.

DANA user can contact Customer Service if there's any issue with Withdraw Bank Transfer.

DANA will attempt to resolve the issue from DANA User

VIII. PURCHASE OF RELOADING PULSE AND PAYMENT OF BILLS

1. Purchase of reloading pulsa as telecommunication operator pulsa or others can be made through DANA application with the available denomination or according to direction shown in the DANA application.

2. Payment of post-paid or monthly bills such as cellular operator bills, Telkom PSTN, and others, can be made through DANA application.

3. Transaction of purchase and payment which is successful can be seen in the history of financial transaction as available at DANA application.

IX. SHOPPING IN MERCHANT OR PURCHASE OF GOODS/SERVICES

1. User can make payment transaction for shopping in merchant or purchase of goods/services using the facilities as provided in the DANA application including any other facility belonging to the third party (DANA partner) connected with the DANA service in the future.

2. User may know the information regarding the current merchants receiving payment with DANA together with any other interesting promos through DANA application or through any other facilities to be developed in the future.

X. TERM OF DANA

The DANA account belonging to the User will always be valid as long as the account is closed permanently.

XI. DANA SERVICE FEES

The fees as shown in the following table shall be the fees that will be deducted directly from your DANA balance in relation to the service of DANA which is currently valid:

No.

Type of Service

Fee (Rp)

1

Activation of DANA for the User of the First Time

FREE

2

Upgrade registration in the gallery/office of DANA*

FREE

3

Top-up/reload the DANA balance through transfer bank*

Article 5

4

Top-up the DANA balance through gallery/office of DANA

FREE

5

Check the DANA balance

FREE

6

Download or email of financial transaction history* (in the future)

FREE

7

Purchase of reload using the DANA balance

FREE

8

Payment of post-paid bills/monthly bills using the DANA balance

FREE

9

Shopping in merchant or purchase of goods/services using the DANA balance

FREE

10

Transferring money to co-User or non-User of DANA * (in the future)

FREE

11

Cash-out in the office/branch/gallery of DANA*(in the future)

FREE

12

Top-up and Cash-out*(in the future) through Agent

According to Agent Fee

The fees or facilities provided by the DANA as shown in the table above shall be subject to change at any time and the change thereof will be informed to communication media which is determined by DANA.

XII. BLOCKING OF DANA ACCOUNT

1. DANA account can be block

i. if the User inserts the wrong PIN and or Password for 4 (four) times consecutively;

ii. if so asked by the User;

iii. unilaterally by DANA due to a certain thing or reason either with or without prior notice to the User.

2. in relation to part 1 item iv) above, DANA shall be entitled to block the DANA account belonging to the User unilaterally either with or without prior notice:

i. at the request of state authority or authorised law enforcement authority; or

ii. if the User commits violation against the Terms and Conditions of the DANA User; or

iii. if the User gives information which is incorrect or misleading upon Registration of DANA; or

iv. if there is indication of misuse of DANA for unlawful activity.

3. DANA account which is blocked:

i. due to anything as shown in part 1 item i) ii) iii) above, the account is unable to make financial transaction but it can still receive fund (including Top-UP) and can be re-activated; or

ii. due to anything as contained in the part 1 item iv) above, the account cannot make financial transaction whatsoever including receiving fund (top-up) and can only be re-activated according to the policy of DANA.

4. the re-activation of blocked account to activate again the DANA account caused by the reasons as referred to in part 1 item i) ii) iii) above can be made by the User in adherence to the following conditions:

i. the DANA account has not/has not yet been blocked permanently;

ii. the User changes the DANA PIN through DANA application and following the direction as shown in the DANA application.

iii. If the process of change of DANA PIN is already successful, then the DANA service shall become active again.

iv. If the User encounters any constraint in the process of change of DANA PIN, the User is suggested to contact the Customer Service of DANA or email to help@dana.id but the approval for the re-activation of the blocked account shall remain becoming the authority of DANA.

XIII. INFORMATION & COMPLAINT

1. the User may raise question around the DANA service or complaint or dispute over the Transaction by contacting the Customer Service of DANA at 1500445 or through email to help@dana.id.

2. The user can also see the information regarding User of DANA service together with the current promotions directly in the DANA application or DANA website at www.dana.id

XIV. LIMIT OF RESPONSIBILITY

1. To avoid any misuse of User data, the User shall remember and keep confidential the information of User data it holds (among others but without limitation to HP number in use, answer of secret question registered for use of change of DANA, PIN or any other data which is given by the User/received by the relevant User for performance of Transaction) or any activity/Transaction made/performed by the User and not disclosing it to any party whomsoever. The User shall be fully responsible for any consequence and risk arising from the negligence of User in keeping confidential the information of account data it holds.

2. The User shall prevent the HP number and alternative HP number that it holds from among others loss/damage; prevent the HP number it holds from being misused by the other party/falsified. The user hereby acknowledges and agrees that DANA cannot be asked for accountability by the User and or any party whomsoever for anything occurring beyond the mistake and or negligence of DANA, including but without limitation to:

i. loss or damage of handphone, or HP number;

ii. Any loss as the result of the DANA User which is indicated to violate law and or misuse by any unauthorised party;

iii. Any loss and or damage due to non operation and or in case of any hindrance due to Force Majeure as referred to in Article 14.

3. In case of loss of HP, either due to thievery, loss, or any reason whatsoever, the User shall immediately contact the Customer Service of DANA for immediate blocking of the account of DANA. The User hereby exempts and keeps the DANA harmless from any risk and consequence sustained by the User in relation to the loss of HP number or alternative handphone number or negligence of User in fulfilling the provision of this paragraph and it shall therefore become the responsibility of the User.

4. The User hereby acknowledges and agrees that as DANA User, he/she shall be subject to including but without limitation to the terms and conditions of this DANA User, or the prevailing regulation in Indonesia from time to time regarding the Electronic money.

5. DANA shall, at its own consideration, be entitled to refuse the application for registration of DANA service by the User without informing the reason or cause of the refusal of the application.

6. The User is hereby required to check and ensure that any information of data inputted upon the Transaction is true. Therefore, the User exempts and keeps DANA harmless from any lawsuit, claim and/or indemnity from User or any party whomsoever and in any form whatsoever in relation to the negligence of the User to fulfil the provision of this paragraph.

7. If the Transaction is already completed, the User hereby acknowledges and agrees that the transaction CANNOT BE revoked under any reason whatsoever and the Transaction shall remain being processed according to the information of data which is already inputted by the User.

8. The User may be charged with certain fees in relation to the DANA service to the User according to the prevailing regulation in the DANA, including but without limitation to Transaction fee, short message serve (SMS) fee, and any other fees which is informed to the User through communication media in use for product of DANA. The user of DANA application service shall use the data service facility, therefore the User shall be subject to data access tariff which facility, fee and condition of its User are regulated by the cellular operator in use by the User.

9. In case of technical interruption to the network or in case of upgrading, change, repair and or maintenance of network causing the interruption of DANA service, then the DANA shall take immediate handling and repair or to a maximum of 1 (one) working day and in this case the User shall receive notification from the DANA application concerning the interruption of the said service.

10. In case of system error due to any reason whatsoever causing the interruption of DANA service or mistake in the implementation of service or transaction of DANA which is not caused by the User, then DANA shall repair at the soonest possible time for the said mistake within 1 (one) working day or to a maximum of 3(three) working days as of discovery of the said mistake.

XV. FORCE MAJEURE

Non-performance or delay in performance of the part or the entire obligation based on this “Terms and Conditions of DANA User” byDANA, shall not be considered as violation against “ the Terms and Conditions of DANA User” if it is caused by any event beyond control of DANA (Force Majeure), including but without limitation to (a) natural disaster, (b) fire, strike, war, insurrection, rebellion or any other military act, (c) the act of competent party/institution affecting the continuity of telecommunication service provision, (d) the act of third party causing DANA unable to give telecommunication service, and € any decision or amendment to decision giving impact to the implementation of this DANA service, including amendment to effectiveness of tariff to the User.

XVI. SECURITY AND CONFIDENTIALITY OF TRANSACTION

1. DANA is very concerned to security and comfort of User upon Transaction with DANA. Therefore, DANA has the security system when User makes transaction to give certainty to the User that the Transaction and information of User are safe.

2. DANA uses safe server to maintain the security of confidential information of User. All information which is sensitive in nature shall be sent through Secure Socket Layer (SSL) technology, of which in this case the data can only be accessed by the personnel having special authority which is required to remain keeping confidential the said information.

3. Ensure that PIN belonging to User is not known by anyone whomsoever, to avoid misuse by the other party.

4. In the case where DANA has cooperation with any third party in relation to provision of access to the DANA service to User through the said third party facility:

i. DANA can display the User’s account information data to any third party in the interest of maintaining the security of system;

ii. DANA can use the authorisation facility other thanDANA which is jointly determined by theDANA and third party which is in cooperation with DANA.

iii. DANA warrants that the provision on implementation as referred to in part i) and ii) above has fulfilled the standard of security and provision of DANA as well as ensuring that the said matter does not violate the prevailing legislation.

XVII. REPRESENTATION AND WARRANTY

1. In relation to the implementation of Transaction it performs, the User hereby represents and warrants that it has read, understood and agreed with all of the content of “Terms and Conditions of DANA User”

2. User hereby represents and warrants that it shall be fully responsible for any service of DANA accessed with its User ID number.

3. User hereby represents and warrants that the data given/filled in is true/accurate and full.

4. Any document already submitted to DANA and cannot be returned under any reason whatsoever.

5. User agrees to exempt and keep DANA harmless from any lawsuit, claim, and/or indemnity of the party whosoever in relation to negligence of User in fulfilling the provision of this representation and warranty.

XVIII. MISCELLANY

1. This terms and conditions of DANA User shall be subject to, governed, and implemented according to law of the Republic of Indonesia.

2. In case of dispute in the interpretation and implementation of “ Terms and Conditions of DANA User”, DANA and User agree to resolve the same by deliberation.

3. User can contact Customer Service of DANA or see the application and website of DANA to know the information regarding the product and service of DANA.

4. User shall receive notice regarding product or service or recent promotion of DANA through personal communication media such as SMS or through application of DANA. If the User is not willing to receive the notice then the User may file Call Contact Us:

PT Espay Debit Indonesia Koe

Capital Place Lantai 18 (18th Floor)
Jl. Jenderal Gatot Subroto kav. 18
Jakarta 12710

Operating hours:

Mondays – Fridays, at 08.30 – 17.00

Telephone/Facsimile : 021-27937262 / 021-27937108

Email: help@dana.id

Notice to DANA Users relating to Personal Data (Privacy) Ordinance (“Ordinance”)

This notice applies to services provided by PT EDIK (otherwise known as “DANA”, “we”, “our” or “us”) and sets out how we may collect, use and disclose your “personal data”, “personally identifiable information” or other personal information (collectively, “Personal Data”) in connection with your access to and use of the DANA mobile application.

As more fully described in the DANA User Terms and Conditions (“App Agreement”), your DANA wallet is an integrated life-style services app designed by PT EDIK for users. The DANA App provides a gateway for registered users of DANA Wallet to participate in a variety of activities, including interacting with friends, accessing information and making payments.

The DANA App is provided free of charge for registered users. Anyone who does not have an account can sign up for an DANA Wallet account (“DANA Wallet”) with PT EDIK, a stored value facility licensee under the Indonesia Monetary Authority. For details of the privacy notice with respect to DANA Wallet, please see the relevant section within the DANA App.

From time to time, it is necessary for you to provide us with Personal Data in connection with your access to and use of the DANA App. By agreeing to the App Agreement or by continuing to access or use the DANA App, you will be deemed to have agreed to and been notified of the terms of this notice concerning the collection, use, storage, transfer and disclosure of your Personal Data as set out in this notice.

If you do not supply such Personal Data to us, it may result in us being unable to provide you with the services in the DANA App or to comply with any laws or guidelines issued by regulatory or other authorities.

The word “including” shall not be limiting.

A. COLLECTION OF PERSONAL DATA

We may obtain your Personal Data from various sources (e.g. from you or through third parties), including:

1. Information obtained (directly or indirectly) about your computer, mobile device or other item of hardware through which you access and use the DANA App (including your IP address, geographical location, browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use) (“Device Information”).

2. Information obtained (directly or indirectly) when you register with DANA account as a user of the DANA Wallet, including your name, date of birth, address, telephone number and email address (“Registration Information”).

3. Information obtained (directly or indirectly) during your use of the DANA Wallet, including your bank account numbers, billing and delivery information, transaction data, credit/debit card numbers and expiration dates and other information from checks or money orders (“Account Information”).

4. The above Device Information, Registration Information and Account Information or other information may be accessed or collected (automatically or manually) at the time during your registration with DANA account as a user of the DANA Wallet and/or during the course of your use of the DANA App and DANA Wallet.

The above information obtained by us may constitute your Personal Data. We have taken steps to ensure that we do not collect more information (whether or not such information constitutes Personal Data) from you than is necessary for us to provide you with our services, to perform the functions set out Part B of this notice, to protect your DANA Wallet, comply with our legal obligations, protect our legal rights, and to operate our business.

B. USE OF PERSONAL DATA

We may use the Personal Data that we obtained about you for the following purposes:

1. Verifying your eligibility to use any of the features and functions of the DANA App.

2. Processing your registration with DANA account as a user of the DANA Wallet and maintaining and managing your registration.

3. Providing you with services and related customer services regarding the use of your DANA Wallet, including, working in collaboration with DANA to facilitate the settlement of purchase price for goods and services, shipping and related services for purchases, charge-backs, sending notices about your transactions, and responding to your queries, feedback, claims or disputes.

4. Improving and expanding our offerings by way of research and development of new functions of the DANA App or other new products and services that we may offer from time to time.

5. Performing research, statistical analysis or surveys, whether orally or in writing, in order to manage and protect our business including our information technology infrastructure, to measure the performance of the DANA App and other services we offer and to ensure your satisfaction with our services.

6. Analysing trends, usages and other behaviours (whether on an individualised or aggregated basis), which helps us better understand how you and our collective user base access and use the DANA App and the underlying commercial activities conducted, including for purposes of improving our services and responding to customer queries and preferences.

7. Subject to having obtained your consent in accordance with applicable law and as contemplated in section D below, we may provide direct marketing information to you relating to services offered by us and our affiliates and selected third parties using your Personal Data to contact you, including by telephone, text (SMS), email, post and fax.

8. Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing and/or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our information technology platform.

9. Detecting, investigating, preventing or remediating violations of the App Agreement, any applicable internal DANA Wallet policies, relevant industry standards, guidelines, laws or regulations.

10. Making such disclosures as may be required by any law or regulation of any country applicable to us or our affiliate, government official or other third party, including any card association or other payment network. Disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement in any country applicable to us or our affiliate (including anti-money laundering and counter-terrorist financing reporting requirements).

11. Making any disclosure to prevent any harm or financial loss, to report any suspected illegal activity or to deal with any claim or potential claim brought against us or our affiliates.

12. Enabling any due diligence and other appraisals or evaluations for actual or proposed merger, acquisition, financing transactions or joint ventures.

13. Any other legitimate business purposes, such as protecting you and other users of the DANA App from losses, protecting lives, maintaining the security of our systems and products, and protecting any of our other rights and/or properties.

We also may use your Personal Data in other ways for which we provide specific notice at the time of collection or for which you have subsequently consented.

C. DISCLOSURE OF PERSONAL DATA

Your Personal Data held by us will be kept confidential but we may provide such information to the following parties (whether within or outside your country of residence) for the purposes set out in B.1 to B.13 above:

1. DANA Account and other DANA Wallet wholly or partly owned group companies.

2. Any agent, contractor or third party service provider that we work with in providing you with our services, including for fraud prevention, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services.

3. Entities with whom we maintain business referral or other commercial arrangements, including third parties and entities belonging to PT EDIK.

4. Merchants and other organisations, such as card associations, payment networks or financial institutions, to whom or through which payments are made using the DANA Wallet, or such other entities to enable your use of the DANA App.

5. Third party financial institutions, banks, collection agents and credit agencies.

6. Third party marketing service providers.

7. Professional advisers, law enforcement agencies, insurers, government and regulatory authorities or any other organisations to which PT EDIK is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement, including arrangements with any card association or payment network.

8. Entities involved in any merger, acquisition, financing transaction or joint venture with us.

D. DIRECT MARKETING

As specified at B.7, PT EDIK may wish to use your Personal Data in direct marketing activities and will at such future point in time obtain your consent with respect to the contemplated scope and manner for such direct marketing activities fully in accordance and compliance with the requirements set out in the provisions of Part VI A of the Ordinance. Where you provide such subsequent consent, then please note that:

1. Certain Personal Data obtained by us from time to time may be used in direct marketing.

2. We may market to you goods and services which we believe may be of relevance to you for which your subsequent consent will be specifically obtained. This may include goods and services that are offered by us, any of our affiliates, our business partners or selected third parties, including any payment and financial products.

3. We may provide your Personal Data to certain third parties for use by them in marketing their own goods and services, including (i) our affiliates, (ii) business partners such as the Ant Financial Group, Alibaba Group, and (iii) other third parties.

4. Your consent to the use of your Personal Data for direct marketing purposes will be solicited by way of an opt in check box or other positive indication of no objection.

5. If at any time you do not wish us to continue to use or provide to other persons your Personal Data for use in direct marketing as described above and in the relevant consent, then you may exercise your “opt-out” right by notifying us.

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E. SECURITY MEASURES AND RETENTION

We take all reasonable steps, including technical, administrative and physical safeguards to help protect your Personal Data that we process from loss, misuse and unauthorised access, disclosure, alteration and destruction.

We will retain and procure our service providers to retain your Personal Data only for so long as is necessary for the purposes set out in this notice and in accordance with the Ordinance and all applicable regulatory requirements.

For registered users of the DANA Wallet, your Registration Information and Account Information (if any) can be viewed and edited in the DANA App through your account with DANA, which is protected by a password or PIN code. We recommend that you do not divulge your password or PIN code to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer.

F. THIRD PARTY SERVICES AND WEBSITES

The DANA App may provide links to other websites and services (including apps operated by third parties) for your convenience and information. These services and websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you to review before you use any of their services or conduct any activities on those websites. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for their contents, their privacy practices and the quality of their services.

G. CHANGES TO THIS NOTICE

We reserve the exclusive right to change, amend or revise this notice from time to time.

H. FURTHER INFORMATION

Where you have the right under the Ordinance to access or correct your Personal Data or exercise of any “opt-out” right or if you wish to contact us, please do so by contacting the Data Protection Officer by the following means:

PT Espay Debit Indonesia Koe (DANA)

Capital Place Lantai 18 (18th Floor)
Jl. Jenderal Gatot Subroto kav. 18
Jakarta 12710

Operating hours:

Mondays – Fridays, at 08.30 – 17.00

Telephone/Facsimile : 021-27937262 / 021-27937108

Email: help@dana.id