PRIVACY POLICY

This Privacy Policy is effective as of December 1, 2024, and Last updated on December 1, 2024.

PT Skortech Karya Indonesia (hereinafter referred to as "SkorLife," "Company," "We") is a company that provides Users ("Users," "You," "I") with easy access to financial reputation analysis and planning advice through the SkorLife Platform.

This Privacy Policy is our commitment to ensuring the security of every collection, processing, and disclosure of personal data while guaranteeing full supervision of all personal data processing in connection with providing the Services.

This Privacy Policy aims to provide information about your rights when you access and/or enter the SkorLife Platform under the applicable laws, including Law No. 27 of 2022 on Personal Data Protection ("PDP Law"). Furthermore, this Privacy Policy sets forth the provisions on the use of your data and informs you about the identity, legal basis, purpose of personal data requests, and accountability of all requests and processing of personal data concerning the Services described in the Terms of Use.

Unless otherwise stated, all capitalized terms not defined in this Privacy Policy have the same meaning as those set out in the Terms of Use.

ROLE OF SKORLIFE

We, SkorLife, a company based in South Jakarta, are the controllers of your personal data concerning the account creation process on the SkorLife Platform and the provision of Services that facilitate the monitoring of Credit Information as referred to in the Terms of Use. In facilitating Users to obtain Credit Information from Licensed Credit Bureaus, SkorLife acts as a personal data processor appointed by the Licensed Credit Bureau to assist Users in filling out Credit Information request forms, verifying User profiles, and submitting these forms to the Licensed Credit Bureau.

COLLECTION OF PERSONAL DATA

What do we collect?

The personal data we obtain from you may include the following:

I. PERSONAL DATA YOU PROVIDE TO US

To provide the Services, when Users access, register, and while Users use the Services on the SkorLife Platform, we collect and process your personal data, including but not limited to:
- User basic data: Includes but is not limited to name, place and date of birth, gender, marital status, occupation, nationality, National Identity Number (NIK), photo, and Identity Card (KTP).
- User Contact Information: Includes but is not limited to address, phone/mobile number, and email address.
- Financial Data: Includes but is not limited to address, phone/mobile number, email address, Credit Score Reports issued by Licensed Credit Bureaus, and relevant credit repayment and/or settlement history.
- Camera and Selfie Access SkorLife requests access to the camera for user identification and verification purposes. During the verification process, the SkorLife Platform will ask Users to upload a selfie for identification and verification purposes.
- Microphone Access This access is used for User verification within our system.
- Gmail Access The use and access to the Gmail API by SkorLife are authorized through Google's access mechanism and will comply with the Google API Services User Data Policy, including the Limited Use requirements, specifically for providing Services and monitoring for the benefit of Users.
  - Users authorize SkorLife to access their Gmail within a limited scope only to access and read credit card statements sent by Banks or financial institutions and/or credit reports sent by Licensed Credit Bureaus. SkorLife does not open, read, or write any emails beyond this scope.
  - Users can revoke SkorLife’s access to Gmail at any time via the SkorLife mobile application.
II.DATA WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES
When you access the SkorLife Platform or use our services, we may automatically collect the following information about you:
- Your device’s internet protocol (IP) address, log information, error messages, computer or mobile device operating system, browser type, mobile protocol type, mobile device characteristics, device identity/brand, unique device identification, and/or mobile equipment identifiers.
- Your usage of the SkorLife Platform, such as pages you view, features you use, and location information.
- Cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

USER DATA OF MINORS

Our Services are not intended for Users under the age of 18 years old. We will not collect, use, provide, or process any personal data from Users under 18 years old in any way or for any purpose.

USE OF PERSONAL DATA FOR PERSONS WITH DISABILITIES

Specifically, We will process the personal data of Users with disabilities through communication methods tailored to their needs, in accordance with Law Number 8 of 2016 on Persons with Disabilities.

In processing such data, persons with disabilities may act on their own behalf or be represented by a guardian.

If you have a disability and require assistance in exercising your rights as a data subject, please contact Us at wecare@skorlife.com. The process may take up to 30 (thirty) business days from the date of your request submission.

HOW WE COLLECT YOUR DATA

Your personal data will be collected and stored, either directly or indirectly, in the following situations:

When you log in to the SkorLife Platform;
When you disclose your data to Us;
When you use the Services;
When an authorized person related to you or your legal representative (including but not limited to your spouse or family members) discloses your data to Us; and
When it is collected and stored by relevant third parties, including but not limited to partners working with Us for the provision of Services and/or as requested by government authorities with the necessary legal authority in accordance with applicable laws and regulations.

Regarding point c) above, if the information about you is not provided directly by you, the person representing you or acting on your behalf must first obtain your consent and inform you about the disclosure of your personal data, in accordance with this Privacy Policy.

WHY WE COLLECT YOUR PERSONAL DATA AND HOW WE USE AND SECURE IT

We will process and utilize the personal data you provide to us and the data we obtain periodically for the following purposes:

To provide the Services, including fulfilling Our obligations to You or in accordance with applicable laws and regulations;
To conduct identification and verification before We provide the Services to You or before We register You as a User, including the Know Your Customer (KYC) process;
To provide information to the Licensed Credit Bureau related to the provision of Services and for the User's benefit, enabling the Licensed Credit Bureau to carry out its activities;
To facilitate the forwarding of requests for correction of errors in Credit Information to the Licensed Credit Bureau;
To provide credit arrears analysis services and facilitate payment of outstanding credit;
In certain cases, to provide services to third-party companies working with SkorLife for internal company evaluation and employment-related purposes, where the User has an existing legal relationship with the relevant third-party company;
To improve Our existing Services and develop new Services;
To communicate with You regarding Our current or upcoming Services, including but not limited to terms and conditions, promotions, activities, and advertisements;
For the administration and business operations of the SkorLife Platform; and
To serve as a reliable reference for compliance with Our legal obligations, as required by applicable laws and regulations, including those related to personal data protection.

The collection and use of your personal data will be carried out in accordance with the Terms of Use.

For your security, we implement protective measures to prevent unauthorized access. These measures include internal security checks on the collection, storage, and processing of data, including appropriate encryption and physical security measures to prevent unauthorized access to systems where We store personal data. All information collected within the SkorLife Platform is securely stored in a controlled data center. Access to servers is restricted, password-protected, encrypted as necessary, and strictly limited.

In the event that We appoint another party as a personal data processor to process your personal data, and if the appointed processor acts beyond Our instructions and intended purposes, all consequences arising from such data processing will be the full responsibility of the appointed personal data processor, in accordance with the applicable personal data protection regulations.

HOW LONG WE STORE YOUR DATA

You hereby agree that as long as you remain a registered User of the SkorLife Platform, we may store your data in accordance with this Privacy Policy. We will retain your personal data for as long as necessary to fulfill the purposes of data collection and service provision, unless otherwise required or permitted by applicable regulations.

Your personal data will be retained for a minimum of five (5) years from the time you are no longer a User, which will be counted either from:

Two (2) years of inactivity in your account, or
The deletion of your account based on your request.

Meanwhile, financial information and billing records related to you, in compliance with corporate document regulations, will be retained for at least ten (10) years from the time you are no longer a User of the SkorLife Platform.

Once the retention period specified in this Privacy Policy ends, we will permanently destroy your personal data.

We will delete your personal data if you decide to exercise your rights as a Data Subject, as stipulated in the applicable data protection regulations and in accordance with this Privacy Policy. The deletion process of your personal data will take at least thirty (30) business days from the date of submission of your request.

DISCLOSURE OF USER PERSONAL DATA

To provide Services to you or comply with applicable regulations, your personal data may be disclosed and/or shared with third parties, but only for the purposes stated in this Privacy Policy. These third parties may include, but are not limited to:

Partners working with us to provide Services, such as sending One-Time Password (OTP) codes or conducting Electronic Know Your Customer (e-KYC) processes..
Licensed Credit Bureaus, for obtaining Credit Information or processing Credit Information updates.
Third-party companies cooperating with SkorLife, who may access your Credit Information only with your explicit consent.
Government agencies with legal authority, as required by applicable laws and regulations.

With your explicit consent, we may use information derived from your use of our Services (excluding data collected from external sources such as emails, etc.) for marketing purposes.

This consent is entirely voluntary, and you may choose to opt out of receiving marketing materials from us at any time by following the unsubscribe instructions included in every email you receive from us.

Furthermore, if you wish to remove your contact information from all our mailing lists and newsletters, you may click the unsubscribe button in the email sender section or send a request via email to wecare@skorlife.com.

DISCLOSURE OF USER PERSONAL DATA TO THIRD PARTIES

To enhance your experience in using the SkorLife Platform and optimize traffic access for Users, we will also track your behavior using analytics tools. These analytics tools will be provided by third-party service providers appointed by us. We reserve the right to add, discontinue, or replace the current service providers with other third-party analytics providers. The information we collect for this purpose will be anonymous and cannot be directly identified with you.

For the benefit of our business operations, and subject to applicable laws and regulations, you agree that your data, in an anonymous and non-identifiable form, may be disclosed and/or shared with our affiliates, group companies, and third parties, such as:

External auditors,
Advisors,
Survey/data analysis service providers, and
Investors, in accordance with this Privacy Policy.

In addition to the purposes mentioned above, with your consent, we may disclose and/or share your personal data for the following reasons:

If required by applicable laws and regulations;
If necessary to prevent an emergency or protect others from harm; and 
For public interest purposes.

If we disclose and/or share your personal data with any third party, we will notify the respective party of its confidential nature and their obligation to limit the use of your personal data only for permitted purposes, and to handle the data appropriately in accordance with this Privacy Policy and applicable data protection regulations.

We may disclose your personal data in connection with a merger, acquisition, corporate restructuring, consolidation, or dissolution (“Corporate Action”) involving our company to any parties engaged in such Corporate Action.

To avoid any doubt, if there is a business transition within our company, all existing user data that has been received, processed, and stored by us, including future user data, will be transferred to the new owner, who may continue using the personal data in accordance with this Privacy Policy.

In the event of a Corporate Action, we will notify you before and after the implementation of such Corporate Action via the SkorLife Platform and/or by sending an email notification to you.

DISCLOSURE OF USER PERSONAL DATA TO FOREIGN COUNTRIES

By using the SkorLife Platform and agreeing to our Privacy Policy and Terms of Use, you acknowledge and consent that, in providing our Services, we may transfer, copy, and/or allow access to your personal data and/or Credit Information to or by parties outside the territory of the Republic of Indonesia, in compliance with applicable regulations.

We will ensure that such data transfers are conducted with adequate security measures, in accordance with the applicable laws and regulations.

YOUR RIGHTS AS A DATA SUBJECT

Subject to applicable data protection laws and regulations, by using our Services, your personal data protection rights will include the following processes:

Right to Access
This is the right of Users to access and obtain a copy of their personal data, subject to the data retention provisions outlined in this Privacy Policy. We will grant you access to your data within a maximum of 3 x 24 hours after receiving your request.
Right to Rectification
This is the right of Users to complete, update, and/or correct any errors and/or inaccuracies in their personal data. We will make the necessary corrections within a maximum of 3 x 24 hours after receiving the request.
Right to Erasure
This is the right of Users to terminate processing, delete, and/or destroy their personal data.
Right to Withdraw Consent
This is the right of Users to withdraw their consent for the processing of their personal data previously granted to us. If the User withdraws consent, we will stop processing their personal data within a maximum of 3 x 24 hours from the date we receive the withdrawal request.
Right to Restriction
This is the right of Users to delay or restrict the processing of their personal data, in a proportional manner, in accordance with the purposes outlined in this Privacy Policy.
Right to Data Portability
This is the right of Users to obtain and/or use their personal data in a structured and/or commonly used format that can be read by an electronic system.
Right to File a Complaint
This is the right of Users to submit complaints to the Regulatory Authority regarding the way personal data is processed, particularly in cases of personal data protection failure by us.
Right to Object
This is the right of Users to object to decision-making processes that are solely based on automated processing, which may result in legal consequences or significant impacts on them.

If you wish to exercise any of your data subject rights, please contact us at wecare@skorlife.com. The processing of your request, aside from the ones specified above, may take up to 30 (thirty) working days from the date of your request submission.

DENIAL OF YOUR RIGHTS AND EXEMPTION FROM COMPANY OBLIGATIONS

Subject to the provisions of the Personal Data Protection Law (UU PDP), we may be exempted from our obligations as a data controller to fulfill our duties as outlined in this Privacy Policy and/or applicable laws and regulations if the request is made for any of the following purposes:

National defense and security interests;
Law enforcement processes;
Public interest in state administration; and
Supervision of financial services, monetary policy, payment systems, and financial system stability, carried out as part of state administration.

We may refuse to grant your request to exercise your data subject rights in cases where:

National defense and security interests apply;
Law enforcement processes require it;
Public interest in state administration is involved;
Financial services supervision, monetary policy, payment systems, and financial system stability require the retention of such data; or
Statistical and scientific research purposes necessitate continued data processing.

COOKIES INFORMATION

What are Cookies?

Cookies are small pieces of data sent from a website to be stored on your personal device. They allow the SkorLife Platform to recognize your device and collect information to tailor content according to your preferences. We use cookies through third-party service providers to enhance your experience.

What Cookies Do We Use?

1. Users can choose to modify cookie settings through the SkorLife User Platform, including the option to reject cookies (this choice may affect the optimal availability of our services when using the SkorLife Platform).
2. We use the Google Analytics Demographics and Interest feature. The data we obtain from this feature—such as age, gender, user interests, and other identifying information—will be used to improve the features, facilities, and/or content on the SkorLife Platform.
3. We may use third-party features to enhance our Services and content, including evaluation, customization, and targeted advertisements based on user interests or browsing history.

EXTERNAL LINKS

The SkorLife Platform may contain links to other websites where we cannot guarantee your privacy and security. The inclusion of such links does not ensure that other websites will provide the same level of personal data protection as stated in this Privacy Policy. Therefore, you are fully responsible for your decision to access such websites.

NOTIFICATION OF PERSONAL DATA BREACH

If a personal data protection failure occurs within SkorLife’s capacity as a data controller, SkorLife will provide written notification to you via your registered account and/or email address on the SkorLife Platform within a maximum of 3 x 24 hours from the occurrence of the personal data breach.

SkorLife has established and enforces policies, procedures, and/or guidelines for the prevention and handling of personal data protection failures in accordance with Data Security Procedures.

CHANGES TO THE PRIVACY POLICY

We may modify or update this Privacy Policy at any time to comply with applicable regulations by sending notifications through the SkorLife application when changes occur. We also encourage you to periodically check the “Last Updated Date” of this Privacy Policy.

CONTACT US ABOUT THE PRIVACY POLICY

If you have questions, comments, or suggestions regarding this Privacy Policy, please send your inquiries via wecare@skorlife.com. The process may take up to 30 (thirty) business days from the date of your request submission.

LANGUAGE

This Privacy Policy is written in Bahasa Indonesia and English. If there is any inconsistency or difference in interpretation between the Bahasa Indonesia version and the English version, you agree that the Bahasa Indonesia version shall prevail, and the English version shall be automatically adjusted to align with the relevant parts of the Bahasa Indonesia version.

GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy and its implementation are governed by and interpreted in accordance with Indonesian law.

The parties agree that in the event of any dispute, conflict, or controversy, the dispute resolution method set forth in the "Dispute Resolution" clause of the applicable Terms of Use shall apply.