PRIVACY POLICY

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

The existence of this Privacy Policy is our genuine commitment to provide security for every collection and processing, disclosure, as well as ensuring and fully supervising every processing of your personal data in connection with the provision of the Services.

This Privacy Policy aims to provide information about your rights when accessing and/or logging into the SkorLife Platform based on applicable laws and regulations, including Law Number 27 of 2022 concerning Personal Data Protection ("PDP Law"). Furthermore, this Privacy Policy is created to regulate the terms of use of your data in connection with the provision of the Services mentioned in the Terms of Use.

Unless otherwise specified, all terms in capital letters not defined in this Privacy Policy have the same meaning as set forth in the Terms of Use.

CONTROL OF YOUR PERSONAL DATA

We, SkorLife, a company based in South Jakarta, are your personal data controllers who are responsible for fully processing your personal data collected through the SkorLife Platform.

COLLECTION OF PERSONAL DATA

What do We collect?

The personal data We obtain from You (“Disclosing Party”) may include the following:

I. PERSONAL DATA YOU PROVIDE TO US

In order for SkorLife Platform to provide Services to Users, upon registration and during your interaction with the SkorLife Platform, we may collect and process your personal data as follows:
- User basic data
  This includes but is not limited to name, place and date of birth, gender, marital status, employment, ID Number (NIK), as well as a photo of your KTP and citizenship.
- User Contact
  This includes but is not limited to address, telephone/cellphone number, and email address.
- Financial Data
  This includes but is not limited to credit history and other financial details listed in the Credit Information.
- Access to Camera
  This access is used for the User identification and verification process.
- Access to Microphone
  This access is used to verify users in our system.
- Access to Gmail
  Skorlife's use and access to the Gmail API is authorized through Google's access mechanism, and will adhere to the Google API Services User Data Policy, including the Limited Use requirements, specifically for the purposes of providing monitoring services for the benefit of the User.
  The user authorizes Skorlife access to his/her Gmail for a restricted scope to only access and read their credit card statement sent from banks or financial institutions and/or credit report that may be sent from the Licensed Credit Bureau. Skorlife does not open, read, or write any emails beyond this scope nor any of your personal emails. By giving Skorlife access to this data, Skorlife is able to:
  - Help User monitor and track credit card bill specifics such as total amount due, minimum amount due and due date, and other financial and transactional information.
  - Helping User understand their credit data as reflected by their official credit report.
  - Monitoring User's credit data including their credit facilities and payment history, as reflected from their official credit report
  Skorlife employs automated processes where no humans are involved for accessing and analysing information provided or consented to be provided through Gmail by the User.
  
  If User authorize Skorlife's access to User's Gmail account, Skorlife will securely store account details for each of the e-mail accounts, including user-name and authorization tokens for tracked accounts.
  
  Please note that User's consent to any of the above is purely voluntary. User can terminate the access to Gmail at any time through Skorlife's mobile app.
- The services mentioned above are comprehensive, and Skorlife does not use Credit Information for any purposes other than those stated. Skorlife will protect user data stored by considering adequate security aspects. To clarify further:
  - Skorlife will only use the Credit Information obtained from Licensed Credit Bureaus to provide financial planning services to users.
  - Skorlife does not use Credit Information that you obtain from Licensed Credit Bureaus to determine credit worthiness or apply for loan facilities.
  - Skorlife does not use the Credit Information you obtain from Licensed Credit Bureaus to conduct marketing activities including running ads, retargeting, personalized or interest-based ads.
  - Skorlife does not transfer or sell data to any third party unless required by applicable laws and regulations.
In an effort to improve the Services, you may from time to time update your data and submit other relevant information (apart from that mentioned above) to us. We will not provide your information to any third party except in accordance with the terms of this Privacy Policy.
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 identifier;
- your use of the SkorLife Platform such as the pages you view, the features you use, your Location information; and/or
- cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

UNDERAGE USER DATA

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

USE OF PERSONAL DATA FOR PERSONS WITH DISABILITIES

In particular, we will process the personal data of users who have disabilities, which is done through communication in a certain way in accordance with the needs of people with disabilities as regulated in Law Number 8 of 2016 concerning People with Disabilities.

In processing this data, persons with disabilities can act for and on their own behalf or be represented by a guardian.

If you have a disability and need assistance to exercise your rights as a data subject, please contact us at wecare@skorlife.com.

The process will take up to 30 (thirty) working days from the date of sending your application.

HOW WE COLLECT YOUR DATA

Your personal data will be collected and stored, directly or indirectly, when:

You enter the SkorLife Platform;
You disclose it to Us;
any authorized person related to you or your legal representative (including but not limited to your spouse or family member) discloses to us; and
relevant third parties, including but not limited to partners who collaborate with us in relation to service providers and government agencies that have authority based on applicable laws and regulations.

Regarding letter c) above, when you do not convey information about you directly, the party who represents or is your proxy is obliged to first obtain your consent and notify you about the disclosure of your personal data, in accordance with this Privacy Policy.

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

We will forward and process the personal data that you provide to us and that we obtain periodically for the following purposes as follows:

to provide Services, including carrying out our obligations to you or based on applicable laws and regulations;
to carry out identification and verification before We provide Services to You or before We register You as a User, in this case including carrying out the User introduction (Know Your Customer/KYC) process;
to provide information to the Licensed Credit Bureau related to the provision of Services and for the interests of Users, so that the Licensed Credit Bureau can carry out its activities;
to improve Our existing Services and develop new Services;
to communicate with you about our existing or future Services, including but not limited to, terms and conditions, promotions, activities and advertising;
for administration and business operations of the SkorLife Platform; And
to be a reference that we can trust, for the purpose of fulfilling the obligations to which we must comply, as required by applicable laws and regulations including those related to personal data protection.

We will collect and use your personal data in accordance with the Terms of Use.

For your security, we take security measures to protect against unauthorized access. These actions include internal checks of practices and security measures of data collection, storage and processing, including appropriate encryption and physical security measures to protect against unauthorized access to systems where we store personal data. All information collected on the SkorLife Platform is stored securely in controlled data centers. Access to the server is restricted, password protected, includes necessary encryption, and strictly restricted.

In the event that we may appoint another party as a personal data processor to process your personal data and in the event that the appointed personal data processor acts outside the orders and purposes set by us, then all consequences arising from the processing of such personal data will be our responsibility. from the appointed personal data processor in full accordance with the provisions of laws and regulations relating to Personal Data Protection

HOW LONG DO WE KEEP YOUR DATA?

You hereby agree that as long as you are a registered user of the SkorLife Platform, we can store your data, and so on, in accordance with this Privacy Policy. We will retain your personal data as long as necessary for the purposes of collecting and using the Services, unless required or permitted by applicable laws and regulations. Your personal data will be stored for at least 5 (five) years since you are no longer a User starting from the time there is no activity on your account for a period of 2 (two) years.

Meanwhile, financial and billing information related to you, in accordance with statutory regulations relating to company documents, will be stored for at least 10 (ten) years since you are no longer a User on the SkorLife Platform.

We will delete your personal data if you decide to exercise your rights as a Data Subject (as intended in laws and regulations related to personal data protection) in accordance with the provisions of this Privacy Policy. Deletion of your personal data will take at least 30 (thirty) working days from the date of sending your request.

DISCLOSURE OF USER'S PERSONAL DATA

To carry out our obligations towards you or the applicable laws and regulations, your personal data may be disclosed and/or disseminated to limited third parties only for the purposes stated in this Privacy Policy. These third parties include but are not limited to partners who collaborate with us in relation to service providers and government agencies that have authority based on applicable laws and regulations.

Subject to your explicit consent, we may use information generated by your use of the Services, excluding information collected from other sources such as email, etc., for marketing purposes. This consent is purely voluntary and you may at any time opt out of receiving marketing materials from us by following the unsubscribe instructions included in any email you may receive. Furthermore, if you wish to remove your contact information from all our lists and newsletters, please click the unsubscribe button on the email sender or send an email request to wecare@skorlife.com

Then, for the purpose of improving your experience in using the SkorLife Platform and optimizing traffic in access by Users, we will also track your behavior using analytical tools. This analytical equipment will be provided by a third party provider appointed by us, and we hereby reserve the right to add, discontinue or change the current provider to another third party analytical service provider. The information we collect for this purpose will be anonymous and non-identifiable to you.

For the purposes of our business activities, and subject to applicable legal provisions, you agree that your data, anonymously and not identifiable to you, may be disclosed and/or disseminated to our affiliates or group companies and third parties such as the company's external auditors, advisors , survey/data analysis service providers, and investors in accordance with this Privacy Policy.

Apart from the purposes mentioned above, based on your consent, we may disclose and/or distribute your personal data for the following reasons:

this is required by the provisions of applicable laws and regulations;
it is necessary to prevent an emergency or protect others from harm; And
for the public interest.

If We disclose and/or disseminate your personal data to any third party, We will inform the third party about its confidential nature and their obligation to limit the use of such personal data to anyone involved for permitted purposes only as necessary, and to handle such personal data is strictly in accordance with this Privacy Policy and is subject to statutory provisions regarding the protection of personal data.

We may disclose your personal data in connection with a merger, separation, takeover, consolidation or dissolution ("Corporate Action") that we carry out to other parties involved in the Corporate Action. For the avoidance of doubt, if changes occur to Our business, then any existing User personal data that has been received, processed and stored by Us and your data in the future will be transferred to the new owner who can use your personal data in the same way as set forth in this Privacy Policy.

In the event of a Corporate Action, We will provide notification to you before and after the Corporate Action is carried out via the SkorLife Platform and/or by sending you an electronic letter.

PROHIBITION OF DISCLOSURE OF USERS' PERSONAL DATA OVERSEAS

We will not transfer, copy and/or make accessible personal data and/or Credit Information to or by parties outside the territory of the Republic of Indonesia in accordance with the provisions of applicable laws and regulations.

YOUR RIGHTS AS A DATA SUBJECT

Subject to the provisions of applicable laws and regulations regarding personal data protection, by using the Service, the protection of your personal data will include the following processes:

Right to Access
namely the User's right to gain access and obtain a copy of personal data about himself.

Right to Rectification
namely the User's right to complete, update, and/or correct errors and/or inaccuracies in personal data about himself.

Right to Deletion
namely the User's right to end processing, delete and/or destroy personal data about him.

Right to Withdraw Consent
namely the User's right to withdraw consent to the processing of personal data about him that has been given to us.

Right to Restrict
namely the User's right to delay or limit the processing of personal data proportionally in accordance with the purposes of personal data processing in this Privacy Policy.

Right to Obtain Data
namely the User's right to obtain and/or use personal data about himself from Us in a form that conforms to the structure and/or format commonly used or can be read by electronic systems.

Right to File a Complaint
namely the User's right to submit a complaint to the Institution regarding the way personal data is processed which results in the failure of our protection of your personal data.

Right to Object
namely the User's right to object to decision-making actions that are based solely on automated processing that give rise to legal consequences or have a significant impact on you.

If you wish to exercise your rights as a Data Subject, please contact us at wecare@skorlife.com. This process will take up to 30 (thirty) working days from the date of sending your application.

REFUSAL OF PROVIDING ACCESS TO YOUR PERSONAL DATA

We have the right to refuse to provide access to your personal data, in the case of:

national defense and security interests;
interests of the law enforcement process;
public interest in the context of state administration;
interests in supervision of the financial services sector, monetary, payment systems and financial system stability carried out in the context of state administration; or
interests of statistics and scientific research

COOKIES INFORMATION

What are Cookies?

Cookies are small pieces of data sent from websites to be stored on your personal device. They enable the SkorLife Platform to recognize your device and collect information to tailor content to suit your preferences. We use cookies through our third party service providers to improve your experience.

What Cookies do We Use?

Users can determine the choice to make modifications through the SkorLife User Platform settings, namely by choosing to reject cookies (this choice can hinder the optimal availability of our services when Users using SkorLife Platform).
We use the Google Analytics Demographics and Interest feature. The data we obtain from this feature is as follows: age, gender, User interests and other information that can identify the User, we will use to develop features, facilities and/or content on the SkorLife Platform.
We may use features provided by third parties in order to improve our services and content, including assessing, customizing and serving advertisements to each user based on their interests or visit history.

EXTERNAL LINKS

The SkorLife Platform may contain links to other websites for which we cannot ensure your privacy and security. The inclusion of such a link does not guarantee that other websites will provide you with the same standards of personal data protection in accordance with this Privacy Policy. Therefore, you are solely responsible for your decision to access the website.

NOTICE OF FAILURE TO PROTECT YOUR PERSONAL DATA

If there is a failure to protect your personal data, we will provide written notification to you via your account and/or email address registered on the SkorLife Platform no later than 3x24 (three times twenty four) hours after the failure to protect your personal data occurs. Skorlife establishes and implements policies, procedures and/or guidelines regarding preventing and handling failures in Personal Data Protection in accordance with Data Security Procedures.

PRIVACY POLICY CHANGES

We may at any time make changes or updates to this Privacy Policy to comply with applicable legal provisions by notified you via Skorlife application when changes occur. We also encourage you from time to time to check the “Date Updated” of this Privacy Policy.

CONTACT US ABOUT PRIVACY POLICY

If you have questions, comments, or recommendations about the Privacy Policy, please send your questions, comments, or recommendations to wecare@skorlife.com. This process will take up to 30 (thirty) working days from the date of submission of your application.

LANGUAGE

This Privacy Policy is written in Indonesian and English. In the event of any inconsistency or difference in interpretation between the Indonesian version and the English version, you agree that the Indonesian version shall prevail to the extent of such inconsistency or difference, and the relevant English version is deemed to be automatically modified to conform to the relevant portion of the Indonesian version.

APPLICABLE 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 a dispute, conflict or controversy, the dispute resolution method set out in the “Dispute Resolution” Clause in the Terms of Use applies.