PRIVACY POLICY

PT Skortech Karya Indonesia (hereinafter “SkorLife”, the “Company”, “We” or “Us” or “Our”) is a company providing easy access for Our user (“User”, “You”, “Your”) to get Credit Information and any other data, to allow You to manage Your Credit Information, or to build Your credit history through SkorLife Platform. Any defined terms in the Terms of Use shall also apply to this Privacy Policy, unless stipulated otherwise.

The existence of this Privacy Policy is Our real commitment to provide security for each collection, processing, disclosure, and transfer, as well as guarantee and take full supervision over any processing of personal data that You provide to Us.

This Privacy Policy aims to provide information on Your rights when You access and/or login to SkorLife Platform under Law Number 27 of 2022 on Personal Data Protection (“PDP Law”). Furthermore, this Privacy Policy is made to govern the usage of Your data in relation to the provision of Services that We mentioned in Terms of Use.

Unless stipulated otherwise, all capitalized terms that are not defined in this Privacy Policy have the same meanings as set out in the Terms of Use.

YOUR PERSONAL DATA CONTROLLER

We, SkorLife, a company domiciled in South Jakarta, is Your personal data controller who is responsible for fully processing Your personal data collected through the SkorLife Platform.

PERSONAL INFORMATION COLLECTION

What We collect?

Personal information that We collect from You (“Disclosing Party”) may include the following:

• I. PERSONAL DATA THAT YOU PROVIDED TO US

  To make the SkorLife Platform able to provide Service to User, We will be able to collect and process the following information and/or data as follows:

  • Personal Details
    This may include but not limited to name, place and date of birth, gender, marital status, occupation, Identity Card Number (NIK), mother’s maiden name, as well as Your photo and citizenship.
  
  
  • Contact Information
    This may include but not limited to address, telephone/mobile number, and email address.
  
  
  • Financial Information
    This may include but not limited to credit history and other financial detail which include 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 User in Our system.
  
  
  • Access to Gmail
    Authorizing access to User Gmail account is required in order to access User’s credit report and other financial and transactional information, to provide the following services including but not limited to:
    
    • Providing insights regarding User’s credit history
    • Managing User’s credit information at one place
  
  
  Skorlife’s access to the Gmail account is authorized through Gmail’s access mechanism. 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 de-link the access to Gmail at any time the User wishes.
  
  We only read emails from the Licensed Credit Bureau and do not open, read or access any personal emails. For the sake of clarity, Skorlife employs automated processes for accessing and analysing information provided by the User; where Skorlife may need to use algorithms to access a password-protected document utilizing information provided by the User.
  
  In an effort to improve the SkorLife Platform Service, You may from time to time, update data and submit other relevant information (other than as stated above) to Us. You can rest assured that We do not share the information provided with any third parties except in accordance with the terms of this Privacy Policy.

• II. DATA THAT WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES

  When You access SkorLife Platform or use Our services, We may automatically collect the following information about You:
  • internet protocol (IP) address of Your device, log information, error messages, computer or mobile device operating system, browser type, mobile protocol type, mobile device characteristics, device ID/brand, unique device identification, and/or mobile equipment identifier;
  • Your usage of SkorLife Platform such as pages You viewed, features You use, Your location information; and/or
  • cookies, pixel tags and similar technologies that create and maintain unique identifiers.

INFORMATION ABOUT MINOR

Our Services are not intended for children under the age of 18 years. We will not collect, use, provide or process, in any form, any personal information from children under the age of 18 years intentionally.

As a parent and/or legal guardian, please do not permit Your children to submit their data to Us. We will close all accounts used by such children and will eliminate and/or delete all personal information sent to Us without the consent of parents or legal guardians for children under the age of 18 years.

USE OF PERSONAL DATA FOR PERSONS WITH DISABILITIES

In particular, We will process the personal data of User with disabilities through communication in a certain way according to the needs of people with disabilities as regulated in Law Number 8 of 2016 concerning Persons with Disabilities.

In processing data, persons with disabilities can act for themselves or be represented by their guardians.

If You have a disability and need help to use Your rights as a Data Subject, please do not hesitate to contact Us at wecare@skorlife.com. The process will take up to 30 (thirty) business days from the date of Your submission.

HOW DO WE COLLECT THOSE INFORMATION?

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

• You enter SkorLife Platform;
• You disclose to Us;
• any authorized persons related to You or appointed by You (including but not limited to Your spouse or family member) discloses to Us; and
• relevant third parties (including but not limited to the financial services providers, such as bank, payment services provider, payment gateway provider with which We have entered into a cooperation, or other financial institutions, regulatory bodies e.g. Financial Services Authority of the Republic of Indonesia (Otoritas Jasa Keuangan or OJK), Directorate General of Tax of the Ministry of Finance of the Republic of Indonesia (DGT), Directorate General of Population and Civil Registration of the Ministry of Home Affairs of the Republic of Indonesia (DGPCR), Indonesian Financial Transaction Reports and Analysis Center (Pusat Pelaporan dan Analisis Transaksi Keuangan or PPATK), Indonesian National Police (Kepolisian Negara Republik Indonesia or POLRI), and other reliable sources.

In the case of (c), when the information concerning about other persons (“Data Subject”) than the Disclosing Party is given to Us, it is the sole responsibility of the Disclosing Party to ask for a consent from and notify the data subject of the Disclosing Party of his/her personal information and the terms and conditions of this Privacy Policy.

WHY DO WE COLLECT AND HOW DO WE USE AND SECURE THOSE DATA?

We will use and process the personal data that You provided to Us and which We obtain periodically for the following purposes:

• to provide You with Our Services which shall include performing Our relevant contractual or regulatory obligations;
• to identify and verify before We provide Services to You as a User, in this case including carrying out the Know Your Customer (KYC) process;
• to provide information to the Licensed Credit Bureau, so that Licensed Credit Bureau may carry out their operations;
• to enhance Our existing Services and products and develop new Services and products;
• to communicate with You about Our existing or up-coming Services or products, including but not limited to, terms and conditions, promotion, activities, and advertisement;
• for administration and business operation of SkorLife Platform; and
• to rely on the purpose or obligation which are subjected to Us to collect Your personal data stipulated by the relevant applicable laws and regulations, such as personal data protection laws and other related law.

We will collect and use Your personal data based on the authority and power You grant to Us as stated in Our Terms of Use.

For Your security, We take appropriate security measures to protect against unauthorized access. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. All information gathered on SkorLife Platform, is securely stored within a controlled database. Access to the servers is restricted, password-protected, including appropriate encryption, and is strictly limited.

In the event that We may appoint other 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 the personal data will be the responsibility of the appointed personal data processor in full in accordance with the provisions of the PDP Law.

HOW LONG DO WE RETAIN THE INFORMATION?

You hereby agree that so long as You are a registered User in SkorLife Platform, You agree that We may retain Your data, and continuously in accordance with this Privacy Policy. We will retain Your personal information as long as it is necessary for the purposes of collection and use, unless required or permitted by applicable law. Your personal information will be retained for 5 (five) years minimum since You no longer become a user in SkorLife Platform starting from absence of activity found on your account for a period of 2 (two) years.

Whereas for financial information related to You, such as the amount of payment of premiums, claims and other ancillary payments, as per the applicable laws and regulations on Corporate Documents, will be retained for at least 10 (ten) years since You are no longer become a User in SkorLife Platform.

We will delete Your personal data in the event that You decide to use Your Data Subject rights as stated in this Privacy Policy. The deletion of Your personal data will take up to 30 (thirty) business days from the date of Your submission.

DISCLOSURE OF USER PERSONAL DATA

In order to perform Our contractual obligations towards You or Our regulatory obligations towards regulators and authorities, Your personal information may be disclosed, or disseminated to limited third parties for only the relevant purpose mentioned in this Privacy Policy. These third parties may include but not limited to Licensed Credit Bureau (to carry out credit valuation/scoring), regulators e.g. OJK, authorities e.g. DGT, PPATK, POLRI, or other relevant government institutions, data storage service providers, call center service providers, payment system provider or payment gateway provider.

Moreover, in order to improve Your experience in using SkorLife Platform, and traffic optimization during access by User, We will also track Your behavior using analytical tools. These analytical tools will be provided by third-party provider that We have engaged, and We hereby reserve the right to add, stop or change existing providers to other third-party analytical tools providers. The information that We have gathered for this purpose will be anonymized and shall not be identifiable to You.

For Our business operations, where Our legitimate interests are no less important than the rights of Data Subject, You agree that Your information, which We will ensure will not be identifiable to You, can be disclosed on and/or disseminated to affiliation or Our group company and third parties such as external company auditors, consultant, survey service providers /data analysis, and investors for the purposes regulated in this Privacy Policy.

In any case, Your personal information will not be disclosed and/or disseminated to any other persons other than the cases of the above three paragraphs and for the purpose of providing the Services, without Your consent, except for the following cases:

• providing that it is required by any applicable law;
• providing that it is necessary for preventing emergencies or protecting others from danger; and
• for the public interest.

In case where We disclose and/or disseminate Your personal information to any third parties, We shall notify the said third parties of its confidential nature and their obligations to restrict the use of such information to any person involved for the permitted purposes as necessary only, and to handle the information appropriately in accordance with this Privacy Policy and comply with the PDP Law in Indonesia.

We may disclose Your personal data concerning the merger, separation, acquisition, consolidation, or dissolution (“Corporate Action”) that We carry out to other parties involved in the Corporate Action. For the avoidance of doubt, if a change occurs in Our business, then any personal data of existing User that have been received, processed, and stored by Us and future User data will then be transferred to the new owner which may use Your personal data in the same way as set out in this Privacy Policy.

In the event of a Corporate Action, We will notify You before and after the Corporate Action is carried out through the SkorLife Platform and/or by sending an e-mail to You.

PROHIBITION OF DISCLOSURE OF USER PERSONAL DATA ABROAD

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

YOUR RIGHTS AS A DATA SUBJECT

Subject to PDP Law in Indonesia, by using SkorLife Platform, receiving Our services and/or purchasing Our products, the protection of Your personal data will cover the following process:

• Rights to Access
  is the User’s Right to gain access to and obtain a copy of personal data about them.
• Rights of Rectification
  is the User’s right to complete, update, and/or correct errors and/or inaccuracies of their personal data.
• Rights to Erasure
  is the User’s right to end processing, delete, and/or destroy their personal data.
• Rights to Withdrawal of Consent
  is the User’s right to withdraw the consent to the processing of personal data about themself that has been given to Us.
• Rights of Restriction
  is the User’s right to delay or restrict the processing of personal data proportionally in accordance with the purposes for processing personal data mentioned in this Privacy Policy.
• Rights to Data Portability
  is the User’s right to obtain and/or use personal data about them from Us in a form that is in accordance with the structure and/or format commonly used or readable by electronic system.
• Rights to Complaint
  is the User’s right to file a complaint with the Institution regarding the processing of personal data which causes the failure of the protection of Your personal data by Us.
• Rights to Object
  is the User’s right to object to decision-making actions based solely on automated processing that have legal consequences or have a significant impact on You.

If You would like to use Your rights as Data Subject, please contact Us at wecare@skorlife.com. The process will take up to 30 (thirty) business days from the date of Your submission.

REFUSAL TO GIVE ACCESS TO YOUR PERSONAL DATA

We may refuse to grant access to changes to Your personal data, if:

• Endanger the safety, physical health, or Your mental health and/or others;
• Impact on the disclosure of other people's personal data; and/or
• Contrary to the interests of national defence and security.

COOKIES INFORMATION

What are Cookies?

Cookies are small pieces of data sent from a website to be stored in Your personal devices. They allow SkorLife Platform to recognize Your devices and collect information to adjust the content to be in accordance with Your preference. We use cookies through third-party service providers to improve Your experience.

What Cookies do We Use?

• User may determine options to do modifications through settings in SkorLife User’s Platform, by opting to refuse cookies (this option may hinder the optimal provision of Our’s Services when the User is accessing SkorLife Platform).
• We use Google Analytics Demographics and Interest feature. Data that will be collected by Us from that feature are as follows: age, sex, User’s interest, and other information that may identify the User, will be used by Us for feature development, facilities, and/or contents within SkorLife Platform.
• We may use features provided by third parties for the purpose of enhancing the Services and content of Us, including among others assessment, adjustment, and provision of advertisement to every User based on interest and visit history.

EXTERNAL LINK

SkorLife Platform may contain links to other websites which We cannot ensure Your privacy and security. The inclusion of such links does not guarantee that other websites will provide You with the same standard of personal data protection as per this Privacy Policy. As such, You are fully responsible on Your decision to access such websites.

NOTIFICATION OF FAILURE TO PROTECT YOUR PERSONAL DATA

If there is a failure to protect Your personal data, We will provide written notification through Your Account and/or registered email address in SkorLife Platform no later than 3x24 (three times twenty four) hours since the failure to protect the personal data occurs.

CHANGES TO THE PRIVACY POLICY

We may make changes or updates to this Privacy Policy at any time to comply with any applicable law. Hence, We encourage You to check the “Updated Date” of Our Privacy Policy.

CONTACT US ABOUT PRIVACY POLICY

If You have any query, comments, or recommendations about the Privacy Policy or if You would like to use Your rights, please submit Your query, comments, or recommendations at wecare@skorlife.com. The process will take up to 30 (thirty) business days from the date of Your request submission.

LANGUAGE

This Privacy Policy is made in Indonesian and English. In the event of any inconsistency or different interpretation between the Indonesian and English version, You agree that the Indonesian version will prevail to the extent of such inconsistency or conflict, and the relevant English version is deemed to be automatically amended to be consistent with the relevant part of the Indonesian version.

GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy and the performance thereof is governed by and construed in accordance with the laws of Indonesia.

The parties agree that in the event of any dispute, conflict or controversy, dispute resolution method stipulated in the Clause “Dispute Resolution” in the Terms of Use shall apply.