A. Collection and Collection of User Data

Smarty Indonesia collects User data for the purpose of processing User transactions, managing and expediting the process of using the Site, as well as other purposes as long as permitted by applicable laws and regulations. The User data collected is as follows:

1. Data submitted independently by the User, including but not limited to data submitted when the User:
   • Create or update a Smarty Indonesia account, including username, email address, telephone number, address, photo, etc.;
   • Contact Smarty Indonesia, including through customer service;
   • Fill out a survey sent by Smarty Indonesia or on behalf of Smarty Indonesia;
   • Interact with other Users through message features, product discussions, reviews, ratings, Resolution Centers and so on;
   • Use services on the Site, including detailed transaction data, including type, amount and/or description of the product or service purchased, shipping address, payment channel used, transaction amount, transaction date and time, and other transaction details;
   • Fill in payment data when Users carry out payment transaction activities through the Site, including but not limited to bank account data, credit cards, virtual accounts, instant payments, internet banking, retail outlets; and/or
   • Using features that require access permission to the User's device.
2. Data recorded when the User uses the Site, including but not limited to:
   • Real or approximate location data such as IP address, Wi-Fi location, geo-location, and so on;
   • Data in the form of the time of each User activity, including registration, login, transaction activities, and so on;
   • User usage data or preferences, including User interactions in using the Site, saved options, and selected settings. The data is obtained using cookies, pixel tags and similar technologies that create and maintain a unique identifier;
   • Device data, including the type of device used to access the Site, including hardware model, operating system and version, software, IMEi number, file name and version, language choice, device identifier unique, advertising identifier, serial number, device motion information, and/or mobile network information;
   • Log data, including records on servers that receive data such as device IP addresses, date and time of access, application features or pages viewed, application work processes and other system activities, browser type, and/or party sites or services third party that you used prior to interacting with the Site.
3. Data obtained from other sources, including:
   • Smarty Indonesia's business partners who help Smarty Indonesia in developing and providing services on the Site to Users, including payment service provider partners, logistics or couriers, site infrastructure, and other partners.
   • Smarty Indonesia business partners where Users create or access Smarty Indonesia accounts, such as social media services, or sites/applications that use the Smarty Indonesia API or those used by Smarty Indonesia;
   • Financial service providers, including but not limited to credit rating agencies or agencies or Credit Information Management Institutions (LPIP);
   • Financial service providers (if the User uses specific features such as Smarty Partners);
   • Marketing service providers;
   • Publicly available sources.

Smarty Indonesia can combine data obtained from these sources with other data it has.

B. Data Usage

Smarty Indonesia may use all or part of the data obtained and collected from Users as stated in the previous section for the following matters:

1. Process all forms of requests, activities and transactions made by Users through the Site, including for the purpose of sending products to Users.
2. Provision of features to provide, realize, maintain and improve our products and services, including:
   • Offering, obtaining, providing, or facilitating a service marketplace, insurance, financing, loans, or other products through the Site;
   • Enabling features to personalize Smarty Indonesia Users' accounts, such as Wishlist and Favorite Tako; and/or
   • Carry out internal activities necessary to provide services on the Smarty Indonesia website/application, such as solving software problems, bugs, operational problems, conducting data analysis, testing, and research, and to monitor and analyze trends in usage and activity.
3. Assist Users when communicating with Smarty Indonesia Customer Service, including to:
   • Checking and solving User problems;
   • Directing User questions to the appropriate Customer Service officers to resolve problems; And
   • Monitor and improve Smarty Indonesia Customer Service response.
4. Contacting Users via email, letter, telephone, fax, etc., including but not limited to assisting and/or completing the transaction process or problem solving process.
5. Using information obtained from Users for research, analysis, product development and testing purposes in order to improve the security and security of services on the Site, as well as develop new features and products.
6. Inform Users regarding products, services, promotions, studies, surveys, news, the latest developments, events and others, both through the Site and through other media. Smarty Indonesia may also use this information to promote and process contests and sweepstakes, provide prizes, and present relevant advertisements and content about Smarty Indonesia's services and its business partners.
7. Monitor or investigate suspicious transactions or transactions indicated to contain elements of fraud or violations of the Terms and Conditions or applicable legal provisions, as well as take necessary actions as a follow-up to the results of monitoring or investigation of these transactions.
8. Under certain circumstances, Smarty Indonesia may need to use or disclose User data for law enforcement purposes or to fulfill applicable legal and regulatory requirements, including in the event of a dispute or legal process between the User and Smarty Indonesia.

C. Disclosure of User Personal Data

Smarty Indonesia guarantees that there is no sale, transfer, distribution or lending of your personal data to other third parties, without your permission, except in the following cases:

1. Disclosure of User data is required to partners or other third parties who assist Smarty Indonesia in presenting services on the Site and processing all forms of User activity on the Site, including processing transactions, payment verification, product delivery, and others.
2. Smarty Indonesia can provide relevant information to business partners in accordance with User agreement to use business partner services, including applications or other sites that have integrated APIs or services with each other, or business partners where Smarty Indonesia has collaborated to deliver promotions, contests , or specialized services
3. There is a need for communication between Smarty Indonesia's business partners (such as logistics, payment providers, etc.) and Users in terms of solving problems and other matters.
4. Smarty Indonesia may provide relevant information to vendors, consultants, marketing partners, research firms or similar service providers.
5. Users contact Smarty Indonesia through public media such as blogs, social media, and certain features on the Site, communications between Users and Smarty Indonesia may be publicly visible.
6. Smarty Indonesia can share User information with its subsidiaries and affiliates to help provide services or perform data processing for and on behalf of Smarty Indonesia.
7. Smarty Indonesia can share User data or information needed in the context of creditworthiness to credit rating agencies or bureaus or Credit Information Management Institutions (LPIP).
8. Smarty Indonesia discloses User data in an effort to comply with legal obligations and/or there is a valid request from law enforcement officials.

D. Cookies

1. Cookies are small files that will automatically take place on the User's device that performs the function of storing User preferences and configurations while visiting a site.
2. These cookies are not intended to be used when accessing other data that the User has on the User's computer, other than what the User has agreed to submit.
3. Even though the User's computer device will automatically receive cookies, the User can make the choice to make modifications through the User's browser settings, namely by choosing to reject cookies (this option can limit optimal service when accessing the Site).
4. Smarty Indonesia uses the Google Analytics Demographics and Interest feature. The data we obtain from these features, such as age, gender, User interests and others, will be used for the development of the Smarty Indonesia Site and content. If you don't want your data to be tracked by Google Analytics, you can use the Google Analytics Opt-Out Browser Add On.
5. Smarty Indonesia can use features provided by third parties in order to improve Smarty Indonesia's services and content, including among other things, customizing and serving advertisements to each User based on interest or visit history. If you do not want ads to be displayed based on these adjustments, then you can set them through the browser.

E. User Choice and Transparency

1. Mobile devices in general (iOS, Android, and so on) have settings so that the Smarty Indonesia application cannot access certain data without the consent of the User. iOS devices will provide notifications to Users when the Smarty Indonesia application requests access to the data for the first time, while Android devices will provide notifications to Users when the Smarty Indonesia application is loaded for the first time. By using the application and providing access to the application, the User is deemed to have given his consent to the Privacy Policy.
2. After a successful sale and purchase transaction through the marketplace, Sellers and Buyers have the opportunity to provide ratings and reviews of each other. This information may be publicly viewable with the User's consent.
3. Users can access and change information in the form of email addresses, telephone numbers, dates of birth, gender, address lists, payment methods, and bank accounts through the Settings feature on the Site.
4. Users can withdraw from information or notifications in the form of bulletins, reviews, product discussions, private messages, or private messages from the Admin sent by Smarty Indonesia through the Settings feature on the Site. Smarty Indonesia can still send messages or emails in the form of transaction information or information related to User accounts.
5. To the extent permitted by applicable regulations, Users can contact Smarty Indonesia to withdraw consent for the acquisition, collection, storage, management and use of User data. If this happens, the User understands the consequences that the User cannot use Site services or other Smarty Indonesia services.

F. Retention and Deletion of Information

Smarty Indonesia will store information as long as the User's account remains active and can delete it in accordance with applicable legal regulations.

G. Privacy Policy Update

Smarty Indonesia may change or update this Privacy Policy at any time. Smarty Indonesia recommends that Users read carefully and check this Privacy Policy page from time to time to find out about any changes. By continuing to access and use Site services and other Smarty Indonesia services, Users are deemed to agree to changes in the Privacy Policy.