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Jack Service Agreement
Privacy Policy
Privacy Policy
Last updated: April 9, 2025
EN
ID
Privacy Policy
The following Privacy Policy describes how we, JACK (PT Indo Koala Remittance hereinafter referred to as "We", “Us”, or “Our”) collect, store, use, process, control, transfer, disclose and protect the information and data related to Our service users, including Personal Data, in so far required. As provided under Our Service Agreement, JACK services are provided to legal entities and business entities both being established on the ground of certain deed or otherwise (“Business Entity”). Accordingly, each information and data other than the Personal Data governed under this Privacy Policy shall refer to information and data of each Business Entity registered to in the electronic system of JACK, and Personal Data (as defined hereunder) shall refer to the Personal Data owned by employees or business representative of such Business Entity. This Privacy Policy is created in accordance with all applicable laws, including but not limited to Law Number 27 of 2022 on Personal Data Protection and their implementing regulations.
By accessing and/or using JACK services, each Business Entities and employees or business representatives (hereinafter referred to as “You”) represent that each of Your information, data, documents, and Personal Data is true, complete, and valid, and You give consent to JACK to obtain, collect, store, transfer, manage and use such Personal Data as stated in the JACK Privacy Policy, Service Agreement, and Terms and Condition of Jack services (“Consent”). Your Consent shall remain valid until such time as withdrawn by You in writing or, subject to Article 13, following the termination of Your contractual relationship with Us.
If You have any questions about how We protect or use Your information and data, please send an e-mail and/or WhatsApp to the contact available in this Privacy Policy.
1. Data Protection
1.1.
For the purposes of this Privacy Policy, “Personal Data” means information that identifies or can be used to identify, contact, or locate the person or device associated with that information. Personal Data may include, but not limited to, name, address, date of birth, occupation, telephone number, email address, bank account and credit card details, gender, identification (including passport or national identity document) or other government-issued identification, photos or selfies, nationality, telephone numbers of You and other individuals in Your mobile phone contact list, financial-related information, and biometric information (including but not limited to facial recognition). In addition, to the extent that other information, including personal profiles and/or unique identifiers, is associated or combined with personal data, that information also constitutes Personal Data. Personal Data referred to in this Privacy Policy applied to individuals who are employees or business representatives of the Business Entities to whom JACK provides its services.
1.2.
We are serious about guarding the security of Your Personal Data and use a secure server to store Your Personal Data. All information that You provide to Us is stored on secure servers. Any payment transactions will be encrypted using Transport Layer Security (TLS) technology.
1.3.
However, We must tell You and You understand that there is no system that cannot be infiltrated by unauthorized and irresponsible third parties. Therefore, You agree to waive, release and forever discharge Us from and against any legal action, whether in civil or criminal proceeding in connection with the successful infiltration by the third parties (if any).
1.4.
You shall not disclose Your password to anyone. No matter how effective a technology is, there is no impenetrable security system.
1.5.
Subject to the provisions of Article 6 of this Privacy Policy, we always do our best to maintain the confidentiality of Your information, documents, and Personal data. We restrict access to Your information, documents, and Personal Data to Our employees who have a business reason for knowing such information. We continuously educate and train Our employees about the importance of confidentiality and privacy of Your information (including obtaining certain certifications required by laws and regulations). We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect Your Personal Data from unauthorized access.
2. Information Collection
2.1.
JACK collects Your information, data, and documents (including Personal Data) for the purpose of processing the transaction of JACK users, managing and expediting the process of using the application and/or portal, as well as other purposes in so far permitted by applicable laws and regulations.
2.2.
JACK will conduct face-to-face meetings with each potential User for verification purposes, as required by the applicable laws and regulations. If a direct or physical face-to-face meeting could not be conducted, JACK may require the meeting through technological means (in the form of a video call) or use other means or methods as permitted by the laws and regulations. You shall be required to appoint an authorized representative for this purpose. JACK will maintain any data and information disclosed during the verification process and manage it in accordance with the provisions of this Privacy Policy and the applicable laws and regulations.
2.3.
You agree that for the purpose of the above Article 2.1, We shall collect and use the following data and information:
a.
Information that You give us, with the following conditions.
i.
We will require You to give Us information and data about You to Us when You sign up to use Our services, including Your Business Entity's corporate documents, Personal Data of every employee, directors and business representatives of Your Business Entity who uses JACK services. This also includes information that You provide through Your continued use of Our services, where We may request any additional information and documents related to the legality of Your Business Entity and transactions, participate in discussion boards or other social media functions related to Us, participate in competitions, promotion or survey, and when You report a problem with Our services. The information that You give Us may include Your name, address, e-mail address, phone number, nationality, date of birth, financial information, transaction reason, and photograph.
ii.
We will always consider the information, documents, and Personal Data that You provide as correct, complete and valid information. Any loss that We incur as a result of invalid or incorrect information, documents and Personal Data that You provide are Your responsibility and We reserve our rights to file claims, demands and lawsuits for these losses against You.
iii.
We may also need additional commercial information and/or identification from You e.g. if You send certain high-value or high volume transactions or as We consider are needed to comply with anti-money laundering and counter-terrorism financing obligations under applicable law.
iv.
In the event that You provide information, documents, and Personal Data of other individuals (such as information and documents related to an entity or Personal Data related to it, which may be related to the provision of Your services to third parties which is connected to Our services), You represent and warrant that You have obtained the Consent from such individual(s) regarding the collection, use and disclosure of the individual's information, documents, and Personal Data, for the purposes set out in this Privacy Policy.
b.
Information We collect about You. With regard to Your use of Our services We may automatically collect the following information:
i.
details of the transactions that You carry out when using Our services, including geographic location from which the transaction originates;
ii.
technical information, including the Internet Protocol (IP) address used to connect the computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
iii.
information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our application and/or portal (including date and time); products that Your viewed or searched for; page response time, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our Customer Support number.
c.
Information We receive from other sources. We may receive information about You if You use other websites We operate or other services We provide. We also work closely with third parties and may receive information about You from them, for example, the banks and payment service providers You use to transfer money to Us; Your beneficiary payment service provider; business partners; technical sub-contractors, payment and delivery services; advertising networks; analytics providers; find an information provider; and credit reference institutions.
d.
Information from social media networks. If You log in to Our services using Your social media account (for example Google) We will receive relevant information that is necessary to enable Our services and authenticate You. The social media network will provide Us with access to certain information that You have provided to them, including name, profile image, and email address. We use such information, together with any other information that You directly provide to Us when registering or using Our services, to create Your account and to communicate with You about the information, products and services that You request from us. You may also be able to specifically request that We have access to the contacts in Your social media account so that You can send a referral link to Your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy.
3. Cookies
Cookies are small files that will automatically take place on the Your devices that performs the function of storing You preferences and configurations during a site visit. Such cookies are not intended to be used at the time of accessing other data that You have on the Your computer devices, other than those that You have agreed to convey.
4. Use Made of Information
4.1.
We use your information, documents, and Personal Data in the following ways:
a.
to carry out Our obligations relating to agreement between You and Us (if any) and to provide You with the information, products, and services;
b.
to comply with any applicable legal and/or regulatory requirements;
c.
to notify You about changes to Our services;
d.
as part of Our efforts to keep Our services safe and secure;
e.
to administer Our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
f.
to improve Our services and to ensure that they are presented in the most effective manner;
g.
to measure or understand the effectiveness of advertising We serve and to deliver relevant advertising to You;
h.
to allow You to participate in interactive features of Our services, when You choose to do so;
i.
to provide You with information about other similar goods and services We offer;
j.
to provide You, or permit selected third parties to provide You, with information about goods or services We consider may interest You;
k.
to combine information that We receive from other sources with the information from You that You give to Us and information We collect about You. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).
4.2.
We may also use Your information, documents, and Personal Data in other ways for which We provide specific notice at the time of collection or for which You have subsequently consented.
5. Use of Information
5.1.
We may use information, documents, and Personal Data collected for the following purposes or for other purposes permitted by applicable laws and regulations ("Purposes"):
a.
to identify and register You as a user and to administer, verify, disable, or manage Your business account;
b.
to facilitate or enable any verification that We consider necessary before We register You as a user or before We or Our payment provider partners provide service to You, including conducting the Know Your Customer (KYC) and/or Know Your Business (KYB) process;
c.
to process and facilitate orders and payment transactions that You make, including as applicable, transactions made through payment cards or accounts available on the application and/or portal;
d.
to enable You to provide services to Your users, in the event that You provide services to other parties connected to Our services;
e.
to check and resolve users’ issues;
f.
to contact You by email, mail, phone, and others, including but not limited to, to assist and/or complete the transaction process and the process of resolving obstacles.
g.
to monitor or investigate suspicious transactions or transactions indicated to contain elements of fraud or violation of Our Service Agreement and/or Terms and Conditions of Our services or applicable laws, as well as taking the necessary actions as a follow-up to the results of monitoring or investigating such transactions.
h.
to process and respond to inquiries and suggestions received from You;
i.
to maintain, develop, test, improve and personalize the application and/or portal to meet Your needs and preferences;
j.
to monitor and analyze user activity, behavior and demographic data including habits and use of various services available on the application and/or portal;
k.
to offer or provide services from Our affiliates or partners (as applicable); and
l.
to send direct or focused marketing communications, advertisements, vouchers, surveys and information, and information about special offers or promotions to You.
5.2.
If We need to collect information, documents, and Personal Data based on the laws and/or based on other terms binding between We to You, and You choose not to provide such information, documents, and Personal Data or to provide incomplete information, documents, and Personal Data to Us, We have the right not to provide Our services to You. This in all respects shall not be an event of default and You will release Us from any demands, claims, lawsuits related to this matter.
6. Disclosure of Your Information
6.1.
We may share Your information with selected third parties including:
a.
Affiliates, payment provider partner, business partners, suppliers, vendors, and sub-contractors for the performance and/or execution of any contract We enter into with them or You, including for the purposes of providing services to You, implementing KYB and KYC, and monitoring transactions;
b.
Financial institutions, banks, collection agents and credit agencies; (i) to comply with credit card association rules requirements to be included in the list of discontinued users (ii) to comply with their anti-money laundering and counter financing requirements of terrorism or (iii) if We believe that disclosing Your information is necessary to help Us prevent fraud or assess and manage operational or financial risks.
c.
Law enforcement, regulators, government officials, or other third parties in accordance with subpoenas, court orders, inquiry or investigative orders, official order of document disclosure, notices and regulatory guidelines, or legal proceedings or other requirements applicable to Us or any of Our payment service provider partner or affiliates when We need to do so to comply with law or credit card rules or when We believe, based on Our own discretion, that disclosure of information, documents, and Personal Data is necessary to prevent physical loss or financial loss, to report suspected illegal activity or to investigate violations of Our Service Agreement and Terms and Conditions of Our services.
d.
Advertisers and advertising networks solely to select and serve relevant adverts to You and others;
e.
Analytics and search engine providers that assist Us in the improvement and optimization of Our site;
f.
Our group entities or subsidiaries; and
g.
Entities involved in any merger, acquisition, financing transaction or joint venture with Us.
6.2.
We may disclose Your information, documents, and Personal Data to third parties:
a.
in the event that We sell or buy any business or assets, in which case We may disclose Your information, documents, and Personal Data to the prospective seller or buyer of such business or assets;
b.
if We are under a duty to disclose or share Your information, documents, or Personal Data in order to comply with any legal obligation, to comply with an order to an inquiry or investigation to an alleged criminal act, or in order to enforce or apply Our agreement and other applicable agreements; or to protect the rights, property, or safety of JACK, Our customers, or other party. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
c.
to assist Us in conducting or co-operating in investigations of fraud or other illegal activity where We believe it is reasonable and appropriate to do so;
d.
to prevent and detect fraud or crime;
e.
in response to a subpoena, warrant, court order, or as otherwise required by law;
f.
to assess financial and insurance risks;
g.
to recover debts or in relation to Your insolvency; and
h.
to develop customer relationships, services, and systems.
7. Access and Correction of Personal Data
7.1.
Subject to applicable laws and regulations, You may request that You access and/or correct Your information, documents, and Personal Data under Our control, by contacting Us in the details provided below.
7.2.
We reserve the right to refuse Your request to access, or to correct, some or all of Your information, documents, and Personal Data that We control and process where permitted or necessary under applicable law. This includes in circumstances where such information, documents, and Personal Data may contain references to others or where requests for access or requests to correct are for reasons We consider irrelevant, not serious, or troubling.
7.3.
To avoid doubts, We are not obliged to accept Your request to access and/or correct information and documents related to Business Entities, as long as this is not related to Personal Data and is permitted by law.
8. Limitation of Liability
8.1.
You are responsible for security and implement appropriate safeguards in safeguarding Your information, documents, and Personal Data such as limiting access, creating strong passwords, safeguarding passwords, updating passwords from time to time (as necessary), and/or maintaining One-Time Password (OTP).
8.2.
We are not responsible for the exchange and/or provision of Your information, documents, and Personal Data by Yourself to other party(s), including what You do through Our application and/or portal. By continuing to access Our services, You waive the rights to any claim, loss, demand and lawsuit that You may have in the event of a failure to protect the information, document, and Personal Data arising from any negligence committed by Yourself or Your business representatives in maintaining the security and confidentiality of information, documents, and Personal Data and/or resulting from actions of third parties who seek to obtain information, documents, and Personal Data in the way that is against the law.
8.3.
Our application and/or portal may contain links to other platforms managed by third parties. In the event that You use the link, You must understand that We have no control over such other platforms, so You represent and warrant that We shall not be held responsible for the privacy policies of such third-party platforms based on the link and therefore advise You to read the privacy policy of each platform that You visit.
8.4.
We are only responsible for the protection and security of Your information, documents, and Personal Data being stored in a system developed and managed by Us. We will always carry out and take any reasonable steps necessary to protect and protect Your information, documents, and Personal Data.
8.5.
We are not responsible for the originality, authenticity, correctness, accuracy and/or completeness of the information, documents, and Personal Data provided by You.
9. Your Personal Data Storage Location
The information, documents, and Personal Data that We collect from You shall be managed, transferred and stored in the jurisdiction where We collect such information, document, and Personal Data from, as regulated by applicable law. By submitting Your information, documents, and Personal Data, You agree to this transfer, storing or processing. We will take all reasonably necessary steps to ensure that Your data is treated securely and in accordance with this Privacy Policy. We may also retain Your information, documents, and Personal Data for as long as We deem necessary to comply with the Purposes, the terms of this Privacy Policy or in accordance with any applicable laws.
10. Jurisdiction and Transmission of Data Across Borders
10.1.
In order to provide Our services to You, it is sometimes necessary for Us to transfer Your data to the third parties that are based outside the jurisdiction where We collect the information, documents, and Personal Data from. In these cases, We ensure that We and Our partners shall take adequate and appropriate technical, physical and organizational security measures to protect Your data. We also ensure We have appropriate contractual protections in place with these third parties.
10.2.
We may store and process Your information, documents, and Personal Data in the countries where We operate or where We engage service providers, and We may transfer data to countries outside Your country of residence, which may have data protection rules that differ from those in Your home country. However, We will take steps to ensure that any transmission of such data complies with applicable data protection laws and that Your information, documents, and Personal Data remains protected by the standards set out in this Privacy Policy. In certain circumstances, courts, law enforcement officials, regulatory agencies or security authorities in these other countries may be entitled to access Your information, documents, Personal Data.
11. Profiling and Automated Decision Making
11.1.
We may use some instances of Your data in order to customize Our services and the information We provide to You, and to address Your needs such as country of address and transaction history. For example, if You frequently send funds from one particular currency to another, We may use this information to inform You of new product updates or features that may be useful for You. When We do this, We take Our best effort to ensure that Your privacy and security are protected, and We only use pseudonymized data wherever possible.
11.2.
As part of being a highly technical and innovative company, We may use Automated Decision Making (ADM) in order to improve Your experience or to help fight financial crime. For example, so that We can provide You with fast and efficient services, We may use ADM to verify Your identity documents or to confirm the accuracy of the information that You have provided to us. None of Our ADM processes have a legal effect on You.
12. Your Rights and Obligation
12.1.
You have the right to ask Us not to contact You for marketing purposes by contacting Us via the contact available in this Privacy Policy or by adjusting the notification preferences.
12.2.
You have the obligation to correct any information, documents, and Personal Data that We hold on You that is inaccurate, incorrect, or out of date.
12.3.
You also represent that You have the right to share all information that You have provided to Us and to give Us the right to use, change, and/or delete the data You provide that does not correspond to the information You provide.
12.4.
You have the right to ask Us to stop collecting, using, disclosing, and/or delete Your Personal Data when it is no longer necessary or no longer subject to a legal obligation to which JACK is subject to, and You have the right to withdraw Your Consent (whether in part or in whole) at any time in writing to Us via the contact provided in this Privacy Policy. Upon the receipt of Your written request, We will inform You of the consequences of such withdrawal, and We will cease to collect, use or disclose Your Personal Data in accordance with this Privacy Policy. Notwithstanding the above, You agree that We may continue to use and disclose Your information, documents, Personal Data for the Purposes, for a reasonable period of time after the termination of the contractual relationship with Us.
12.5.
You have the right to transfer Your Personal Data between data controllers, for example, to move Your business account details from one online platform to another.
12.6.
Our Services may, from time to time, contain links to and from the websites of Our partner networks, advertisers, and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies, and that We do not assume any responsibility for them. Please check these policies before You submit any Personal Data to these websites.
13. Closing and Blocking Account
13.1.
Upon Your request, We will close Your business account and use of JACK services with Your business account. In addition, if in Our consideration, things happen that are detrimental and/or can harm Us or You, We will also block Your business account. Nevertheless, We provide You with a path to file a complaint in accordance with the terms of this Privacy Policy.
13.2.
Business account blocking may occur including due to, but not limited to, the following events:
a.
Your report that Your business account was stolen or hacked.
b.
Blocking orders issued by government or monetary institutions or based on court orders.
c.
Use of Your business account and/or JACK services in a manner contrary to this Privacy Policy and other terms that JACK may govern, the JACK Service Agreement, Terms and Conditions of Our services, and any applicable laws and regulations.
d.
Other reasons that harm You or Us, including abusive and fraudulent actions or when Our system catches suspicious patterns of financial transactions.
e.
If Your business account is blocked and You have strong evidence that nothing suspicious has happened, You may file Your complaint as stated in JACK Service Agreement as well as Terms and Conditions of services. After checking Your complaint, We may determine whether to terminate or continue blocking Your business account. Blocking will not be continued unnaturally if We decide that the things that resulted in the blocking have ended.
13.3.
Your business account may be closed due to the following:
a.
Your request, if You have never made a transaction. If You have made a transaction, then Your business account will be unverified but cannot be closed because according to the regulation, Your business account must be stored for 5 (five) years.
b.
Our policies are based on applicable laws and regulations.
c.
Force majeure occurring for 3 (three) months or more in a row; and/or another reason for blocking accounts.
d.
Other reasons in connection with business account blocking.
e.
We will refund Your money (if any) through a mutually agreed method between the parties, after deducting the fees owed (if any), unless in Our sole consideration withholding of a certain part of Your money is required, for example due to a reasonable belief that such part is related to or resulting from fraud and/or other violations of the law.
f.
Your business account will be terminated automatically or closed when You close Your business account.
14. Changes to Our Privacy Policy
14.1.
We reserve the exclusive right to change, amend or revise this Privacy Policy from time to time.
14.2.
Any changes We may make to this Privacy Policy will be posted on JACK application and/or portal, and, as appropriate, notified to You via a notification in Your application. Please check back regularly for updates or changes to Our Privacy Policy.
15. Others
15.1.
This Privacy Policy is made, implemented, subject to and interpreted based on the laws of the Republic of Indonesia.
15.2.
All disputes between you and us arising from this Privacy Policy and the provision of our services will be resolved at the administrative office of the South Jakarta District Court. However, you and we agree that we will do whatever is necessary to resolve the dispute amicably.
15.3.
This Privacy Policy has been prepared in English and Indonesian. If there is a conflict between the English and Indonesian language versions of this Agreement, the Indonesian language version shall prevail for all purposes and supersede all language differences.
16. Contact
16.1.
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@itsjack.com
16.2.
If You feel that We have not addressed Your questions or concerns adequately, You may make a complaint to Our Customer Service support.
17. Recognition and Approval
By agreeing to the Privacy Policy, You acknowledge that You have read and understood this Privacy Policy and agree to all its terms. In particular, You agree and consent to Us collecting, using, sharing, disclosing, storing, transferring or processing Your information, documents, and Personal Data in accordance with this Privacy Policy.
If there are provisions or parts of this Privacy Policy that are unlawful, cannot be applied or become invalid, then those provisions or parts will be deemed removed from this Privacy Policy and We will adjust these provisions so that they can be implemented, where the other provisions of this Policy will remain fully applicable
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