Data Privacy Policy

This Privacy Policy explains the relationship between Simpool and its Members with regard to the acquisition, collection, use, display, announcement, disclosure, opening of access, storage, transmission, provision, transfer, processing, management, destruction, and protection of Personal Data.

This Privacy Policy is included as part of the Terms, such that by using the Simpool Application, you agree to both the Terms of Use and this Privacy Policy. Please read this Privacy Policy carefully to make sure you fully understand it before registering for, accessing, and/or using the Simpool Application.

Collection of Personal Data

Personal Data may be provided directly by you when you register in the Simpool Application or when you use the features within it. Such Personal Data includes, but is not limited to, your name, telephone number, email address, email password, date of birth, place of birth, gender, identity number, tax identification number (NPWP), and other information that may be added from time to time.

We collect as much information as possible regarding the use of the Simpool Application, as well as personal data from various sources, so that we can always provide the best service to users of the Simpool Application over time. This includes data/information originating from Simpool, both new and historical data, intended to make things easier for

Providing your Personal Data is voluntary. If you do not provide accurate information, We will not be able to provide services properly.

Use of Personal Data

We may use and process your Personal Data for business and operational activities and other purposes in line with the purpose for which the Personal Data was provided and with your consent, including but not limited to:

• Validating and processing the services you request.

• Responding to your questions, comments, and feedback.

• Communicating with you through various media such as in-app notifications, email, telephone, text messages (SMS), chat, and social media.

• Simpool's marketing and promotional purposes, such as sending announcements, promotional materials, greetings, invitations to participate, and privileges originating from Simpool, business partners, sponsors, and advertisers.

• Processing your participation in any activities, contests, games, promotions, polls, and surveys.

• Understanding and analyzing usage patterns and sales of products and services in relation to needs and preferences.

• Developing, improving, and providing products and services that suit your needs.

• Internal administrative processes such as audits and taxation.

• All information, whether in the form of images, video, and/or text, submitted and published by users of the Simpool Application will become the property of Simpool.

Provision and Disclosure of Personal Data

For business and operational purposes and other purposes, Simpool may cooperate with third parties in the provision, display, announcement, disclosure, opening of access, transmission, transfer, and management of your Personal Data to those third parties for processing and additional purposes, including but not limited to:

• Research and marketing companies related to promotions carried out by Simpool.

• Information technology (IT) service providers, such as services for infrastructure, cloud computing, software, and development of "Big Data" and "Machine Learning" analytics, including services for "Data Cleansing," "Data Insight," "Credit Scoring," and others.

• Other service providers and Simpool partners related to the features, products, and services offered in the Simpool Application.

• Professional consultants and external auditors, including legal consultants, financial consultants, and other consultants.

• Other entities that are part of Simpool, including in the event of a Simpool transaction such as the creation of a new division, merger, or acquisition.

• Government authorities, both inside and outside the jurisdiction of the Republic of Indonesia, in connection with compliance with legal processes, requirements, laws, and other regulations.

Simpool does not control the privacy policies of these third parties, including Simpool's partners and/or affiliates, and you are subject to the privacy policies of those third parties, as applicable.

Management and Security of Personal Data

Simpool greatly values Personal Data and makes reasonable efforts to protect all personal information and data obtained from Members. Simpool continually strives to improve the standard of protection for members who use the Simpool Application. However, please note that Simpool cannot fully guarantee such security and is not responsible for losses, including but not limited to data loss, arising from incidents beyond Simpool's control. Therefore, with regard to data security, you are strongly advised to always keep the Simpool Application and your software up to date and not to disclose your password to anyone.

Simpool may transmit, store, use, and process the Personal Data of members who use the Simpool Application on servers located in data centers designated by Simpool. These data centers may be located outside the Republic of Indonesia, although efforts will still be made to locate them within the territory of the Republic of Indonesia.

In any case, information and Personal Data of users of the Simpool Application that are collected, used, disclosed, or transferred in connection with the use of the Simpool Application will continue to be governed by this Privacy Policy. We will retain your information and Personal Data until there is a specific request to delete your account.

Updating and Changing Personal Data

You may change the information and Personal Data you have provided to Simpool at any time, including the option to stop receiving communications from Us or to withdraw your consent to the use of your Personal Data, whereby you agree that such withdrawal of consent will affect your access to the Simpool Application services that you can use. You can use the information in the Contact Us section to contact Simpool.

User Agreement

By registering for, accessing, and/or using the Simpool Application, you are deemed to have read, understood, and given your consent to Simpool's Privacy Policy as described above. You also represent and warrant that the information, Personal Data, or funds you provide to Simpool are accurate and lawfully obtained, and that you have the right to provide them to Simpool.

By using the Simpool Application, you agree to delegate your voting rights and exercise them as a Simpool Member through e-RAT, an electronic Member Meeting application system, for both the Annual Member Meeting and other Member Meetings as mandated by Simpool's Articles of Association and Bylaws.

Simpool may change this Privacy Policy at any time by displaying notice of such changes. Your continued access to and/or use of the Simpool Application constitutes your acceptance of and consent to the changes to the Privacy Policy. Therefore, Simpool encourages you to review this page periodically to stay informed about how this Privacy Policy applies at Simpool.

Miscellaneous

This Privacy Policy is governed by and interpreted in accordance with the laws of the Republic of Indonesia, and any dispute arising from this Privacy Policy falls under the jurisdiction of the Tangerang District Court.

In the event of any inconsistency between the Indonesian version and any other language version, the Indonesian version shall prevail.