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Privacy Policy

This privacy policy explains how KoinWorks collects and uses the personal data you have submitted to us. Your privacy and the protection of your sensitive personal information is very important to us. Because we collect and/or store certain types of information from and about you, we need to explain our policies and terms and conditions surrounding the collection and use of such information.
  1. Employee Behavior
    KoinWorks applies full commitment to integrity and corporate values and ethical standards and business conduct that are also required of all our employees. KoinWorks Code of Conduct regulates procedures regarding the security of specific confidential information, including customer information. In general, these guidelines limit employee access to confidential information and restrict the use and disclosure of information, especially regarding approved and ongoing transactions and processes. If we become aware of an employee violating the Code of Conduct, corrective action may be taken by the company, including dismissal.
  2. Data Practitioner Verification
    Periodically, our business activities and practices will be reviewed to check whether they are in accordance with procedures and policies governing the confidentiality of information. These checks may be carried out by our own internal staff, external accounting and audit services, and the government. This includes an assessment of consumer protections related to privacy.
  3. What does KoinWorks do with your personal information?
    We collect financial and personal information from you when you use our website and most of the information is obtained when you register and upload your data. We also collect data from social media accounts that you allow us to access. We also obtain data from the time you are on our page. These data include, but are not limited to, your computer, geographic information, IP address, referral source, length of time you have been on the page, period of visit, page views and clicks. This collection of information is mostly used to improve the performance and security of the Platform.
  4. What is the reason why KoinWorks asks for your personal information?
    We require all users to submit basic information to facilitate the process of verifying your identity as regulated by the laws of the country, communicate you, ensure that you are of legal age and reduce the potential for fraud. We will only use personal information to provide services to users and will not share such data with third parties without the consent of our users. We request optional additional data but it must be filled in to enable us to provide additional services to users. This includes determining borrowers’ eligibility for their loan applications through our credit-scoring process, creating user-based communities on our platform and carrying out necessary data collection activities.
  5. Is my data safe?
    1. Access
      2. KoinWorks takes great care in our business practices so that the data you send to us is secure. If deemed necessary and appropriate by us and in accordance with applicable laws, rules and regulations, Personal Data will only use personal information to provide services to users and will not share such data with third parties without the consent of our users, including:
      1. provide access to you and facilitate the use of our Site and ensure that site content, products, services, are displayed in the most effective manner for you and your Device;
      2. provide you with information, site content, products, services you request from us and access to Third Party Sites and Third Party Content;
      3. carry out our obligations arising from any contract entered into between you and us;
      4. provide you with information about other Products and Services we offer that are similar to the Products and Services you have purchased or inquired about;
      5. provide you, or allow Selected Third Parties to provide you with information about Products or Services that we feel may be of interest to you. If you have become a User, we will only contact you by email, SMS or telephone to provide Information about Products and Services similar to those you have previously considered, funded or utilized. If you are a new customer, and if you agree to disclose your Personal Data to Selected Third Parties, we (or Selected Third Parties) may contact you via email or SMS to provide information about the Products or Services;
      6. notify you of changes in site content, products, services;
      7. administering our Site and for its internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      8. improve our Site to ensure that site content, products, services are delivered in the most effective manner for you and your Device;
      9. allow you to participate in the Interactive Services and other interactive features of our site content, products, services, if you choose to do so;
      10. implement and review security and protection measures on our Site so as to keep our Site safe and secure;
      11. assess or understand the effectiveness of our advertising and third party advertising on our Site and on other third party websites, and to deliver relevant advertising to you;
      12. make suggestions and recommendations to you and other Users of our Site about Products, Services or third party products and services that may be of interest to you or them;
      13. make decisions relating to the opening or continuation of the User’s account(s) and the creation, provision or continuation of the Service(s) and Product(s) in addition to maintaining accurate “know your customer” information and conducting anti-money laundering, credit and background checks;
      14. provide, operate, process and manage User’s account(s), Service(s) and Product(s) or manage applications for User’s Account(s), Service(s) and Product(s), any transactions (including money transfer transactions), and maintain service quality and train staff;
      15. carry out activities related to the provision of User’s account(s), Service(s) and Product(s), including subscriptions or proposed subscriptions to Product(s) or Service(s) (whether offered or issued by Bitvault or others) and the provision of research reports or materials for analysis;
      16. provide services and support related to the Product, including but not limited to, providing management or administrative support or acting as an intermediary/nominee/agent in connection with your participation in the Product(s);
      17. provide or provide access to Product-related materials such as offer documents, research reports, product profiles, fact sheets, term sheets or other product-related materials;
      18. comply with domestic and foreign legal, regulatory and compliance requirements applicable to Bitvault under applicable laws (including anti-money laundering and tax obligations applicable to KoinWorks, and disclosures on any stock exchange, court, governmental authority, supervisory authority or other regulator in accordance with any relevant guidelines, regulations, orders, directives or requests of such organizations) and comply with any international agreements or agreements applicable with or between foreign and domestic governments applicable to KoinWorks;
      19. check the identity and/or authority of your attorneys who contact KoinWorks or can be contacted by KoinWorks and to carry out or respond to requests, questions or instructions from the inspected attorneys or other parties in accordance with our applicable security procedures;
      20. conduct risk assessment, statistical and trend analysis and planning, including carrying out data processing, statistical analysis, credit, risk and anti-money laundering, creating and managing credit scoring models, conducting credit and other background checks and reviews, and storing your credit history and your valid power of attorney (regardless of whether there is a direct relationship between the authorized power of attorney and KoinWorks or not) for current and future reference;
      21. monitor and record calls and electronic communications with you for recordkeeping, quality, training, investigation and fraud prevention purposes;
      22. detect, prevent, investigate and prosecute crime and fraud including assisting in any investigation of crime by relevant authorities against you, the Relevant Individual or any other person;
      23. enforce (including, but not limited to, collection of amounts owed to KoinWorks) or defend the rights of KoinWorks, derived from contract or otherwise;
      24. conduct internal management to operate control and management information systems and conduct internal audits or permit the conduct of external audits;
      25. enable the actual or proposed assignee of KoinWorks, or the participant or sub-participant of KoinWorks rights with respect to you, to evaluate transactions that are intended to be the object of transfer, participation or sub-participation;
      26. comply with contractual arrangements by or between autonomous industries, industry bodies, industry provider associations or other institutions similar to KoinWorks; and
      27. manage KoinWorks’ relationship with you, which may include providing information to you or Relevant Individuals, about KoinWorks products and services, if specifically approved or where permitted under applicable laws and regulations;
      28. to market financial or loan-related products or services through various modes of communication including mail, telephone, SMS, fax, email, internet, market research, and design or screen similar products or services including by conducting market research, data analysis, and surveys;
      29. comply with any obligations, requirements, policies, procedures, assessments or arrangements for sharing data and information in KoinWorks and the use of other data and information pursuant to any KoinWorks program for sanctions fulfillment or prevention or detection of money laundering, terrorist financing or other unlawful activities.
      As the purposes for which we may collect, use, disclose or process your Personal Data depend on the circumstances at the time, such purposes may not appear in the above clause. However, we will notify you of such other purposes at the time of requesting your consent for the collection of such Personal Data, unless the processing of your Personal Data without your consent is permitted by law. We may also share Personal Data with Selected Third Parties including:
      1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
      2. advertisers and ad networks that need data to select and provide relevant ads to you and others. We do not disclose information about identifiable individuals to advertisers, but we may provide them with aggregate information about our Users (for example, we may tell them that 500 men under the age of 30 clicked on their ads on a given day). We may also use this aggregate information to help advertisers reach the types of audiences they want to target. We may use information or data collected from you to enable us to fulfil the wishes of our advertisers by showing their advertisements to targeted audiences;
      3. analytics and search engine providers who assist us in the improvement and optimization of our site;
      4. prospective seller or buyer of a business or assets in the event that we sell or buy any business or assets, in which case we may transfer your Personal Data to such buyer or seller as part of the transaction;
      5. any such organization or person, if we are under an obligation to disclose or share your Personal Data to comply with any legal obligation, or to enforce or enforce our Terms of Use, our Cookie Policy, and other agreements, or to protect the rights, assets, or security of Bitvault, our customers, Users or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
      6. agents, contractors or third party service providers who provide bookkeeping, administration, postal delivery, telemarketing, direct sales telecommunications, call centers, business processes, travel, visas, knowledge management, human resources, data processing, information technology, computers, payments, debt collection, credit references or other background checks or other services to KoinWorks in connection with the business operations of KoinWorks;
      7. persons or entities that are part of the KoinWorks Group even if only to the extent necessary to fulfill the relevant Permitted Purpose;
      8. interested or withdrawing banks in respect of any cheque or equivalent processed by KoinWorks;
      9. financial institutions with which you own or propose to have affairs in relation to any Products and/or Services;
      10. persons or entities to whom KoinWorks is obligated or required to make disclosures pursuant to legal process or under the requirements of any law, regulation, domestic and foreign court order or agreement entered into, which is binding or applicable to Bitvault and any governmental authority, domestic or foreign, or between two or more governmental authorities at home or abroad, or any disclosure based on and for the purpose of guidelines or instructions provided or issued by law enforcement agencies, regulations, government agencies, tax authorities, law enforcement agencies or other authorities, or autonomous regulations of industry bodies or associations of financial service providers or stock exchanges required or expected to be fulfilled by KoinWorks, or any disclosure pursuant to any contract or other commitment of KoinWorks with the agency laws, regulations, governmental bodies, taxes, law enforcement agencies or other authorities, or autonomous bodies or industries or associations of financial services providers, or stock exchanges, all that may be within or outside Singapore including disclosures to courts, tribunals, and/or legal, regulatory, tax and governmental bodies, regardless of legal process, obligations, requests, such terms, agreements or guidelines are currently in existence or made in the future;
      11. financial institutions, process agents, or other parties who will be involved in money transfer transactions or any banking/financial activities;
      12. actual or proposed transferee of KoinWorks, or participant or sub-participant or transferee of KoinWorks rights with respect to You or another Relevant Individual, all or part of the assets or business of KoinWorks; and
      13. a party who grants or undertakes to provide any third party warranty or guarantee to the recipient of the warrant or guarantee the obligations of you or those of any Relevant Individual.
      We request optional additional data but it must be filled in to enable us to provide additional services to users. The User understands that the User has authorized the Company to collect information about the User, including but not limited to the User’s gallery, storage, camera, location, microphone, IP address and hardware since the User visited and accessed the Platform Only a limited number of our staff have access to user data and most of them only have access to certain parts of the data necessary to perform their tasks as part of our services. Our staff are not allowed to transfer or bring out data from our servers.
    2. Storage
      3. We consult with financial security service providers and implement technical safeguards such as encryption, two-factor authentication, and regular monitoring to ensure that your information is protected and that safeguards are in place to protect the interests of our users.
    3. Reviews
      4. These measures will be reviewed and adjusted periodically based on ongoing risk assessments or security breaches, as no agency can guarantee a truly secure system yet. We also recommend users take certain steps to help protect their information.
    4. Share
      5. Users can choose to add other users to their contact list, or form and join groups with other users to identify and feel comfortable and safe. This allows users to allow some information from each to be viewed by group members and contact lists.
    5. Notification
      6. We may send you notifications from time to time. This is necessary for your transactions on our platform as well as the necessary confirmation of the actions taken. This is to ensure that no one else makes changes to your account without your knowledge. We’ll also send you periodic updates on your account during certain periods. Sometimes we may also send you messages about updates on our platform that may be promotions or changes on our platform that will affect our users.
    6. Situational Cases
      7. In the case of legal process, court order, or proceeding, we may share relevant data with law enforcement or government agencies as required by law. We can also share loan and borrower records as well as any type of payment recorded in the Central Bank of Indonesia system.
  6. Privacy Policy Changes
    As our companies and platforms evolve to better serve our users, we may occasionally make changes to this Privacy Policy as necessary. In the event of substantive or material changes, we will notify you before such changes become effective.

General Terms and Conditions

Last updated: 05 August 2019

Welcome to KoinWorks! Thank you for visiting www.koinworks.com Before using, accessing or utilizing this Platform, please make sure you have read carefully all these General Terms and Conditions.

These General Terms and Conditions contain rules, guidelines, guidelines, notices, policies and instructions relating to the use of the Platform and the Services contained in the Platform. By continuing to access and use this Platform, you declare that you have read, understood and agreed to any and all contents of these General Terms and Conditions.

We will publish any substantial changes or amendments to these General Terms and Conditions (if any) through the Platform and you are required to read carefully any such changes or amendments so that if you continue to use, access or utilize the Platform, you are deemed to have known, understood and agreed to the changes or amendments.

1. Definitions

Unless the context otherwise requires, the terms in the User Terms and Conditions below shall have the following meanings:

a. Company or We are PT Lunaria Annua Teknologi a company that provides a Platform in order to carry out peer to peer lending activities.

b. Service is a space provision service provided by the Company on the Platform to bring together Lenders and Borrowers in order to carry out information technology-based lending activities (peer-to-peer lending).

c. Lenders means a User who uses the Service intending to provide a Loan through the Platform.

d. Borrowers means any User using the Service who intends to receive a Loan through the Platform.

e. Users means any person who visits, accesses and/or uses the Platform.

f. Loan Target is a Loan application from the Borrower placed in the Platform to be offered to Lenders.

g. Loan Target Classification is a Loan Target category based on risk and interest value.

h. Loans means funds provided by the Lender to be addressed to the Borrower through the KoinWorks Account.

i. Loan Target Collection Period means a certain period in the context of collecting Loan funds by one or more Lenders against a Loan Target, which will be determined respectively in the Credit Agreement and included in the description of the Loan Target.

j. Platform is KoinWorks page in www.koinworks.com

k. KoinWorks Account is a special account for peer to peer lending transactions in the form of an escrow account which contains the User’s virtual account .

l. Credit Agreement is a loan and loan agreement between the Lender and the Borrower in connection with the Loan in the context of providing Services provided by the Company.

2. General Terms

By accessing and using the Service as a Lender, you represent that you have read, understood and agreed to be bound by the General Terms and Conditions and the User Terms and Conditions.

In the event of any conflict or difference in interpretation between the General Terms and Conditions and the User Terms and Conditions, then what applies to you is these User Terms and Conditions.

3. User Operational Rules

The User may only use the Services on the Platform through the User’s account. The User understands that in this case to be able to have an account on this Platform, the User must first register.

The flow of operational activities as a User is as follows:

An overview of the steps you need to pay attention to as a User is as follows:

a. The User will register in advance on the Platform by filling in personal data and other required information. The User warrants that the personal data and information submitted by the User are true, accurate, complete, up-to-date and not misleading.

b. Users as Lenders can choose the Loan Target listed on the Platform.

c. One Target Loan can be funded by multiple Lenders.

d. The minimum requirement for the loan value is IDR 100,000 (one hundred thousand Rupiah) per Loan and the loan multiple is IDR 100,000 (one hundred thousand Rupiah).

e. The tenor of the loan repayment along with the interest is determined in the description of each Loan Target.

f. Loans are denominated in Rupiah.

g. There are several types of Loan Target Classifications based on the risk level of the Borrower and the Loan Target, namely risk levels A to E. Risk level A is the Loan Target Classification with the lowest risk (best) and risk level E is the Loan Target Classification with the greatest risk (least good). However, the Company may change the level of Loan Target Classification per each risk level, considering that the Company will continue to improve services in providing true information for Users. The Company will notify any changes to the Loan Target Classification through the Platform.

h. The company transfers the return.

i. The Lender will transfer the Loan through a KoinWorks Account where the Company will forward the Loan to the Borrower, with the following conditions:

  • The Target Loan funding process has reached 100% (the required funds have been met) or at least has reached 80% by the time the Target Loan funding period ends.
  • The Target Loan funding process has reached 100% (the required funds have been met) or at least has reached 80% by the time the Target Loan funding period ends.

j. The Borrower will return the Loan in monthly installments (along with interest) which will be paid to KoinWorks Account. Then, the Company will distribute the loan repayment to each Lender.

k. Lenders can withdraw Loan repayment from KoinWorks Account at any time.

l. The User bears taxes incurred in accordance with applicable tax laws and regulations.

In using the Service as a Lender, the User understands and agrees that:

  • The Company makes no representations, guarantees, promises or guarantees that any funds lent to the Borrower through this Platform will be repaid either in whole or in part;
  • Information provided by the Company in connection with the Service and Loan is an attempt by the Company to provide information about the Loan that is as clear as possible and is not an attempt by the Company to influence Your decision regarding the provision of the Loan;
  • You will conduct a risk analysis independently or use the services of a third party that you appoint for every decision you make through the Platform.

The Company has the right to obtain payment from the Lender for the services of providing the Platform to You in the amount of 1% (one percent) towards each return of the Loan by the Borrower.

4. T+2 Policy

a. To the User, the T+2 Policy will apply, where the Company can only store funds that have been sent by the User for 2 (two) days. To facilitate Users, after 2 (two) days the funds will then be automatically invested into Mutual Fund products managed by PT Mandiri Manajemen Investasi (“Mandiri Investasi”). However, if the User does not agree to the application of the automatic investment to him, then the User must withdraw his funds contained in his Virtual Account every 2 (two) days. In this case, the User is deemed to agree to invest in funds if the funds have not been withdrawn within a period of 2 (two) days. Further provisions regarding the T+2 Policy can be seen here and information provisions regarding products and Mandiri Investasi can be seen atsini.

b. For the Mutual Fund investment, the User will obtain balance details, Net Asset Value and investment history as well as a transaction confirmation letter and monthly report on the Platform.

5. User Terms

In accessing and using the Service as a User, the User represents and warrants that:

a. The User is an Indonesian citizen and domiciled in Indonesia;

b. The User is at least 21 (twenty-one) years old and legally competent to be bound by these User Terms and Conditions and all other agreements with the Company and/or other parties related to the use of the Service;

c. The money used by the User for providing Loans (in the event that the User is a Lender) is not the result of a violation of applicable laws and regulations;

d. The User agrees to authorize the Company to sign all application forms, documents, correspondence and other necessary matters with the Borrower and/or other parties in the context of implementing the Service.

e. If the User is married and does not have a prenuptial agreement, the User has obtained consent from the spouse to use the Service as a User.

6. Registration

In registering/registering as a User through the Platform, the User represents and warrants that you:

a. Use the Platform in good faith;

b. Not utilizing the Platform for purposes that are contrary to the law;

c. Provide true, accurate, complete, current and non-misleading information about you as requested by the Company, including but not limited to, information requested in each registration form contained on the Platform;

d. If the User registers on behalf of an organization, association or company, whether incorporated or unincorporated, the User guarantees that the User is the person authorized to represent the organization, association or company. You also warrant that Users provide true, accurate, complete, up-to-date and non-misleading information as set out in point c above;

e. Maintain password security and User account identification on the Platform;

f. Maintain and update registration data and all other information that the User provides to the Company;

g. Notify the Company of any material changes to information or circumstances that may affect the eligibility of using the User’s account on the Platform;

h. Fully responsible for all information provided to the Company through the Platform;

i. Fully responsible for the use and all actions that the User takes through the User’s account on the Platform.

7. Information Disclosure

The Company will not provide information about Users to other parties. If other Users (both Borrowers and other Lenders) in the context of providing Loans request information about you other than those contained on the Platform, the Company can only provide such information after obtaining the User’s prior consent.

By using the Service as a Lender, the User has the right to:

a. obtain information about prospective Borrowers who will be given Loans available to the Company through the Platform;

b. access the Loan installment history contained in the Company through the Platform.

8. KoinWorks Account

For information technology-based lending transactions (peer-to-peer lending) that occur on the Platform, the Company will provide an escrow account in which the User’s virtual account is loaded.

The Company shall not use the User’s funds held in the Account other than for the purposes agreed in the Lending Agreement.

9. Company Services to Lenders

Users in using the Service as a Lender are entitled to get Services on the Platform as follows:

a. View all Loan Targets on the Platform and determine the Loan Targets that Users will provide Loans;

b. Communicate with other Users. However, any information you provide to such other Users, whether through the Platform or not through the Platform, will be your responsibility and not the Company’s;

c. Change and update your information as a Lender listed on the Platform.

In addition, the Lender may at any time instruct the Company through the Platform to the following:

1. Leave Lender’s money (Loan funds and/or Loan refunds along with interest) in KoinWorks Account as stand-by funds for other Loan Targets no later than 2 (two) Working Days. Further provisions regarding this, please refer to Point 4 of the User Terms and Conditions above regarding the T+2 Policy;

2. Distribute Lender’s money (Loan funds and/or Loan refunds along with interest) in KoinWorks Account for other Loan Targets; or

3. Disburse and transfer Lender’s money (Loan refund along with interest) in KoinWorks Account to registered Lender’s account. Please note that the Lender’s money disbursed as referred to in letter C above is as follows:

  • money belonging to the Lender that has been used to fund the Target Loan, but the Target Loan is rejected (because it does not reach 80% within the funding period of the Loan Target ends);
  • is money that settles in Lender’s KoinWorks Account because it is not used to fund any Loan Target; and/or
  • constitutes a refund of the Loan.

10. Privacy Policy

We respect the protection of User privacy. The User understands that the User can only access some features on the Platform if the User provides and permits some information and/or data to the Company through the Platform.

The User understands that the User has allowed the Company to collect information about the User, including but not limited to the User’s IP address and hardware since the User visited and accessed the Platform.

The Company always asks for the User’s consent first before providing information about the User to other parties. In the event that the User communicates and provides information about the User to other Users, whether through the Platform or not through the Platform, the User is fully responsible for this and is not the responsibility of the Company.

11. Tax Provisions

The User understands that the User has a tax obligation for every transaction that the User makes through the Platform based on applicable laws and regulations. The Company does not provide tax or legal advice to Users in connection with the Loan.

In the event that the User shall consult with an accountant, tax advisor and/or legal advisor regarding the use of the Platform and/or Services, the User shall consult with the User’s own accountant, tax advisor and/or legal advisor.

12. Statement of Power of Attorney

In connection with the implementation of this information technology-based money lending transaction (peer-to-peer lending), the User is willing to authorize the Company which will be stated through a Special Power of Attorney later.

13. Changes to the User Terms and Conditions

The Company reserves the right to amend the User Terms and Conditions at its sole discretion from time to time. All changes to these User Terms and Conditions will take effect immediately after the Company includes them on the Platform. The Company will post the date of the last amendment to the User’s Terms and Conditions on the front page of the Platform and inform the User through the User’s account. The User may terminate his/her membership on the Platform if the User does not agree to the Changes to the User’s Terms and Conditions.

If after the date of the Change in the User Terms and Conditions, the User does not respond and/or continues to make transactions on the Platform, then the User is deemed to understand and agree that when the User continues to use the Platform and continues to carry out activities as a User after changes are made to these User Terms and Conditions, the User is subject to and bound by the new User Terms and Conditions.

14. Indemnification

The User agrees to release, release and indemnify the Company, its affiliates, shareholders, directors, commissioners, employees, sub-contractors, suppliers, agents from and against all forms of claims, suits, claims, losses, damages, including legal consultant fees, caused by violations of these User Terms and Conditions by the User and other provisions stipulated by the Company

15. Company Representations and Warranties

The Company hereby represents and warrants the following:

a. The Company is a Platform provider that facilitates Peer-to-Peer Lending activities and provides lending education to Users.

b. The Company is not a finance company because the concept of Peer-to-Peer Lending is a direct loan provided by Users as Lenders to Users who have Borrower status, but facilitated by the Company as a Platform provider.

c. The Company or Borrower does not issue products in the form of Securities as referred to in Law No. 8 of 1995 concerning Capital Market (“Capital Market Law”) so it is not subject to the provisions regarding the Registration Statement, Public Offering and other provisions regulated in the Capital Market Law.

d. The Company or Debtor does not issue products in the form of Shares as referred to in Law Number 8 of 1995 concerning Capital Market (“Capital Market Law”) so it is not subject to the provisions of the Registration Statement, Public Offering and other provisions regulated in the Capital Market Law.

e. The Company represents and warrants that the KoinWorks Account used by the Company for receipt, payment and repayment of Loans (Escrow Account) is a separate account from the Company’s operational bank account.

f. The Company will only deduct fees for every return and/or every Loan payment that is entitled to the Company, and will not use the funds stored in the KoinWorks Account.

g. The Company declares that any business transactions and activities carried out in connection with the provision of peer-to-peer lending services This will not relate to any actions that may violate laws and regulations related to anti-bribery, anti-corruption, anti-money laundering and countering the financing of terrorism (“Law No. 31 of 1999 concerning the Eradication of Corruption as amended by Law No. 20 of 2001 concerning Amendments to Law No. 31 of 1999 concerning the Eradication of Corruption Crimes, Law Number 8 of 2010 concerning the Prevention and Eradication of Money Laundering”)

16. Best Effort Service by the Company

The User understands that the Company has tried and continues to make every effort to provide Services to Users through the Platform, including but not limited to providing the risk level of the Loan Target Classification based on the Company’s analysis.

The User also understands that the Company’s analysis in determining the Loan Target Classification based on the risk value of each Loan is not a guarantee from the Company of its correctness and accuracy. However, the Company continues to make every effort to improve the accuracy in determining the level of risk.

17. Platform Services and Security

The Company always gives full attention and effort in order to provide the best security and service to Users through the Platform. However, in the event of problems on the Platform beyond the control of the Company, including but not limited to cyber crime, problematic servers , malware, etc., you as the User of the Service agree to release and release the Company to be responsible for such matters.

In the event of problems on the Platform beyond the control of the Company, including but not limited to cyber crime, problematic servers and malware, the Company will improve the Platform in order to maintain the security of User data and Services. For such purposes, it may be possible that the Platform will be temporarily suspended and/or experience delays in the Service process. The User agrees to release and release the Company from all losses arising in connection with the repair process.

You as the User are responsible for maintaining the confidentiality of the User’s personal information needed in the verification process of each User account, both via email and User’s mobile phone. Any negligence on the confidentiality of such personal information is the responsibility of each User, and is not the responsibility of the Company.

18. Limitation of Liability

The User as the Lender understands that there is a risk of default by the Borrower and understands that such failure is entirely the risk of the Lender. However, the Company according to instructions from the User as the Lender may take collection actions (in collaboration with third party collection service providers) to collect the defaulted Loan.

As a Platform provider, the Company’s responsibility is only limited to facilitating the needs and complaints between each User (between Lenders and Borrowers). The Company provides Customer Service facilities within working hours of 09.00 to 18.00 Western Indonesia Time (WIB) to serve Users in the Services provided through the Platform.

19. Governing Law

These User Terms and Conditions shall be governed by and construed in accordance with the laws of the Republic of Indonesia. The User agrees that any legal action or dispute that may arise from, in connection with, the use of the Platform will be resolved exclusively within the jurisdiction of the South Jakarta District Court of the Republic of Indonesia