Effective Date: 17th March 2020

This Privacy Policy (“Privacy Policy”) is incorporated into and is subject to the PT Gaji Pintar Indonesia (“we,” “us,” or “our”) Terms (accessible via www.wagely.app/terms) and describes the information that we gather from you on www.wagely.app (the “Site”), Gaji Pintar mobile application (the “Application”), and related services (together, the “Service”), how we use and disclose such information, and the steps we take to protect such information.


1. Scope of Applicability 

This Privacy Policy applies to activities on the Service provided by us, which may contain features or links to websites and services provided by third parties, and other products and services that may be made available to you through a third-party website (“Third-Party Service”). Any information you provide to a Third-Party Service, is subject to the policies, if any, of their respective operators governing privacy and security, even if accessed through the Service. We have no control over the nature, content, availability, or privacy and security practices of any Third-Party Service or any third-party sites or services which are linked from, or can be accessed through the Service. This Privacy Policy does not cover the links within the Service that link to such other Third-Party Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.


2. The Information We Collect and How We Use It

We collect and process personal information about you for the following purposes:

(a) identification purposes as well as to manage your account, each time you wish to have a Service provided;

(b) customization of your experience, by identifying your preferences so that we can offer a personalized experience (such as language), provide a recommendation of certain functionalities of our Service, products, services, and/or interests; of which may be of interest to you;

(c) operation, maintenance, enhancement and provision of all the features of the Service, for the provision of services and information that you request, to respond to comments and questions and otherwise to provide support to users;

(d) analysis of the usage trends and preferences of our users, improvement of the Service, development of new products, services, features, functionality, performance and participation in studies and develop marketing materials;

(e) contact you for administrative purposes such as customer service, or to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties;

(f) to provide personalized advertisements of our products and/or services, as well as advertisements provided by relevant third-parties service provider; of which we believe may be of interest to you and preference;

(g) to share your personal information to relevant processors and third-parties as necessary for us to provide our Service to you.

With regard to the letter f and g above, we would like to inform you that we have put appropriate safeguards to ensure the security, confidential, protection of your personal information. Kindly refer to data sharing policy in Section 5 below for more detail on this matter.

When you use the Service or a Third-Party Service, we may collect information about you, either directly from you or from the entity that operates the Third-Party Service. Personal information we collect may include:

(a) first name;

(b) last name;

(c) email address;

(d) physical address(es);

(e) phone number;

(f) employee identification number;

(g) employment details;

(h) date of birth; and/or

(i) geographic location.

In addition to the above personal information, kindly note that we automatically collect, store, and process certain types of data which are generated by your interaction with our Service. We automatically process, among other things, the following data:

(a) Internet protocol (IP) address with which your computer or other device is connected to the internet to access our Service;

(b) username, e-mail address, as well as password of your account;

(c) technical information about your computer, device, and connection, for example, type and version of the browser used, plug-ins, operating system, or other relevant setting;

(d) the location of your computer or device of which you use to access our Service;

(e) other usage information about the use of the Service, including a history of the pages you view.

In addition, we may use device identifiers, cookies, and other technologies on devices and our Service to collect browsing, usage, and other technical information. Kindly refer to our Cookie provision in the Section 3 below.

We collect and use the personal information described above in order to provide you with the Services in a reliable and secure manner. To the extent we process your personal data for other purposes, we ask for your consent in advance.


3. Our Cookie Policy

We may use cookies and automatically collected information to:

(a) personalize our Service, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Service;

(b) provide customized advertisements, content, and information;

(c) monitor and analyze the effectiveness of the Service and third-party marketing activities;

(d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and

(e) track your entries, submissions, and status in any promotions or other activities on the Service.


What cookies are we using

In providing our Service and Third-Party Service through our Service, we use the following cookies:

(a) Necessary cookies. This cookie enables core functionality of the Service, such as security, network management, and accessibility.

(b) Analytics cookies. This cookie allows us to improve our Service by collecting and reporting information on how you interact with the Service as well as its functionalities. This cookie interacts with your device or computer in a manner that does not directly identify you as it will only result in an aggregated data.

(c) Third-party cookies. This cookie, in this context, includes search engines, suppliers of analysis services, social media, and advertising companies.

Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. We may use third party cookies on our Service as well. We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Service or who use our Service.


How we use our cookies

When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you.


4. Aggregated Data

At times we conduct research on its customer demographics, interests and behavior based on the personal information and other information provided to us, which may be compiled and analyzed on an aggregate basis and be shared with our affiliates, agents, and business partners. We process this aggregate information in a manner that does not directly identify you as it will only result in an aggregated data.


5. Our Data Sharing Policy

Except as described in this Privacy Policy, we will not disclose information about you that we collect on the Service to third parties without your consent. We only share your personal information in the manner described below to relevant third-party service provider or processors.

We understand and respect the importance of keeping your personal information secure and confidential. Rest assured that we have put appropriate safeguards (e.g., processing agreements and standard operating procedure policy) to make sure that your personal information are adequately protected.

Except as described below, you will receive a consent request from us when we share your personal information with third parties, in which you have the option to indicate whether or not you would like us to do so.

The following are circumstances where we share your personal information:

(a) We share personal information with third parties, including financial institutions that process disbursements of funds or third-party web hosts, who are facilitating the delivery of the Service. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to information that is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. Such third parties must agree to use such personal data only for the purposes for which they have been engaged by us and they must either:

(i) comply with the privacy principles or another mechanism permitted by applicable law(s) for on transfers and processing of Personal Data; or

(ii) agree to provide adequate protections for the personal data that are no less protective than those set out in this Privacy Policy.

(b) We may disclose information about you to your employer in order to enable us to verify your identity and otherwise provide the Service to you.

(c) We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with the prevailing laws and regulations, in response to a court order, judicial or other governmental decree, or to otherwise cooperate with law enforcement or other governmental agencies.

(d) We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

(e) Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

(f) We may make certain aggregated, automatically-collected, or otherwise de-identified information available to third parties for various purposes, including:

(i) compliance with various reporting obligations;

(ii) for business or marketing purposes; or

(iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.


6. Your Choices About Your Information

You do have options regarding the collection, use, and sharing of your personal information. Please note that if you decide not to provide us with the personal information that we request, you may not be able to access all of the features of the Services.

If you wish to access or amend any personal information you have provided to us, you may do so through the Service or through a Third-Party Service, or you may contact us at [email protected] In your request, please note you are writing about “personal information” in the subject or body of the email. Please note that while any changes you make will be reflected in active databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.


7. Marketing Material

Please note that by agreeing to this Privacy Policy, you also agreed to receive marketing email from us, as we explained in section 2 letter e of this document.

You may unsubscribe at any time by following the instructions contained within the email. You may also withdraw your consent for us in sending you marketing email by sending your request to us by email at [email protected] In your request, please note you are writing to “unsubscribe” in the subject or body of the email or correspondence.

Please be aware that if you withdraw your consent in receiving marketing email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request, and you may continue receiving promotional communications from us during that period. After you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us regarding the Service.


8. Security of Your Information

We maintain physical, technical and administrative safeguards to protect your personal information. Our servers are located in Indonesia and to provide you with the Services, we may store, process and transmit information in Indonesia. Personal information may also be stored locally on the device you use to access the Services.

When you submit information to us, your information is protected both online and offline. Wherever we collect personal information, that information is encrypted and transmitted to us in a secure way. While we use encryption to protect personal information transmitted online, we also protect your information offline. We store your personal information using a secure encryption technology and in the computers/servers in which are kept in a secure environment.

Rest assured that we have an adequate internal policy on standard operating procedure in handling your personal information. Only employees who need access to the information to perform a specific job (for example, in order to provide customer service) are granted access to personal information. In addition, we commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.


9. Breach of Personal Information Security

In the event that personal information is compromised as a result of a breach of security, We will promptly notify those persons whose personal information has been compromised in accordance with the notification procedures set forth in this Privacy Policy or any other applicable law.


10. Data Retention

We only retain collected personal information for a limited period of time for as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.

All data in our Service are retained for five (5) years, or any other longer period as required by the prevailing laws and regulations. A customer may request deletion of their data, but certain transaction information must be retained for legal purposes. After five (5) years, personal information is deleted but certain non-specific transactional information is retained.

If you would like to inquire as to what, if any, of your personal information we have or request deletion of any personal information you have submitted to us, please contact us at [email protected] In your request, please note you are writing about “personal information” in the subject or body of the email.


11. Notification

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you by

(a) email notice,

(b) written or hard copy notice, or

(c) through conspicuous posting of such notice on our Service, as determined by us in our sole discretion.

We reserve the right to determine the form and means of providing notifications to you, to the extent permissible by the prevailing laws and regulations.

In regard to notification in the event of security breach, you hereby agreed that we may send the notification to you electronically. We will send such notification with a registered/stamped email or any other electronic means which will ensure that you receive such notification.


12. Changes and Updates to the Privacy Policy

We reserve the right to amend the Privacy Policy at any time, for any reason. We will update and post the amended Privacy Policy on our Service. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner we will let you know, among others, by updating the “Effective Date” at the top of this page.

If you have any questions or comments about this Privacy Policy please contact us by email at [email protected] and please note you are writing about “Privacy Policy” in the subject or body of the email.


13. Language

This Privacy Policy is drawn up in English and Indonesian language. In the event of any inconsistency between the English and the Bahasa Indonesia versions, the English version shall prevail.


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