1. Purpose and Scope of the Privacy Policy

This Privacy Policy regulates the policies and practices implemented by HORUS as Controller of Personal Data in obtaining, correcting, updating, distributing, displaying, announcing, transferring, disclosing, deleting, and destroying (hereinafter referred to as "Processing") your Personal Data, related to the use of products and/or services, include a versatile payment solutions offering solutions for online transactions, including disbursement, QR code payments, virtual accounts (VA), and bank transfers (hereinafter referred to as "Services").

2. Rights of Personal Data Subjects

As a Personal Data Subject, you have the right to:

• Obtain information regarding clarity of identity, basis of legal interest, purpose of requesting and using Personal Data, and accountability of the party requesting Personal Data.
• Complete, update and/or correct errors and/or inaccuracies in Personal Data about yourself in accordance with the purpose of processing Personal Data.
• Withdraw consent to the processing of Personal Data about yourself that has been given to the Personal Data Controller.
• File an objection to decision-making actions that are based solely on automatic processing, including profiling, which give rise to legal consequences or have a significant impact on the Personal Data Subject.
• Suspend or limit the processing of Personal Data proportionately according to the purposes for which the Personal Data is processed.
• Other rights of Personal Data Subjects related to the processing of Personal Data refer to the applicable laws and regulations.

3. Purpose of Processing Personal Data

In processing Personal Data belonging to Personal Data Subjects, HORUS has the following objectives:

• To carry out Know Your Customer (KYC) principles and provide personalization to Personal Data Subjects regarding the use of services provided by HORUS.
• To carry out statutory regulations.
• To carry out troubleshooting related to access to services.
• For the marketing needs of the services and products offered by HORUS, this includes sending promotions, new products, news, surveys and service-related updates.
• To evaluate and update HORUS service features on an ongoing basis.
• For the needs of processing Personal Data to produce Personal Data Subject profile data.
• To offer advertisements or promotions or offers from other parties who work with HORUS.

4. Personal Data Processed by HORUS

HORUS obtains and collects information that identifies and/or can be identified separately or combined with other information either directly or indirectly through electronic and/or non-electronic systems related to that information which in this case is limited to Services.

Personal data collected by HORUS can be provided by Personal Data Subjects directly or from third parties. HORUS will collect Personal Data in various forms of purposes, including those permitted by the laws and regulations in force in the Republic of Indonesia.

Your Personal Data that will be collected in the implementation of this Service include:

5. Storage of Personal Data

HORUS is committed to keeping your Personal Data with the best protection as long as necessary to provide the Service. Some Personal Data can also be managed, processed and stored by third parties who work with HORUS to maintain Service performance while still complying with obligations for effectiveness of supervision in accordance with applicable laws and regulations.

HORUS will store Personal Data as mentioned above as long as it is needed to achieve the purpose why the Personal Data was collected, while you are still using the Service, or as long as the storage is required or permitted in accordance with HORUS data retention policy and applicable laws and regulations in the Republic of Indonesia.

HORUS will stop storing your Personal Data, or eliminate the ways in which Personal Data can be associated with you, immediately after reviewing the reasons or assumptions that the collection of Personal Data is no longer fulfilled by storing related Personal Data, and storage is no longer required for legal and business purposes.

6. Processing of Personal Data

Personal Data Subjects are responsible for maintaining the confidentiality of details of their Personal Data and must always maintain and be responsible for the security of the devices used to access HORUS Services.

Personal Data Subjects, hereby acknowledges and if required by applicable Personal Data Protection regulations, expressly agrees that the Personal Data obtained and collected by HORUS together with information related to relevant transactions, can be disclosed to authorized government agencies or other authorized parties based on laws or cooperation agreements, in terms of:

• For the purposes of applicable law and/or in response to ongoing legal processes.
• To protect the safety of HORUS, the safety of Personal Data Subjects or the safety of other people or for legitimate interests in the context:
  1. Law enforcement process.
  2. State administration.
  3. The interest in overseeing the financial services sector, monetary, payment systems, and financial system stability.
  4. Aggregate data and its processing are intended for the purposes of statistics and scientific research in the framework of state administration.
• For the purposes of internal audit and/or digital forensics for criminal acts or violations of regulations or policies within HORUS and affiliated companies.
• If necessary in connection with legal proceedings filed against the Bank, officials, employees, affiliates or other related third parties.
• To establish, implement, protect, maintain and enforce the legal rights of HORUS.
• In the context of processing personal data with HORUS affiliated companies, HORUS will only provide it in good faith in the form of a summary on the basis of legitimate interest before the law.
• To disclose your Personal Data to third parties, in order to ensure that HORUS can provide services to you and assist the government of the Republic of Indonesia and its supporting institutions for the implementation of state functions.
• For certain services, HORUS needs to process sensitive Personal Data, such as information related to health, genetics, biometric identifiers, sexual orientation, and so on.

7. Correction and Updating of Personal Data

If you find an error in your Personal Data caused by inaccuracies or you need to update your Personal Data, then you can ask HORUS to correct, complete and/or update your Personal Data which is in the management of the HORUS, by contacting the communication channel set by the HORUS.

In the event that there is an inaccuracy in providing your Personal Data, HORUS has the right to stop services and/or transactions based on the knowledge and considerations of HORUS.

HORUS urges you to play an active role in ensuring the accuracy and updating of your Personal Data.

8. Deletion and Destruction of Personal Data

In accordance with applicable laws and regulations or HORUS data retention policy or at your request / request, HORUS can delete and/or destroy your Personal Data from the system so that the data no longer identifies you, except in the case of:

• If it is necessary to retain Personal Data to fulfill legal obligations, the need for proof at a later date, tax, audit and accounting.
• Personal Data is still in the retention period based on the applicable laws and regulations.

9. Personal Data Security

Confidentiality of your Personal Data is a priority for the HORUS. HORUS group is committed to implementing the best efforts in order to protect and secure Personal Data to collection, processing, analysis, storage, disclosure, repair and deletion by unauthorized parties.

In the event of illegal activities on the confidentiality of Personal Data that are beyond the control of the HORUS, HORUS will immediately notify you at the first opportunity so as to reduce the risks arising from these incidents.

You are responsible for maintaining the confidentiality of your Personal Data information, including maintaining your username, password, email or OTP from anyone and for always maintaining and being responsible for the security of the device you use.

10. Acknowledgment and Approval

This Privacy Policy can be changed and/or updated as needed HORUS urges you to always read carefully and check this page regularly to find out about changes to this policy.

In terms of using User Personal Data, you have the right to:

• Request a copy of Personal Data (HORUS reserves the right to charge a reasonable fee to complete this request).
• Request HORUS to correct incorrect data, or complete incomplete Personal Data.
• Submit a complaint to a data protection authority or other independent regulator about the use of Personal Data.

11. Service Settings

You can choose not to receive marketing services, advertising, or other activities related to the processing of Personal Data, by contacting the HORUS through the communication channels set by the HORUS, or through other mechanisms prepared by each HORUS Service.

If you choose not to receive one service, HORUS still has the right to send messages regarding other HORUS services.

12. Cookie Use Policy

Web applications use cookies to differentiate you from other users of the application. This is to assist HORUS in providing a good experience when you use web applications and also allows HORUS to improve service quality through web applications.

You have the ability to accept or decline cookies by modifying the settings in your browser.

13. Amendment of Privacy Policy

We may update this privacy policy from time to time in accordance with changes in applicable laws or our internal policies. Any changes made will be announced through our website or other available communication channels. Users are encouraged to periodically review this privacy policy to stay informed about how we protect your personal information.

14. Governing Law and Dispute

This Policy shall be governed by and enforced in accordance with the laws of the Republic of Indonesia. We will try to resolve amicably any dispute arising out of or in connection with the provisions of this Policy (including any question of its existence or validity), but if such efforts fail, the Dispute shall be adjusted by agreement of each party using the Law of the Republic of Indonesia.

15. Contact Us

If you have questions or complaints regarding this Privacy Notice, or if you wish to access and/or correct your personal information, please submit your request through the official contact form.

16. References

Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection.