PRIVACY POLICY

At Instapay, we respect the privacy rights of our online visitors and users of the Instapay Service and recognize the importance of protecting the information we collect about you. This Privacy Policy explains how we collect, use, share and protect your personal information. It applies both to (1) our website at instapay.id, including any mobile or localized versions and any subdomains (the “Site”), and (2) our “Product”, which is our suite of services and features relating to business management, as more fully described in our Terms of Service (together with the Site, the “Service”). It also covers the treatment of information we may collect from social networks and certain other third party sources as described below.

If you receive an invoice from one of our customers and then come to the Site or otherwise interact with the Service, then you are also considered a user of the Service subject to this Privacy Policy.

Please remember that we provide the Service to small businesses who have their own privacy practices. This Privacy Policy applies only to our own data practices, and not to the practices of third parties that we do not control.

1. Definitions

• “Affiliate” means (i) controlling party of; (ii) subsidiary of; or (iii) party in the same control of PT MCP Indo Utama. "Application" means a software application and/or web portal which we developed to become an electronic medium to (i) create invoice and invoice link by merchants; (ii) facilitate online payment by End Customer; and (iii) other invoice management support features for merchants.
• "Personal Information" means information regarding merchant which can be privately identified and collected through the Application.
• "We" means PT MCP Indo Utama, a company established under the laws of the Republic of Indonesia, and/or its affiliate.
• “Terms of Service” means terms and condition or standard operational procedures or other terms in connection with each Application developed by PT MCP Indo Utama and/or its affiliate (as applicable), as may be amended or supplemented from time to time by PT MCP Indo Utama and/or its affiliate;
• "Service" means various functions and services offered the Application, including but not limited to invoice creation, and online payment.
• “End Customer” means a party whom receive invoice generated by merchant using the Application, and offered to perform online payment.
• "Merchant" means a party who uses the Application to generate electronic invoice.
• "Website" means our website at [the address of] www.instapay.id or other sites which we developed officially to support the Service ecosystem.

2. Types of Information We Collect

The categories of information we may collect include:

• Registration and profile information collected when you sign up for the Service. We may collect personally identifiable information, such as a username, first and last name, phone number, e-mail address, and photo ID, as well as information about your business, when you register for the Service or if you correspond with us. We may also collect information about your interactions with us, including any contact we have with you by telephone, email or online. For service improvement, security, dispute resolution and training purposes we may monitor and record your communications with us (including email and telephone).
• Information collected through Instapay Payments. If you use Instapay to receive payments from End Customers, we may collect certain information regarding your transactions from you or from our Payments Partner. If you are an End Customer paying an invoice through Instapay as described in our Payment Terms, we and our Payments Partner receive certain information as described in Section 6 below (Security of Information We Collect).
• Personal and business information collected through your use of the Service. After you set up an account for the Service and in order to provide the Service to you, we may collect various information through your use of the Service about your business and your customers, for example, your phone number, bank account information, taxpayer identification, or your customers’ mailing addresses or phone number. We use and share information about your customers in the same way we use and share your other information, as described below in Section 4 (Use of Information We Collect) and Section 5 (Sharing of Information We Collect).
• Usage, viewing and technical information collected when you use the Service. Any time you use the Service (even if you do not register for our Service), we may collect information about how you access or use the Service or input data. For more information about how we collect and use this information, see Section 2 (Use of Cookies and Other Technologies) below.
• Information we collect from social networks and other sources. We may receive information about you when you interact with the Service through various social media, for example, by logging in through or “liking” us on Facebook or “following” us on Twitter. The data we receive is dependent upon your privacy settings with the social network. You should always review, and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. In addition, we may receive information about you from other sources, such as referrals from other websites or affiliates, marketing partners or analytics providers, which we also use and share in accordance with this Privacy Policy.

3. Use of Cookies and Other Technologies

We automatically collect certain types of usage information when you access or use the Service. This section provides information about some of the technologies used by the Service and how they work.

• Cookies When you visit the Site, we may send one or more “cookies” — a small text file containing a string of alphanumeric characters — to the device you use that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the Site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allows us to track your usage of the Service over time.
• Log File We may also collect log file information about your browser or mobile device each time you access the Site or use the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. If you elect to provide your contact or other personal information to us during your browsing session, we may link that information to the IP address from which you are accessing the site.
• Clear Gifs We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users and invoice recipients to track which emails are opened and which links are clicked by recipients of those emails. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. Although we do our best to honor the privacy preferences of our users, we are not able to respond to Do Not Track signals from your browser at this time, as we believe that there is no consistent industry standard for how to respond to Do Not Track browser settings.
• Device IDs When you access the Site or use the Service by or through a mobile device, we may receive or collect and store a unique identification number associated with your device (“Device ID”), mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Please note we will not collect your precise geographical location without your consent but we may know the city or country you are in. Similar to IP addresses, we may link any of the contact or other personal information you provide during a browsing session to the Device ID from which you are accessing the Site.

4. Use of the Information We Collect

We use your information in the following ways:

• To provide, maintain and improve the Service and our other products and services, including to operate certain features and functionality of the Service;
• To process your order or inquiries;
• To diagnose or fix technology problems;
• To control unauthorized use or abuse of the Service and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
• To analyze trends, administer or optimize the Service, monitor usage or traffic patterns (including to track users’ movements or actions with the Service) and gather demographic information about our user base as a whole;
• To deliver customer service;
• To settle transaction amount belonging to you to the designated bank account;
• To communicate directly with you by phone, including to respond to customer service inquiries or comments through the Service, on social media or otherwise, and to discuss issues relating to your account or the Service.
• Any use of your information that is incompatible with the foregoing will be disclosed to you in advance so that you may opt out of such use at your discretion.

5. Sharing of Information we Collect

We may share your personally identifiable information with:

• Our parent companies, subsidiaries and affiliates. These companies will use the information in the same way as we can under this Privacy Policy;
• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include content or service fulfillment, or providing analytic, archival, auditing, accounting, legal, business consulting, banking, payment, delivery, data processing, data analysis, research, investigation, website or other technology services;
• The Payments Partner, if you enable Instapay to receive payments from your End Customers. In this case, we provide the Payments Partner with certain information about your business and your use of the Service for its use in underwriting and risk and fraud modeling, subject to the Payment Partner’s Privacy Policy;
• Our business partners who offer a service to you jointly with us, for example, when running a co-sponsored contest or promotion;
• Other users of the Service who have sent you an invoice or with whom you’ve otherwise interacted through the features of the Service. For example, as a customer of one of our users, we may share certain information about you with that user, such as whether you have opened an emailed invoice or made a payment;
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings; and
• Third parties if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) satisfy any law, legal process or governmental request; (ii) enforce our Terms of Service, including investigation of potential violations thereof; or (iii) protect against fraud, imminent harm to the Service or the rights, property or safety of Instapay, our users or the public as required or permitted by law.

6. Security of Information we Collect

• Payment Information: Instapay collects credit card information using a security-enabled, transparent pass-through to our payment processors and does not store full credit card numbers or any CVV2 data itself. Any credit card information you provide is stored by our third party payment processors, who have committed to complying with the Payment Card Industry Data Security Standard (PCI-DSS). Our payment processors use your payment information as follows:
  • Payments to Merchants If you are an End Customer using Instapay to pay a Merchant, then our Payments Partner will use your information as described in its own privacy policy.

  In addition to the above, Instapay may receive (from you or from its payment processors) the name on a credit card, the cardholder postal code, the last four digits of a credit card number and certain other transaction information, which we use in accordance with this Privacy Policy as described in Section 4 (Use of Information We Collect).

• Storage and Processing: Information collected through the Service may be stored and processed in Indonesia or other country in which Instapay or its subsidiaries, affiliates or service providers maintain facilities. You consent to the transfer of information to Indonesia or any other country in which Instapay or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
• Keeping your information safe: Instapay cares about the security of your information, and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Instapay will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
• Password Security: Your password is an important element of our security scheme, and as such, you are responsible for maintaining the confidentiality of your password and account, and are fully responsible for all activities that occur under your password or account. You must report any misuse or compromise of your password to Instapay at the contact address provided in Section 9 (How to Contact Us) as soon as you become aware of any such misuse or compromise.

7. Acknowledgement and Consent

• By using the Application, you acknowledge that you have read and understood this Privacy Policy and the Terms of Service and agree and accede to the use, practice, processing and transfer of your Personal Information by us as stated in this Privacy Policy.
• You also represent that you are entitled to share all of the information you have provided to us and to give us the power to use and share such information to the Merchant (if you are End Customer) or End Customer (if you are a Merchant) to support and perform the function of Application.
• Unless regulated otherwise in the laws and regulation, you may perform your consent revocation of the collection, use and/or disclosure of your Personal Information and/or deletion of your Personal Information, the requirements and procedures of which are pursuant to the laws and regulation specifically regulating this matter.
• Consent revocation or deletion of your Personal Information whether all or in part, may no longer allow you to use our Application and/or Website. You hereby state that you have acknowledged and understood the consequences of the consent revocation and/or the deletion of your Personal Information.

8. Governing Law and Jurisdiction

• This Privacy Policy shall be regulated and interpreted pursuant to the laws of the Republic of Indonesia. Any and all dispute arising from this Privacy Policy shall be regulated by the exclusive jurisdiction of the District Court of South Jakarta.
• This Privacy Policy is made in Bahasa Indonesia and English languages. If there is any inconsistency between the Indonesian and English versions, the Bahasa Indonesia version shall prevail.

9. How To Contact Us

If you have any questions or otherwise need to contact us in connection with this Privacy Policy or the Service, please contact us at:

PT. MCP Indo Utama
Jalan Warung Jati Barat 8A
Kalibata, Pancoran, Jakarta Selatan 12740
Indonesia
Email: help@instapay.id
Telpon: 021-79190513

CHANGES TO OUR PRIVACY POLICY

Instapay may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices or applicable laws, and you should therefore review this page periodically. Your continued use of the Service after changes to this Privacy Policy have been posted will signify your acceptance of such changes.