Address: Alamanda Tower Lt. 2 Unit H1, Jl. TB Simatupang, Jakarta Selatan 12430 Indonesia

Registrar of Companies NIB Number: 1508230114744

The objective of TransTrade’s privacy policy is to commit to protecting the privacy of users and customers of our website and services. Please read this carefully, as this policy is legally binding when you use our Services. For the purpose of the relevant data protection regulations, TransTrade is the “data controller” of your information.

This Privacy Policy describes how we collect, use, handle, and, under certain conditions, disclose your personal data when you access our services, which include our content on the website located at io.TransFi.Trade or any other websites, pages, features, or content we own or operate (collectively, the “Website (s)”), or any TransTrade APIs or third party applications relying on such an APIs, and related services (referred to collectively hereinafter as “Services”).

This Privacy Policy also explains the steps we have taken to secure your personal information. Finally, this Privacy Policy explains your options regarding the collection, use and disclosure of your personal information. By visiting the site, you accept the practices described in this privacy policy for the site.

Personal information means any data that relates to a living individual who can be identified from that data, or from that data and other information, which is in the possession of, or is likely to come into the possession of, TransTrade (or its representatives or service providers). In addition to information, it includes any expression of opinion about an individual and any indication of the intentions of TransTrade or any other person in respect of an individual. The definition of personal information depends on the relevant law applicable to your physical location. TransTrade may collect and use the following data about you.

This includes information you provide to us in order to establish an account and access our Services. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services, or is relevant to our legitimate interests described in greater detail below.

The nature of the Services you are requesting will determine the kind of personal information we might ask for but may include:

Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email;

Institutional Information: Employer Identification Number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners;

Financial Information: Payment card primary account number (PAN), transaction history, and/or tax identification;

Transaction Information: Information about the transactions you make on our Services, such as your name, the amount and/or timestamp;

Employment Information: Office location, job title, and/or description of role; or

Correspondence: Survey responses and information provided to our support team or user research team.

This includes information we collect automatically, such as whenever you interact with the Sites or use the Services. With regard to your use of our Services, we may automatically collect the following information:

Details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates;

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser name, type and version, time zone setting, browser plug-in types and versions, operating system, geolocation/tracking details and platform;

Information about your visit, including the authentication data, security questions, full Uniform Resource Locators (URL) click-stream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any email used to contact us.

Cookies and other Technology. Like many websites, the website employs cookies, location-based services, and web beacons (also known as clear GIF technology or “action tags”) to speed up your navigation of the Site, recognize you and your access privileges, and track your usage.

Please read our Cookie Policy below for more information.

We may receive information about you if you use any of the other websites we operate or the other services we provide. This includes information we may obtain about you from third-party sources. The main types of third parties we receive your personal information from are:

Public Databases, Credit Bureaus, and ID Verification Partners in order to verify your identity in accordance with applicable law. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction lists maintained by public authorities, and other relevant data;

Marketing Partners and Resellers so that we can better understand which of our Services may be of interest to you;

The banks/financial service providers you use to transact with us may provide us with your basic personal information, such as your name and address, as well as your financial information, such as your bank account details;

Business partners may provide us with your name and address, as well as financial information, such as card payment information and advertising networks, analytics providers and search information providers may provide us with pseudonymized information about you, such as confirming how you found our website.

We may use your information in the following ways and for the following purposes:

(a) Internal Use: We use your personal information to provide you with our services. We may internally use your personal information to improve the Site’s content and layout, to improve our outreach and for our own marketing efforts (including marketing our services to you), and to determine general information about visitors’ usage behavior to the Site. We may require certain information such as your identification, contact and payment information. Third parties that we use may also access and/or collect your personal information when providing fraud prevention services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. The consequence of not processing your personal information for such purposes is the termination of your account.

(b) Communications with You: According to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing and to share promotional offers. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request via

We may send you service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments relating to your account that may affect how you can use our Services. You cannot opt out of receiving critical service communications.

We also process your personal information when you contact us to resolve any questions or disputes, collect fees, or troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

(c) To maintain legal and regulatory compliance: TransTrade needs to process your personal information in order to comply with security laws. In addition, when you seek to link a payment option to your TransTrade account, we may require you to provide additional information, which we may use in collaboration with service providers acting on our behalf to verify your identity or address and/or to manage risk as required under applicable law. We may be required to disclose certain information in response to requests from law-enforcement officials conducting investigations, subpoenas, a court order, or if we are otherwise required to disclose such information by law. We also will release personal information where disclosure is necessary to protect our legal rights, enforce other agreements, or protect ourselves or others. For example, we may share information to reduce the risk of fraud or if someone uses or attempts to use the website for illegal reasons or to commit fraud. We also process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or fund loss. If you do not provide the personal information required by law, we will have to close your account.

(d) External Use: We disclose information to our service providers to help enable them to perform services on your behalf. For example, in order to process payments, we must share some information with third parties, such as your name, email address, physical address, social security number, date of birth, government-issued identification and the amount of your payments. Similarly, when we obtain credit card or debit card information, a third-party receives that information to process your payment. Even when you ask us to remember your credit card or debit card information, we do not store sensitive payment data such as the entire credit card number and CVV. Rather, we pass the payment data to the third-party processor and receive back from them a token that does not contain the sensitive data. We do retain non-sensitive payment data used to identify a payment, such as the last four digits of a card number and expiration date.

We may share non-personal information (such as the number of daily visitors to the website or the size of an order placed on a certain date) with third parties. This information does not directly personally identify you or any user. For the avoidance of doubt, any IP addresses or a device or other identifier we collect may be shared with one or more third parties.

(e) In our legitimate business interests: Sometimes the processing of your personal information is necessary for our legitimate business interests, such as:

quality control and staff training;

to enhance security, monitor and verify identity or service access, and combat spam or other malware or security risks;

research and development purposes;

to enhance your experience of our Services and Sites or

to facilitate corporate acquisitions, mergers, or transactions.

We allow your personal information to be accessed only by those who require access to perform their work and share it only with third parties who have a legitimate purpose for accessing it. TransTrade will never sell or rent your personal information to third parties without your explicit consent. We will only share your personal information with the selected third parties, including:

Financial institutions that we partner with to process payments you have authorized;

Affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;

Advertisers and advertising networks solely to select and serve relevant adverts to you and others;

Analytics and search engine providers that assist us in the improvement and optimization of our site;

Companies or other third parties in connection with business transfers or bankruptcy proceedings;

Companies or other entities that transact with TransTrade;

Law enforcement, regulators, or any other third parties when we are compelled to do so by applicable law or if we have a good faith belief that such use is reasonably necessary, including to protect the rights, property, or safety of TransTrade, TransTrade customers, third parties, or the public; comply with legal obligations or requests; enforce our terms and other agreements; or detect or otherwise address security, fraud, or technical issues; and

If you authorize one or more third-party applications to access your TransTrade Services, then the information you have provided to TransTrade may be shared with those third parties. A connection you authorize or enable between your TransTrade account and a non-TransTrade account, payment instrument, or platform is considered an “account connection.” Unless you provide further permission, TransTrade will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using TransTrade Services. Please note that third parties you interact with should have their own privacy policies, and TransTrade is not responsible for their operations or the use of the data they collect.

Merchants: If you use your TransTrade account to conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us.

Your financial services providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.

TransTrade will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen security or improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

Our website may contain links to other websites for your convenience or information. These websites may be operated by companies unaffiliated with TransTrade, and we are not responsible for the content or privacy practices of those websites. Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

TransTrade implements and maintains reasonable measures to protect your information. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems.

TransTrade is an international business with operations in multiple countries. This means we may transfer your data to locations outside of your country. When we transfer your personal information to another country, we will ensure that any transfer of your personal information is compliant with applicable data protection laws.

We may store and process all or part of your personal and transactional information, including certain payment information. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

As a condition of employment, TransTrade’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential customer information by a TransTrade employee is prohibited and may result in disciplinary measures.

Finally, we rely on third-party service providers for the physical security of some of our computer hardware. We require those third-party service providers to comply with commercially reasonable security practices and measures. For example, when you visit our website, you access servers that are kept in a secure environment. While we use industry-standard precautions to safeguard your personal information, we cannot and do not guarantee complete security. 100% complete security does not exist anywhere online or offline. As such, you assume the risk of security breaches and all consequences resulting from them. To that end, please safeguard your credentials.

If we anonymize your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.

We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, TransTrade will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

We retain the personal information we collect for as long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses and phone numbers until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

We may use some instances of your data in order to customize our services and the information we provide to you and to address your needs - such as your country of address and transaction history. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymized data wherever possible. This activity has no legal effect on you.

Depending on the applicable law of where you reside, you may be able to assert certain rights related to your personal information. These rights include:

the right to obtain information regarding the processing of your personal information and access to the personal information that we hold about you;

the right to withdraw your consent to the processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so (for example, we may need to retain personal information to comply with a legal obligation);

In some circumstances, the right to receive some personal information in a structured, commonly used, and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal information that you have provided directly to TransTrade;

the right to request that we rectify your personal information if it is inaccurate or incomplete;

the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;

the right to object to, or request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to or ask us to restrict our processing of your personal information, but we are legally entitled to refuse that request;

the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us, and

the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.

Subject to applicable laws, you may have the right to access the information we hold about you. Your right to access can be exercised in accordance with the relevant data protection legislation.

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the website after any changes to this Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically, especially before you provide personal data to us. If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on the home page of the website. The date of the last update of the Privacy Policy is indicated at the top of this document.

Last updated: January 2024

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In a few special cases, we also use cookies provided by trusted third parties. The third-party cookies used by us and their reasons are as follows:

Third-party Analytics: These are used to track and measure the usage of our website so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or the pages you visit, which helps us understand how we can improve the site for you.

Cookies to Test New Features: From time to time, we test new features and make subtle changes to the way the website is delivered. These cookies could be used to ensure that you receive a consistent experience on our site.

Advertisement and Affiliate-tracking Cookies: Several partners advertise on our behalf, and affiliate-tracking cookies simply allow us to see if our customers have come to the site through one of our partner sites. This lets us credit them appropriately and also allows you to enjoy any bonuses they might be offering for the use of their service.

Last updated: January 2024

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