SM+ Privacy Policy

Personal Data Protection Notice (“PDP Notice”)

The Use of PT SMPlus Digital Investama Services

SM+

PT SMPlus Digital Investama (“SM+”) fully recognizes that Personal Data is a valuable asset and is committed to maintaining the confidentiality and protection of Your Personal Data. PT SMPlus Digital Investama implements protection policies and practices in accordance with the Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection (“PDP Law”).

All website visitors (Personal Data Subjects) hereinafter referred to as “You“.

Please read and understand this PDP Notice carefully so that You understand how Your Personal Data is processed.

This PDP Notice covers the following:

1. Scope of the PDP Notice

This PDP Notice governs the policies and practices implemented by SM+ as the Personal Data Controller in obtaining, correcting, updating, disseminating, displaying, announcing, transferring, disclosing, deleting, and destroying (hereinafter referred to as “Processing”) Your Personal Data.

2. Rights of Personal Data Subjects

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

    • Obtain information about the clarity of identity, legal basis, purpose of request and use of Personal Data, and accountability of the party requesting Personal Data.
    • Complete, update, and/or correct inaccuracies and/or errors in YourPersonal Data in accordance with the purpose of processing the Personal Data.
    • Access and obtain a copy of Your Personal Data in accordance with statutory provisions.
    • Terminate the process, delete, and/or destroy YourPersonal Data in accordance with statutory provisions.
    • Withdraw consent for the processing of Your Personal Data given to SM+.
    • Request us totransfer YourPersonal Data to other Personal Data Controllers, provided that the systems used can communicate securely in accordance with the principles of Personal Data Protection (PDP) based on statutory provisions.
    • Suspend or limit the processing of Personal Data proportionately according to the purposes for which the Personal Data is processed, which will be responded within 3×24 hours.
    • Other rights as stipulated by applicable law, including but not limited to the PDP Law.

3. Personal Data Processed by SM+

SM+ obtain and collect information that identifies and/or can be identified individually or combined with other information directly or indirectly through electronic and/or non-electronic systems.

The Personal Data collected and processed is Your Personal Data provided based on Your direct consent or contractually when registering through www.smplus.com.

The Personal Data required by SM+ includes general and specific Personal Data, including:

    • Full name
    • Mobile number
    • Company name
    • Title
    • Email address
    • Office address

4. Purpose of Processing Personal Data

SM+ collect Personal Data for various purposes permitted by the laws and regulations applicable in the Republic of Indonesia.

In processing Your Personal Data, SM+ have the following purposes (“Purposes”):

    • For marketing needs including sending promotions, new products information, news, surveys, and updates related to SM+ services
    • To comply with statutory provisions
    • To provide services to You
    • To resolve issues related to access to services
    • For business analysis, maintenance, enhancement, development, testing, and personalizing SM+ applications and services to meet Yourneeds and preferences
    • For processing Personal Data to generate Yourprofile data as a Personal Data Subject
    • To invite Youto events organized by SM+
    • Audits
    • Evaluation, bringing or defending legal claims
    • prevention and detection of financial crime, investigation of complaints

Where necessary to fulfil Your (or Your organization’s) instructions to SM+ and for the other purposes outlined above, SM+ may share information about You with a range of recipients including (but not limited to) the following: credit reference agencies, background screening providers, financial institutions, funds, payment recipients, payment and settlement infrastructure providers, exchanges, regulators, courts, public authorities (including tax authorities), branches, affiliates, or subsidiaries of SM+, service providers/personal data processors, professional advisors, auditors, insurers, and potential purchasers of elements of SM+ business.

Where SM+ need to transfer or share Your Personal Data, SM+ will carefully assess the legitimacy, propriety, and necessity of the data sharing. SM+ will comply with and require the recipient to take all the data protection measures required pursuant to the PDP Law and relevant laws and regulations (for instance, signing a contract that defines the obligations of the parties in terms of data protection).

5. Storage of Personal Data

SM+ are committed to storing Your Personal Data with the best protection for as long as necessary to provide the services. Some of the Personal Data may also be managed, processed, and stored by third parties cooperating with SM+ to maintain service performance while adhering to legal and regulatory obligations for access and effective oversight.

SM+ store Your Personal Data as mentioned above for as long as it is needed to achieve the purposes for which the Personal Data was collected, while You still use the Services, or as long as storage is required or permitted by the laws and regulations applicable in the Republic of Indonesia.

SM+ will cease processing Your Personal Data after reviewing the reasons that the collection of such Personal Data is no longer fulfilled with the related Processing, and the Processing is no longer necessary for legal and business purposes, or as requested by You.

6. Processing of Personal Data

The basis for processing Personal Data by SM+ includes:

    • Explicit valid consent from the Personal Data Subject for one or more specific purposes communicated by SM+to the Personal Data Subject
    • Compliance with SM+legal obligations under statutory provisions
    • Fulfilment of other legitimate interests considering SM+ purposes, needs, and balance of interests with the rights of the Personal Data Subject

The Personal Data Subject acknowledges and, if required by applicable Personal Data Protection regulations, expressly agrees that the Personal Data obtained and collected by SM+ can be disclosed to authorized government agencies or other authorized parties based on laws or cooperation agreements, in the following cases:

    • For applicable legal interests and/or to respond to ongoing legal processes.
    • To protect SM+safety, the safety of the Personal Data Subject, or others, or for legitimate interests in the context of:
      • National security
      • Law enforcement processes
      • State administration
      • Interests of monitoring the financial services sector, monetary, payment systems, and financial system stability
      • Aggregated data and its processing for statistical and scientific research purposes in state administration.
      • Emergencies declared by the Government.
    • For internal audit purposes and/or digital forensics for criminal acts or violations of regulations or policies within SM+environment and affiliated compan
    • If necessary, in relation to legal proceedings filed against SM+, officers, employees, affiliates, or other related third parties.
    • To establish, implement, protect, maintain, and enforce SM+legal rights.
    • In processing data, SM+cooperate with other parties either as Joint Data Controllers or Personal Data Processors.
    • In processing Personal Data with SM+ affiliated companies, SM+ will only provide it in good faith in summary form based on legitimate legal interests.
    • To disclose YourPersonal Data to third parties, in order to ensure that SM+ can provide services to You and assist the Government of the Republic of Indonesia and its supporting institutions in performing state functions.

7. Access to Personal Data

SM+ are committed to fulfilling Your right to access the Personal Data that is collected and processed. In fulfilling requests for access to Personal Data, SM+ may deny requests if SM+ find that the request for access to Personal Data meets one or more of the following conditions:

    • Endangers the security or physical or mental health of the Personal Data Subject and/or others
    • Affects the disclosure of Personal Data belonging to others
    • Contradicts the interests of national defense and security

For more information related to requests for access to Personal Data, You can contact the communication channels listed below.

 

8. Correction and Updating of Your Personal Data

If You find inaccuracies in Your Personal Data due to inaccuracy or require updating of Your Personal Data, You may request SM+ to correct, complete, and/or update the Personal Data under SM+ management by contacting the communication channels listed below.

SM+ will make corrections within 3×24 (three times tSM+nty-four) hours from the time SM+ receive the request for data update/correction that You sent.

In the event of inaccuracies in the provision of Your Personal Data, SM+ reserve the right to suspend the service based on SM+ knowledge and considerations.

SM+ encourage You to play an active role in ensuring the accuracy and updating of Your Personal Data.

 

9. Security and Confidentiality of Your Personal Data

The security and confidentiality of Your Personal Data are priorities to SM+SM+ are committed to implementing the best efforts to protect and secure Personal Data from unauthorized access, collection, processing, analysis, storage, disclosure, correction, and deletion.

SM+ continually update these measures, ensuring they align with the latest technology and best practices. While SM+ strive to maintain the highest security standards, no system is completely secure.

In the event of unauthorized access and activities concerning the confidentiality of Personal Data that are beyond Our control, SM+ will promptly notify You at the first opportunity to mitigate the risks arising from the incident. You are responsible for maintaining the confidentiality of Your Personal Data information, including safeguarding Your username, password, email, or OTP (One-Time Password) from anyone and always maintaining and being responsible for the security of the devices used.

 

10. Deletion and Destruction of Personal Data

Based on Our data retention policy, which is ten (10) years or as per Your request, SM+ may delete and/or destroy Your Personal Data from SM+ records so that it can no longer identify You, except in cases where it is necessary to fulfil legal obligations, comply with mandatory retention period stipulated by the statutory provisions, for future proof, audit, and accounting purposes

After SM+ delete and/or destroy Your Personal Data, SM+ will notify You via email at info@smplus.com 

11. Changes to the PDP Notice

This PDP Notice may be updated and/or revised as needed. Any changes made will be announced through our website or other available communication channels. SM+ recommend that You always read this carefully and check this page regularly to be aware of any changes to this policy.

Regarding the use of Your Personal Data by SM+You have the right to:

    • Request a copy of YourPersonal Data
    • Request correction of incorrect data or completion of incomplete data
    • File a complaint with the data protection authority or an independent regulator about the use of YourPersonal Data
    • Request the deletion of YourPersonal Data if it is no longer needed for the intended purpose or if there is no legal basis for processing or if it is not restricted by regulations.
    • Submit a request at any time by sending a reasonable notice through the communication channels provided by SM+.

 

12. Withdrawal of Consent

You can withdraw Your consent for the processing of Your Personal Data for promotional/marketing purposes by contacting Us via email at info@smplus.com. SM+ will process the withdrawal within 3×24 (three times tSM+nty-four) hours from the time SM+ receive the request from You.

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

Note that withdrawing Your consent does not render SM+ prior handling of Your Personal Data unlawful, and that such withdrawal might have an impact on SM+ ability to continue to provide its services or fulfil its obligations in the same way in future.

 

13. Cookie Usage Policy

SM+ use cookies to enhance Your experience on SM+ website, provide personalized ads or content, and analyze SM+ traffic.

This website uses cookies to distinguish You from other visitors to this website. This helps SM+ to provide a good experience when You use the website and also enables SM+ to improve the quality of its services through the website.

You can choose to enable or disable some or all cookies but disabling them may affect Your browsing experience.

 

14.Contact Us

If You have any questions related to this PDP Notice, or have a complaint related to Our services, please contact Us through the following communication channels:

    • Call center: +(62-21)31909111

    • Email: info@smplus.com