Privacy Policy
Your personal data is protected.
1. Important information, commitment
In this Privacy Policy we describe how Invetra (“we” or “us”) collects and processes the personal data of its existing and prospective clients. Invetra is comprised of the legal entity, details of which can be found in Section 2 below.
This company controls the personal data of its own clients and is responsible for ensuring that such is used fairly and lawfully. This Privacy Policy is issued for and on behalf of Invetra and each company thereof. This Privacy Policy is addressed to legal and or physical persons who provide their personal data to Invetra and/or visit and/or use Invetra websites, trading platforms, software application, social media and/or any other electronic services (“Electronic Services”). For clarity, ‘personal data’ in this Policy relates to identifiable individuals, including authorised representatives of corporate clients.
At Invetra, we acknowledge that confidentiality and security of your personal data is of utmost importance to you hence we have developed specific policies and practices designed to protect your personal data. Protection of your personal data requires, among others, the establishment by Invetra of appropriate technical and organisational measures as a means to ensure a high level of data protection.
Additionally, Invetra will monitor, audit and document internal compliance with data protection policies and applicable statutory data protection requirements, including local data protection legislation. We are constantly working towards enhancing data protection practices within Invetra such as assignment of responsibilities, raising awareness and training the staff involved in data processing operations.
We process personal data in accordance with Law No. 27 of 2022 on Personal Data Protection (“Indonesian PDP Law”) and other applicable data protection laws and principles. This Privacy Policy will be reviewed and/or amended from time to time to include any new obligations or arrangements in the way we process your personal data as a means to ensure compliance with any applicable laws and regulations. You will be notified of any important amendments to this Privacy Policy through the usual communication channel. Any change to the information required will be notified to you before the change takes effect.
We encourage you to carefully read this Privacy Policy together with any other privacy statement or fair processing notice we may provide you with on specific occasions in the process of collecting or processing your personal data.
It is important that you read this Privacy Policy so that you are fully aware of all logistics regarding your personal data. This Privacy Policy supplements any and all other notices that we may provide you with from time to time and is not intended to override.
2. Who we are and who is responsible for your personal data?
Invetra is responsible for the collection of your personal data in the manner described herein.
Invetra includes the following company and their respective affiliates and providers (collectively the "Invetra Entities" and each an “Invetra Entity”).
Company
PT. INVETRA TEKNOLOGI BERJANGKA
Address
Menara Rajawali Lantai 23, Jalan Dr. Ide Anak Agung Gde, Agung Lot#5.1, Desa/Kelurahan Kuningan Timur, Kec. Setiabudi, Kota, Adm. Jakarta Selatan, Provinsi DKI Jakarta, Kode Pos: 12950
Contact Details
Data Protection Officer: [email protected]
Your personal data will be controlled by the Invetra Entity that provides services to or is in electronic communication with you. In some instances, your personal data will be controlled by and or exchanged between more than one Invetra Entity, as applicable.
Any enquiries about our use of your personal data should be addressed to the above contact details of the Data Protection Officer.
3. What personal data do we collect and process?
Personal data means any and all data relating to an individual, whether identified or capable of being identified independently or incombination with other information, whether obtained directly or indirectly through electronic system and/or non-electronic system and does not include any data where identity has been removed (namely, anonymous data). Upon registration with Invetra, it is necessary that we collect your personal data in order to comply with legal obligations such as KYC and other regulatory requirements. By understanding your background and needs, we can treat you fairly, provide you with the services that best match your requirements, offer you appropriate and relevant information and process your requests in a fair and efficient manner. We will collect, use, store and transfer different kinds of your personal data which we have grouped together as follows:
- Identity Data such as first name, maiden name, last name, proof of identity, username or similar identifier, title, date and place of birth, gender, country of residence and citizenship.
- Contact Data such as billing address, delivery address, email address, telephone number(s), proof of address.
- Professional Data such as level of education, profession, employer name, work experience, financial awareness, trading experience.
- Technical Data such as internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Invetra website and Electronic Services.
- Profile Data such as your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses.
- Usage Data such as information about how you use our website, products, services.
- Marketing and Communications Data such as your preferences in receiving marketing from us and any third-party companies on our behalf and your communication preferences.
We may also collect, store and use the following specific types of Personal Data:
- Tax Data such as country of tax residence, tax identification number.
- Financial Data such as annual income, net worth, source of funds, anticipated account turnover, bank account, bank statements, payment card details and copy thereof, e-wallet information.
- Transaction Data such as details about payments to and from you, information on products and services you have purchased from us, deposit methods, purpose of transactions with us.
Where we process specific personal data, we apply safeguards commensurate with its nature and risk.
Information about criminal convictions and offences
We also collect, use and share aggregated data such as statistical or demographic data. Non-personal data may be derived from your personal data but it is not considered personal data for the purposes of law as such does not directly or indirectly reveal your identity in any way whatsoever. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website and the Electronic Services feature. However, if we combine or connect aggregated data with your personal data in a way that, either directly or indirectly, identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Personal Data of Children
We do not offer our services to persons who are not legally eligible to contract under applicable Indonesian law. We do not knowingly or intentionally collect personal data from anyone under the age of 18, provided that individuals aged 18 to 20 may access our services if they submit a valid guardian consent letter. If we become aware that we have inadvertently collected personal data from a data subject under 18 years of age, or from an individual aged 18 to 20 who has not provided a valid guardian consent letter, we will take immediate steps to delete such data from our records, unless we are required otherwise under the laws and regulations. If you believe that any child under your guardianship has provided us with their personal data, please contact us in accordance with this Privacy Policy so we can address the issue.
4. How do we collect your personal data?
We use different methods for collecting your personal data such as:
Direct interactions. You may give us your identity, contact and financial data by filling in the required registration forms in our website, Electronic Services or by corresponding with us by phone, email or otherwise. This includes, but is not limited to, personal data you provide us when you:
- apply for our products or services;
- make a request under the client agreement;
- create an account on our website, through Electronic Services or use of any of Invetra applications;
- provide as a result of transactions you conduct through Invetra systems or in connection with services offered by Invetra;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback
Automated technologies or interactions. As you interact with our Electronic Services, we may automatically collect
technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies (for further information on our use of cookies, please see our Cookie Policy), server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical data from analytics providers such as Google;
- Contact, financial and transaction data from payment services providers;
- Identity and contact data for KYC purposes from individual and publicly availably sources, such as the registrar of companies, WorldCheck, Thomson Reuters, any consumer-reporting agencies, including, where relevant, sanctions/AML screening databases and KYC verification providers.
We also process personal data generated by us in the course of providing you with our services such as Transaction Data.
5. For what purposes will we use your personal data?
We process your personal data only where we have a lawful basis to do so under the Indonesian PDP Law. The lawful basis including:
- Your explicit consent;
- •Necessity for performance of a contract;
- Compliance with legal obligations;
- Legitimate interests, provided such interests do not override your rights; or
- Other lawful basis permitted under applicable Indonesian law.
Any consent request will be presented in a clear, accessible form in Indonesian language where required, and we will maintain evidence of consent.
We may use your personal data for the following purposes ("Permitted Purposes"), based on the following legal grounds:
TO ENTER INTO OR PERFORM OUR AGREEMENT
By applying for our products or services, or where you create an account or any additional account with us online, you are consenting to the processing of personal data by us in accordance with this privacy policy.
To provide services to you in accordance with the agreement(s) you or your organisation may have with us, for record-keeping and compliance procedures;
To provide you or your organisation with brokerage and other services available on our platforms and/or to deal with any requests or inquiries you may have;
To respond to requests for information from you and to follow up afterwards to see if any further assistance is required.
TO COMPLY WITH OUR LEGAL OBLIGATIONS
To comply with any applicable laws in any country we operate in;
For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
To comply with any legal, regulatory or good practice requirement and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue services from time to time.
TO PURSUE OUR LEGITIMATE INTERESTS
For our own administrative and operational procedures;
For statistical purposes and for market research and product analysis and to develop and improve our products and services;
To carry out, monitor and analyse our business or operations including the activities set out in this Privacy Policy;
To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
FOR MARKETING PURPOSES WITH YOUR CONSENT
Where processing is based on your consent, such consent shall be explicit, recorded, and verifiable. You have the right to withdraw your consent at any time by contacting us. Withdrawal of consent shall not affect the lawfulness of processing prior to withdrawal.
We may also process your personal data for the following purposes (after obtaining your express consent where such is legally required) in accordance with your preferences:
- To communicate with you through the channels you have approved so as to keep you up to date on latest developments, announcements and other information about Invetra services, products and technologies;
- To conduct client surveys, marketing campaigns, market analysis or promotional activities;
- To collect information about your preferences, to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
- To conduct monitoring by us or any other person on our behalf using various methods, including:
- the use of "intelligent" automated monitoring tools; or
- through random monitoring of systems, for example systematically via electronic communication recording tools;
- 3specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or;
- data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or
- using other similar monitoring technology that may become available from time to time.
Where legally required, we will not use your Personal Data for taking any automated decisions affecting you or creating profiles other than described above. You have the right to object to decisions based solely on automated processing, including profiling, which have legal or significant effects on you, in accordance with the Indonesian PDPLaw.
We will use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that such reason is compatible with the original purpose and the law (in which case your knowledge or consent for use thereof is not required). If you wish to get an explanation as to how compatibility of the reason and the original purpose is determined, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you accordingly and explain the legal basis which allows us to do so. Please note that we may process your personal data, where this is required or permitted by law.
6. Who we share your Personal Data with and in what circumstances?
We may share your Personal Data in the following circumstances:
We may share your Personal Data between Invetra Entities on a confidential basis as allowed by the Indonesian PDP Law or where required for the purpose of providing products or services and for administrative, billing and other business or ancillary purposes.
We may instruct service providers in or outside Invetra, domestically or abroad, to process personal data for the
Permitted Purposes on our behalf and in accordance with our instructions. Invetra requires these service providers to enter into relevant agreements with Invetra as such may be required by applicable laws that govern the use of any information that they receive from us. These agreements prohibit the service provider from using information of Invetra clients other than for the purposes for which such was provided or disclosed. In accordance with applicable legislation, Invetra will retain control over, remain responsible for your personal data and use appropriate safeguards to ensure integrity and security of your Personal Data when engaging service providers.
We may share your personal data with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies.
We may share your personal data with companies providing services in the areas of IT, trading platforms administration, translation of documents, support of clients, marketing, promoting our services and products, external and internal audit, cloud storage, payment services and banks.
We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or of Invetra Entities; additionally, we may seek to acquire other businesses or merge with them.
We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions.
We shall remain fully responsible for Personal Data under our control and shall ensure that any third-party processors comply with the applicable law. Our processors act only on our instructions; we remain responsible for the processing, and processors may not appoint sub-processors without our written approval.
Consistent with applicable law, we may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defense of a legal or equitable claim or for the purposes of an alternative dispute resolution process.
Generally, we will only disclose your Personal Data when you direct us or authorize us to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
7. International transfers of personal data
Some of Invetra Entities and our external third parties are based outside of your home country so processing of your personal data may involve a transfer of data outside your home country for the Permitted Purposes.
Where personal data is transferred to another country or jurisdiction, we will ensure that any cross-border personal data transfer complies with the Indonesian PDP Law, including implementing appropriate security measures and obtaining consent when required. We will exercise all reasonable and sufficient measures to ensure that appropriate safeguards are in place to protect your personal data in compliance with legal requirements under the applicable laws and regulations. The appropriate safeguards may include legally binding data transfer agreements with data recipients based on standard contractual clauses approved by relevant authorities, or obtaining your explicit consent, to ensure that the receiving parties provide a level of protection comparable to our commitments.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
If you instruct Invetra to cease using or processing your personal data, Invetra has the right to terminate any existing services to you immediately (or within a reasonable time, as determined by Invetra).
8. Security and protection
Invetra has put in place appropriate security measures to protect the security of its clients’ personal data and prevent any unauthorised or unlawful processing, accidental loss, destruction, alteration, disclosure or damage of clients’ personal data. Invetra implements appropriate technical and organisational measures such as network traffic encryption, pseudonymization, data encryption, two-factor authentication, access management procedure, tokenization, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc. Invetra limits access to the clients’ personal data to those employees, agents, contractors and other third parties who have a business need to know, only process clients’ personal data on Invetra instructions and are subject to a duty of confidentiality.
We implement technical and organizational security measures in accordance with Indonesian PDP Law to protect personal data from unauthorized access, disclosure, alteration, or destruction.
9. Recording of telephone conversations and of electronic communications
We record, monitor and process any telephone conversations and/or electronic communications between us through fax, email, social media or electronic messages, either initiated from Invetra or you. All communications are recorded and/or monitored and/or processed by Invetra, including any telephone conversations and/or electronic communications that result or may result in transactions or client order services even if those conversations or communications do not result in the conclusion of any arrangements and or transactions. The content of any in person conversations and/or communications with you may be recorded by minutes or notes.
Any such records can be provided to you upon request at the same language as the one used to provide services to you.
This recording is carried out on the basis of (as applicable) contractual necessity and/or legal obligation and is notified to you in accordance with the Indonesian PDP Law.
10. How long will you use my personal data for?
We will retain your personal data only for as long as necessary to fulfil the purpose which it was collected for to fulfil the purposes for which it was collected and in accordance with applicable legal retention requirements under the prevailing Indonesian laws and regulations.
In order to determine the appropriate retention period for your personal data we consider, among others, any statutory or regulatory retention periods, the amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, applicable legal requirements etc.
11. Your legal rights
Subject to the Indonesian PDP Law, you have certain rights under data protection laws in relation to your personal data:
Request information on Invetra’s identity and accountability, the purposes of personal data processing and the lawful bases by which we process your data.
Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to obtain confirmation as to whether we process your personal data and to receive a copy of the
Personal Data we hold about you so as to check that we are lawfully processing such.
Request correction of your Personal Data. This enables you to request correction of any incomplete or inaccurate information completed and or amended accordingly.
Request the termination of processing (including deletion and destruction) of your personal data. This enables you to request termination of processing, deletion or destruction your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to automated decision making of your personal data that is based solely on automated processing, including profiling, which has legal consequences or has a significant impact on you.
Request the suspension or restriction of processing of your personal data. This enables you to request temporary or permanent suspension of the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from us to another service provider in a safe and secure way.
Right to withdraw consent allows you to withdraw your consent to the processing of your personal data at any time.
Upon withdrawal, we will cease processing your personal data unless continued processing is permitted or required under the applicable law.
Invetra may restrict the following data subject rights: right to terminate processing (including to delete/destroy data), right to withdraw consent, right to object to an automated decision making, right to restrict processing, and right to data portability, for the following purposes:
- national security;
- the enforcement of law;
- public interest;
- financial interest;
- statistical interests and scientific research (applied limited to several rights).
If you wish to exercise any of the rights set out above, please contact the Data Protection Officer through the email or telephone number available above.
You will not have to pay a fee to access your personal data or exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure that your personal data is not disclosed to any person other than you. We may contact you to ask for information in relation to your request to speed up our response.
We will respond to your request as soon as reasonably practicable and no later than the required statutory timeline applicable according to the Indonesian PDP Law.
12. Personal data breach
In the event of a personal data breach, we will take appropriate remedial actions and will, within 3×24 hours, notify affected individuals and relevant authorities. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable authorities of any breach where we are legally required to do so. If you require further information on how we deal with a data breach please contact us.
13. Questions and complaints
If you have any questions which have not been covered in this Privacy Policy, any further concerns regarding the use of your personal data or any complaints as regards to this Privacy Policy and about use of your Personal Data you can reach out to us using the contact details of our Data Protection Officer available above or on our website.
If your complaint or concern is not resolved, you can contact the office of the data protection authority of your home country via their website or the details below:
Via their website at https://www.kominfo.go.id/ or their public complaints portal at https://aduankonten.id/ or write to/call them at:
Address:
Privacy Statement-Cookies Policy-27022026-Invetra
Kementerian Komunikasi dan Informatika / Kementerian Komunikasi dan Digital (KOMDIGI)
Jl. Medan Merdeka Barat No. 9
Jakarta 10110
Indonesia
Phone: +62 21 345 2841