Privacy | M21app

Privacy Policy

Telekomunikasi Indonesia International (Hongkong) Limited and all of its affiliates (from now on referred to as "Telin Hong Kong," "us," "we", or "our") are subject to the requirements of the Personal Data (Privacy) Ordinance (PDPO), Chapter 486 of the Laws of Hong Kong. Our employees adhere to the strictest security and confidentiality standards for all personal information and data transmitted through our products and services to ensure that all requirements are followed. This Privacy Policy (“Policies”) describes how Telin Hong Kong collects, uses, and shares information about you and gives you the choice of how your data is collected, used, shared, and transferred.

Acknowledgment and Consent

By agreeing to the Privacy Notice, You acknowledge that You have read and understood this Privacy Notice and agree to its terms. In particular, You agree and consent for Us to process your Personal Data in accordance with this Privacy Notice.

You may withdraw Your consent to any or all Processing of Your Personal Data at any time by giving Us reasonable notice in writing using the contact details stated below. You must understand and acknowledge that after such withdrawal of consent, You may no longer be able to use the Application or services. A withdrawal of consent by You may result in Us being unable to provide services, deletion of Your account or termination of Your contractual relationship with Us, with all rights and obligations that arise remaining fully fulfilled. Upon receipt of Your notice to withdraw consent for any collection, use or disclosure of Your Personal Data, We will inform You of the likely consequences of such withdrawal so that You can decide if indeed You wish to withdraw consent.

What data do We collect about You?

We collect Personal Data when you use Our Application, including identity data, contact data, transaction data, financial data, payment data, log data and/or location data. We also collect device and technical data from you, and other data that you may submit or transmit when you use Our Application. If you choose not to provide such data, we may not be able to provide services and Applications to you normally.

How will We use the data about You?

We use Your data to set up and manage Your account with Us, communicate with You, and to provide various features, services, and functions for You on Our Application.

We also use Your data to maintain Our Applications and to tailor Our products and services to Your preferences. In addition, We use Your information to market Our products and services to You, and those of Our affiliates companies, partners, and agents (with Your consent where required by Applicable Law).

With whom do We share Your data?

We share Your data with Our third-party partners to facilitate the performance of services for You, to the extent necessary for them to provide their services, including but not limited to, payment processing and verification.

We use these third parties’ services solely to process or store Your data for the purposes described in this Privacy Notice. We also share Your data with Our affiliates for the purposes described in this Privacy Notice and with government and regulatory bodies as required by Applicable Laws.

We may also provide access by displaying Your Personal Data to other Users to facilitate communication and/or implementation of service fulfillment on Our Application.

Where do We process Your data?

We process Your data in several locations, both in Hong Kong and outside Hong Kong. We may also transfer Your data to Our affiliates and third-party partners outside Hong Kong for the purposes as set out in this Privacy Notice.

How long do We process Your data?

We will process Your data for as long as You give Your consent to Us and it is needed to process Your Personal Data to fulfill the purpose for which it was collected and obtained, or as required by Applicable Laws.

How can I exercise my rights over my data?

You may have various rights with respect to Your Personal Data under the Applicable Laws.

If You are willing to apply for the implementation of Your rights, You can submit a request for data subject rights to Us, including a request for deletion of User data through our Application.

If You have any questions, concerns, or complaints, please contact Us through the contact details that can be found in the Contact Us section.

How will We notify You of changes?

We will amend this Privacy Notice from time to time and notify You of the updated versions via Our Applications. Please check back regularly to see any updates or changes to this Privacy Notice.

More elaboration on the above can be read in the below sections.

PERSONAL DATA THAT WE COLLECT

The Types of Personal Data We Collect About You

“Personal Data” means data that identifies or can be used to identify, contact, or locate the person or device to which the data relates. Personal Data includes but is not limited to, name, address, date of birth, occupation, telephone number, email address, bank account and credit card details, gender, identification (including passport or national identity document) or other government-issued identification, vehicle data, photos, nationality, telephone numbers of Users and non-Users in Your mobile phone contact list, health data, financial related data, biometric data (including but not limited to fingerprint recognition and facial recognition), and other data including as Personal Data in accordance with Applicable Laws. In addition, if other data, including personal profiles and/or unique identifiers, are associated or combined with Personal Data, then that data also constitutes Personal Data.

The types of Personal Data that We collect depend on the circumstances of collection and on the nature of the service requested or transaction undertaken.

To the extent permitted by Applicable Laws, We may process collect, use, store, and transfer different kinds of Personal Data, consisting of general and specific/sensitive Personal Data, about You which We have grouped together as follows:

Identity Data includes name, username, passport data and its photo, user ID, or other identifier, phone number or email used for registration, title, date of birth, gender, place of birth, occupation, nationality, photos, and/or biometric data.
Contact List includes email address(es), phone numbers, and phonebook. We will use this data to improve your in-app user experience so you will not have to retype the phone number for each use.
“Know-Your-Client” (“KYC”) information. To support our KYC process necessary for the security of our system and that of our customers, we will also collect your identity document (passport). We may also collect your facial images and identification document images to complete the KYC (together with the Necessary KYC Information, are collectively referred to as the “KYC Information”).
Transaction Data includes purchases or orders made by You, Your interests, preferences, feedback, and survey responses.
Financial Data includes details of bank accounts and payment cards such as the type of card or payment account used, the name of the issuer of the card or payment account, the name of the holder of the card or payment account, the identification number of the account or payment card, the verification code of the payment card or account, and the expiration date such payment card or account, as applicable, virtual account data, financial history (including but not limited to payment card or account transaction history, payment card or account details, CVV code and mapping and/or status and condition of the payment card or account) , and credit scoring data.
Payment Data includes details of payments or transfers made by Users on Our Application, including but not limited to data relating to usage, payments, recipient details (including their account details), payment methods used, payment amounts paid, billing details, and details invoice.
Technical Data includes details on Your usage of Our Applications such as identification generated by the Application (user id), in app messages, in app search history, internet protocol (IP) address, data as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model, and operating system of the device you use to access the Application and crash logs.
Device Data includes device data, including the type of device You are using to access the Application, including hardware model, operating system and version, software, IMEI number, file name and version, language preference, unique device identifier, advertising identifier, serial number, device movement information, and/or mobile network information.
Log data includes records on the server that receive data such as device IP address, date and time of access, Application features or pages viewed, Application work processes and other system activities, browser type, and/or third-party sites or services that the User used before interacting with the Application.
Location Data to detect the country you are accessing from.

We may create, use, license, or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your Personal Data but would not be considered Personal Data as this data will not directly or indirectly reveal Your identity We will ensure (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) the data is then combined with similar data such that the original data forms a part of a larger data set.

If You provide incomplete Personal Data

Where We need to collect Personal Data by law, or under the terms of a contract We have with You, and You either choose not to provide that Personal Data or provide Us with incomplete Personal Data when requested, We may not be able to provide services We have or are trying to enter into with You.

How We Collect Your Personal Data

The Personal Data that We collect may be provided by You directly or by third parties (for example: when You register for or use the Applications, when You contact Our customer services, or when You otherwise provide Personal Data to Us). We may collect data in various forms and for various purposes (including purposes permitted under Applicable Laws)

Data obtained from You or from Your mobile device directly

You may give Us Your Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where requested by Us or where required by Applicable Laws when interacting with Us directly or by corresponding with Us by post, phone, email, or otherwise. This includes Personal Data You provide when You:

register and create an account using the Applications;
use the Applications
make payments using available methods including but not limited to credit card payments, virtual accounts, bank transfers, electronic money and/or electronic wallet (whether as payer or recipient);
add a source of funds for payment in the Applications;
use the chat features in the Applications; and
give Us feedback or contact Us.

Data collected whenever You use the Applications

If You use and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility which is available on Our Application (whether as payer or recipient), We may collect certain Financial, Profile and Payment Data relating to such payments and transfers.

In addition, whenever You use and/or visit the Applications, certain data may also be collected on an automated basis using cookies. Cookies are small application files stored on Your computer or mobile device. We use cookies to track user activity to enhance user interface and experience. Most Mobile Devices and internet browsers support the use of cookies, but You may adjust the settings on Your Mobile Device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable You to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the Applications.

We may also use features provided by third parties in order to improve our services and content, including assessing, customizing, and presenting offers to each User based on interests or visit history. If the User does not want offers to be displayed based on these adjustments, then the User can set it via the browser.

Data collected from third parties

We may also collect Your Personal Data from third parties (including Our agents, vendors, suppliers, contractors, partners, and any others who provide services to Us, who collect Your Personal Data and/or perform functions on Our behalf, or whom We collaborate with). In such conditions, We will only collect Your Personal Data for or in connection with the purposes for which such third parties are engaged or the purposes of Our collaboration with such third parties (as the case may be).

Data about third parties You provide to Us

When You are using the chat features or balance transfer in Our mobile Applications, You will provide Us with phone numbers stored on Your mobile phonebook to enable You to use Our chat features and for other purposes.

How we use your data

Depending on the circumstances, your personal data may be used for one or more of the following purposes:

To verify your identity;
To process your application for any service;
To communicate with you;
To facilitate the daily operation of the services provided to you;
To conduct customer due diligence as required by law and regulations;
To provide you with marketing and promotional materials for your enjoyment of benefits;
To facilitate Telin Hong Kong's use of your personal data for purposes relating to the provision of services offered by Telin Hong Kong and/or our merchants, and marketing services, special events, and/or promotions of Telin Hong Kong and/or our merchants;
To handle and investigate complaints and other inquiries;
Loyalty program administration, operation, and management;
Developing and upgrading services and products to meet your specific requirements;
Billing
Processing payment instructions
Daily administration and management of our business
Credit checking and debt recovery (including the employment of debt recovery agents and civil processes).
Obtaining legal counsel and making legal claims or defenses, as well as participating in legal processes;
Fraud and crime prevention and investigation;
Disclosure as permitted or required by any jurisdiction's laws, regulations, and court orders, and/or as required by any government, regulatory, or law enforcement authority;
Any such incidental or related reasons connected to the aforementioned, as well as any other purposes you may agree to from time to time.

We may also use Your Personal Data more generally for the following purposes (although We will in each such case always act reasonably and use no more Personal Data than what is required for the particular purpose):

to undertake associated business processes and functions;
to monitor the usage of the Applications and administer, support, and improve the performance efficiency, growth, user experience and functions of the Applications;
to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Applications or the services;
to generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and collaboration;
to prevent, detect, and investigate any suspicious transactions or prohibited, illegal, unauthorized, or fraudulent activities;
to facilitate business asset transactions (which may extend to any mergers, acquisitions, or asset sales) involving Us and/or any of Our affiliates;
to enable Us to comply with all obligations under Applicable Laws, including but not limited to responding to requests, investigations, or decree in accordance with regulations, complying with filing, reporting, and licensing requirements required by Applicable Laws, and conducting audit checks, due diligence, and investigation; and
for any other purpose that We notify You of and, where required by Applicable Laws, obtain Your consent to.

Disclosures Of Your Personal Data

We may disclose to, allow access to, or share with affiliates and other parties Your Personal Data for any of the following purposes as well as for such other purposes as are permitted by Applicable Laws:

respond to regulatory inquiries, questions, requests, investigations, decisions, and reporting, to comply with filing requirements and conditions, as specified in Applicable Laws;
where instructed, requested, required, or authorized by the government authorities, for the purpose as specified in the government policy, regulations, or Applicable Laws;
where there is any form of legal proceeding between You and Us, or between You and another party, in connection with, or relating to the services, for the purposes of that legal proceeding;
in relation to any verification as We or other third party may consider necessary before the Service Provider provides You with the services or We register You as a User, including for KYC.
where We enable Our services on any third party’s platform, (i) to assist Us in obtaining Your Personal Data and/or (ii) to register You or allow You to use Our services from such platforms.
in an emergency concerning Your health or safety (whether You are a User or a Service Provider) for the purposes of dealing with that emergency;
in situations related to your health or the public interest (whether you are a Service Provider or User), We may share your Personal Data with authorized government institutions and/or other institutions that may be appointed by the authorized government or have cooperate with Us, for tracking purposes contact, support government initiatives, policies or programs, public health, and other purposes as reasonably necessary;
in connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of Our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
in connection with an insurance claim, We will share Your Personal Data for the purpose of processing the insurance claim with the insurance company that We engage or collaborate with;
where We share Personal Data with affiliates, We will do so for the purpose of them helping Us to provide the Applications, to operate Our business (including, where You have subscribed to Our mailing list, for direct marketing purposes), or for the purpose of them conducting data processing on Our behalf.
any of Telin Hong Kong's agents, contractors, subcontractors, or associates (including their employees, officers, agents, contractors, service providers, and professional advisers);
any third-party service providers (including their employees and officers) who provide services to us or any affiliate of our parent company, PT Telkom Indonesia (Persero) Tbk (Telkom), in connection with the operation or maintenance of our business;
any persons bound by a duty of confidentiality to us or a PT Telkom Indonesia (Persero) Tbk. (Telkom) subsidiary who have agreed to keep such information private;
any affiliate of PT Telkom Indonesia (Persero) Tbk. (Telkom);
PT Telkom Indonesia (Persero) Tbk. (Telkom) co-branding partners or any PT Telkom Indonesia (Persero) Tbk. (Telkom) (the names of such co-branding partners will be provided throughout the application process for the relevant products and services, as the case may be); and
Telecommunications network operators;
Third-Party reward and loyalty programs providers;
Financial institutions, charge or credit card issuers, credit providers, credit information or reference bureaus, or collection agencies, as well as security agencies,
Any actual or projected assignment of all or a portion of the Company's business and/or assets.

Where it is not necessary for the Personal Data to be associated with You, We will use reasonable endeavors to remove the means by which the Personal Data can be associated with You as an individual before disclosing or sharing such data.

We will not sell or lease Your Personal Data.

Other than as provided for in this Privacy Notice, We may disclose or share Your Personal Data if We notify You or We have obtained Your consent for the disclosure or sharing.

International Transfers

When You are using Our Applications and services in other countries where Our Applications are also accessible (“Designated Country”), We may transfer Your Personal Data from the origin country (“Origin Country”) to the Designated Country in order to enable and ensure smooth customer experience when You are using Our Applications abroad.

Your Personal Data may also be stored or processed outside of Your country by Our personnel who work for Us in other countries, or by Our third-party service providers, vendors, suppliers, partners, contractors, or affiliates.

We will comply with the Applicable Law and use all reasonable endeavors to ensure that Our affiliates abroad and all such third-party service providers provide a level of protection that is comparable to Our commitments under this Privacy Notice and what is required under the laws of Your country.

You understand and consent to the transfer of Your Personal Data out of Your home country and/or the Origin Country as described in this Privacy Notice.

PROTECTING YOUR PERSONAL DATA

Data Security

We will always strive to ensure that your personal data will be protected against unauthorized access, processing, erasure, or other use. We have implemented appropriate electronic, physical, and managerial measures to safeguard, protect, and secure your personal information.

All personal information you provide is only accessible by the authorized personnel of Telin Hong Kong or our authorized third parties. Such personnel shall be instructed to observe the terms of this Policy when accessing such data. You may rest assured that Telin Hong Kong will only keep your personal information for as long as necessary to fulfill the purpose for which it is collected. To support electronic transactions, we may engage third-party payment gateway service providers.

The online browser and third-party payment gateway transmit sensitive information you provide for completing any electronic transactions, utilizing secure Socket Layer Technology (SSL). We also use HTTPS ("HyperText Transfer Protocol Secure") for data transfers through M21 App, CAPTCHAs ("Completely Automated Public Turing Test to Tell Computers and Humans Apart") on M21 App, regular penetration checks, encryption and masking methods for images to ensure sensitive data is well protected, and One-Time Password (OTP) mechanism for personal verification. You must protect your OTP by keeping them hidden and private. Never, ever, ever share the password. If you believe your password has been shared with another person, stolen, or used in an unauthorized transaction, you must notify us immediately.

There is no such thing as 100 percent secure Internet transmission or computer storage. As a result, while we make every effort to safeguard your personal information from unauthorized access, we cannot guarantee its complete security.

Data Retention

Your Personal Data will only be held for as long as it is necessary to fulfill the purpose for which it was collected, during the retention period, or for as long as such retention is required or authorized by Applicable Laws. We shall cease to retain Personal Data or remove the means by which the Personal Data can be associated with You as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by retention of Personal Data, there is a request from You to delete Your account, and retention is no longer necessary for legal or business purposes.

We will delete and/or anonymize User Personal Data under Our control when (i) User Personal Data is no longer necessary to fulfill the purpose for which it was collected; (ii) end of the retention period and (iii) storage is no longer necessary for the purpose of compliance with Applicable Laws.

Please note that there is still the possibility that some of Your Personal Data might be retained by the other party, including by the government institutions in some manner. In the event We share Your Personal Data with the authorized government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with Us, You agree and acknowledge that the retention of Your Personal Data by the relevant institutions will follow their respective policy on data retention.

Data that is submitted through communications between Buyer and Seller that are carried out other than through the use of the Application (such as via telephone calls, SMS, mobile messages, or other means of communication and collection of Your Personal Data by Our agents) can also be stored in several ways. We do not allow the processing of Personal Data between Buyer and Seller that occurs outside Our Application. Therefore, Buyer and Seller are fully responsible for the Processing of Personal Data.

To the fullest extent permitted by Applicable Laws, You agree to indemnify, defend and release Us from and against any and all claims, losses, liabilities, expenses, damages, and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorized retention of Your Personal Data.

YOUR RIGHTS AS A USER

Your Legal Rights

You may have certain rights under Applicable Laws to request Us for access to, correction of, and/or deletion of Your Personal Data in Our possession and control. To the extent, these rights are available to You under Applicable Laws. You may exercise these rights by contacting Us at the details provided in the section below.

We reserve the right to refuse Your requests for access to, correction of, and/or deletion of, some or all of Your Personal Data in Our possession or control if permitted or required under any Applicable Laws. This includes circumstances where the Personal Data may contain references to other people or where the request for access or request to correct or delete is for reasons that We consider to be irrelevant, frivolous, or far-fetched or indicated to be related to violations of the terms of use or to any activity or violation of the law.

In accordance with Applicable Laws, We reserve the right to charge an administrative fee for each access and/or correction request.

ADDITIONAL NOTES

Other Websites and Services

Applications and Marketing Materials (as defined below) may contain links to websites operated by third parties. All processing of personal data on the website is fully controlled by the third party and is under the responsibility of the third party. If You agree to access websites operated by such third parties, then You are subject to the terms and conditions and privacy notices of those third-party websites. Therefore, We recommend that You read the terms and conditions and privacy notices of such third-party websites to find out how they collect and use Your Personal Data.

When You are using Our Applications and enabling the fingerprints and/or biometric recognition features in Your Mobile Device for authentication purposes, please note that We do not store such biometric data. Unless otherwise notified to You, such data is stored in Your mobile device and may also be stored by third parties, such as Your Mobile Device’s manufacturer. You agree and acknowledge that We are not responsible for any unauthorized access or loss of such biometric data that is stored in Your Mobile Device.

Advertisements contained on Our Applications or Marketing Materials operate as links to the advertiser’s website and as such any data they collect by virtue of Your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

Marketing And Promotional Material

We and Our partners (including vendors, suppliers, merchants, and/or other third parties that engaged with Us for commercial and/or non-commercial activities may send You direct marketing, advertisement, and promotional communications via push-notification app, message in Applications, post, chat platform, social media, and e-mail (“Marketing Materials”) if You have agreed to subscribe to Our mailing list, and/or consented to receive marketing and promotional materials from Us. You may opt out from receiving such marketing communications at any time by contacting Us using the contact details stated below.

Please note that if You opt-out, We may still send You non-promotional messages, such as ride receipts or information about Your account.

Updates To the Privacy Notice

We may review and amend this Privacy Notice at Our sole discretion from time to time, to ensure that it is consistent with Our future developments, and/or changes in legal or regulatory requirements. If We decide to amend this Privacy Notice, We will notify You of any such amendments by means of a general notice published on the Application and/or website. You agree that it is Your responsibility to review this Privacy Notice regularly for the latest information on Our data processing and data protection practices and that Your continued use of the Application or website, communications with Us, or access to and use of the services following any amendments to this Privacy Notice will constitute Your acceptance to this Privacy Notice and all of its amendments.

How we collect information

We collect data when you provide information to us or through mobile applications or web technologies

Android System

Flutter 3.10.1

Mobile Application Framework. Flutter is an open-source UI software development kit created by Google. It is used to develop cross platform applications from a single codebase.

https://flutter.dev/

Dart 3.0.1

Programming Language

Android SDK (21-33)

Mobile OS Software Development Kit

Kotlin Ver 1.8.21

Programming Language

iOS System

SDK Name

Descriptions and Official Website

Flutter 3.10.1

Mobile Application Framework. Flutter is an open-source UI software development kit created by Google. It is used to develop cross-platform applications from a single codebase.

https://flutter.dev/

Dart 3.0.1

Programming Language

Xcode Ver 13

Integrated Development Environment (IDE) for Apple’s platform development.

Cocoapods 1.12.1

Dependency manager.

Disclosure or Transfer of Data

You may access the personal information that we have collected and correct factual errors in your personal information by sending us a request that credibly shows the error. You also have the right to ascertain our policies and practices concerning personal data and be informed of the kind of personal data held by us.

We will take reasonable steps to verify your identity before granting access or making corrections to protect your privacy and security. We reserve the right to charge you a reasonable fee for complying with any request for access to your data.

Data Sharing and Disclosure

To achieve the aforementioned goal, we may use third-party Software Development Kits (SDKs) to ensure the operational reliability of our services or to integrate relevant functionality. For more information about the specific circumstances of collecting your personal data, you can check the third-party Software Development Kits (SDKs) privacy policy website, which is provided by Telin Hong Kong. If a third party does not provide a specific privacy policy for its SDKs, we may give a link to the third party's official website to assist you in understanding its specific information.

Data Access or Correction

You have the right to view and update the personal data that we hold. Please write to us at the address below if you would like a copy of any of your personal data or if you believe that any of the Personal Data that we collect and retain is erroneous.

Data Privacy Officer

Telekomunikasi Indonesia International (Hongkong) Limited

Suite 810 & 905, Ocean Centre, 5 Canton Road

Tsim Sha Tsui, Kowloon, Hong Kong

Hotline: 171161

You may send us a request for access to or correction of your personal data, as well as information about our policies and practices and the types of personal data we hold, to the following address. We have the right to charge a reasonable fee for the processing of any data access request under the PDPO

You can query your personal information by logging into the M21 app, and the procedure of inquiry is as follows:

Account > Registration

To ensure the security of your information, we may ask you to authenticate yourself before processing your request.

Updated on 30 November 2023 in Hong Kong.