PRIVACY POLICY FOR THE USER OF ONOFF INSURANCE APPLICATION

This Privacy Policy is created by PT UBI Solutions Indonesia (the “Company”, “we”, “us”, “our”, “Onoff” or “UBI Solutions”) to protect and maintain the privacy of the users of our Website or App (http://www.onoff.insure/). We provide you with this policy statement to inform you of the kinds of information we may gather during your visit to UBI Solutions’s website (the "Website") or the mobile device application (the “App”), why we gather customer information, what we use the information for, the circumstances that allow us to disclose such information, and how you can instruct us to limit the use of that information.

This Privacy Policy is an integral part of our Terms and Conditions. If there is any difference between this Privacy Policy and our Terms and Conditions regarding privacy matters, the provisions of this Privacy Policy shall prevail.

You are expected to read this Privacy Policy carefully before using the Website and App services. By accessing and using services on the Website and App (henceforth together referred to as the “Platform”), the user acknowledges that he/she has read, understood and agreed to the contents written in this Privacy Policy.

Please note that in order to use our Services, you must be 21 (twenty-one) years old or older. If you are under 21 (twenty-one) years old, you will need permission from your parents or legal guardian.

  1. DATA COLLECTED IN THIS PLATFORM
    1. 1.1. Internet Protocol (“IP”) Address
    2. When visiting the Platform, the IP address of the user's device will be registered to UBI Solutions’s online system. The IP address is the sequence of binary numbers of the device used to visit the Platform. The IP address is registered to enable UBI Solutions to trace the device used to access the Platform, in case of misuse or unlawful actions in connection with the visit to or use of the Platform. Furthermore, the IP address is used to identify the user’s approximate location (city level) (hereinafter referred to as the “IP Address”).

    3. 1.2. Type of Device You Are Using
    4. Such as computer, mobile device etc., including the operating system you are using (hereinafter referred to as the “Type of Device”).

    5. 1.3. Type of Web Browser You Are Using
    6. Such as Google Chrome, Mozilla Firefox, Safari, Internet Explorer, etc. (hereinafter referred to as the “Web Browser”).

    7. 1.4. Personal Information
    8. In order to be able to process the insurance product that you use in our Platform, we require you to provide us or any other third-party service providers necessary for us to carry out our business (which we detail further in Clause 2 of this Privacy Policy), with a set of personal information that personally identifies you and your location. We, or those third-party service providers (as detailed further below), may receive and store all such information that you enter anywhere on the Platform, whether in our electronic system directly or the electronic system of those third-party service providers (as applicable). This input includes:

      1. Billing Information:
      2. Information including but not limited to your name, insurance product requested, credit card number, expiration date, and billing address, debit card number, and the amount of shields that you own for the purpose of paying for the insurance product (hereinafter referred to as “Shields”).

        (this point (a) shall hereinafter referred to as the “Billing Information”).

      3. Customer Information:
      4. Information including, but not limited to name, address, telephone number, account username, account password, one-time passcode (OTP) and temporary one-time passcode (TOTP) which will be provided by email and short message service, email address, and trip data (such as geo-location, time and date, battery level, and device information on the device used to access the Application), and specific provisions on the requested insurance products (if any).

        (this point (b) shall hereinafter referred to as the “Customer Information”)

      5. Other Information:
      6. If you communicate with us by email, or complete online forms, surveys, or contest entries, any information provided in such communication may be deemed as Personal Information, as well as the IP Address, Type of Device and Web Browser.

        (this point (c) shall hereinafter referred to as the “Other Information”)

      7. Insurance Information
      8. This information includes the provisions in the insurance policy, the insured vehicle, trademark, model and licence plate of the insured vehicle, details of the accident, damage or loss suffered by your or third-party vehicle, as well as any bodily injury that you or any third-party suffer that are insured by the Insurance Product Provider, as well as other information required and related to the insurance product that you ordered and your insurance claim.

        (this point (d) shall hereinafter be referred to as the “Insurance Information”)

      Billing Information, Customer Information, Other Information and Insurance Information is collectively referred to as "Personal Information." You may choose not to provide us with certain Personal Information. In such an event, you can still access and view much of the Platform, but then you may be unable to take full advantage of many of the features on the Platform.

  2. HOW WE USE YOUR PERSONAL INFORMATION
    1. 2.1. We use your Personal Information for the purposes in accordance with your requests, processing and filling customer’s orders, verifying your qualifications for certain products and services, improving our services, providing an enhanced and more personalised insurance product, communicating with you, and informing you of special offers and discounts. From time to time, we may also use your Personal Information to send you free Shields, which may be used to order the insurance product that you request.
    2. 2.2. By accepting this Privacy Policy in a freely given, specific, informed and unambiguous manner, you understand and agree that UBI Solutions may collect, process, and file your Customer Information, Other Information and Insurance Information to the extent necessary or desirable to fulfil your order, and disclose your Customer Information, Other Information and Insurance Information to the insurance companies which provide the insurance products (“Insurance Product Provider”, which in this case is PT Asuransi Artarindo) and the third-party which provides the payment system to UBI Solutions (“Payment System Provider”).
    3. 2.3. You hereby agree that you will render your approval in a freely given, specific, informed and unambiguous manner, on Insurance Product Provider’s actions, allowing the Insurance Product Provider to process, file and further disclose your Customer Information, Other Information and Insurance Information to the extent necessary or desirable to fulfil your order or process your insurance claim, and UBI Solutions shall not be responsible for the processing, filing and further disclosure of your Customer Information, Other Information and Insurance Information carried out by the Insurance Product Provider after such information is disclosed by UBI Solutions to the Insurance Product Provider.
    4. 2.4. You hereby also agree that you will render your approval in a freely given, specific, informed and unambiguous manner, on Payment System Provider’s actions, allowing the Payment System Provider to collect, process, file and disclose your Billing Information to the extent necessary or desirable to fulfil your order, and UBI Solutions shall not be responsible for the collection, processing, filing and disclosure of your Billing Information carried out by the Payment System Provider.
    5. 2.5. Collection, processing, filing and disclosure of Billing Information will be carried out by the Payment System Provider, by way of hyperlink to Payment System Provider’s platform in UBI Solution’s Platform. UBI Solutions shall not be responsible for the privacy practice of the platform operated by the Payment System Provider or any other parties, and you are advised to inspect the applicable privacy policy of such platform to determine how they handle all information collected from you.
    6. 2.6. We will not disclose your Personal Information to any other third-party unless you have granted us permission to do so, except to the matters regulated in Clause 2 above, in Clause 3, 5 and 11 below, and our cooperation with the Insurance Product Provider and Payment System Provider.
  3. USAGE AND SHARING OF PERSONAL INFORMATION
  4. In addition to Clause 2 above, we may also use the information such as age, gender, interests of user, etc. (“Demographic Information”) for the purpose of developing UBI Solutions’s Platform and share the Demographic Information to our partners on an anonymous and aggregate basis. This type of data is not linked to any identifiable Personal Information. We cooperate with the third parties, including the Insurance Product Provider and Payment System Provider, to bring you our Service. We share information when another company is involved in the transaction so that company can perform its functions.

  5. DATA CONTROLLER
    1. 4.1. For the Customer Information, Other Information and Insurance Information, UBI Solutions shall be the data controller of the master data you enter, where UBI Solutions shall determine the purposes and means of the processing of such of those information.
    2. 4.2. For the information which you are the data controller, you shall determine the content you choose to disclose or deliver in the Platform, including the information that are disclosed or delivered as a result of the connection of your social media with the Platform.
    3. 4.3. For the Customer Information, Other Information and Insurance Information which the Insurance Product Provider is the data controller after such information is disclosed by UBI Solutions to the Insurance Product Provider, UBI Solutions shall not be responsible on the determination of the purposes and means of the processing, filing and further disclosure of such information.
    4. 4.4. For the Billing Information which the Payment System Provider is the data controller, UBI Solutions shall not be responsible on the determination of the purposes and means of the collection, processing, filing and disclosure of such information.
  6. DATA PROCESSOR
    1. 5.1. UBI Solutions may exclusively use the service provided by other company to maintain the technical operation, safety and confidentiality of Customer Information, Other Information and Insurance Information. This company is the data processor with regard to the Customer Information, Other Information and Insurance Information (“Data Processing Company”).
    2. 5.2. By accepting this Privacy Policy, you give your consent to UBI Solutions to disclose to and allow Data Processing Company to process the Customer Information, Other Information and Insurance Information.
    3. 5.3. The Data Processing Company may act independently according to instruction(s) from UBI Solutions, and by accepting this Privacy Policy, you also give your consent over such instructions that may be necessary, including but not limited to instructions to carry out the processing of the Customer Information, Other Information and Insurance Information for the purpose of usage in the Platform.
    4. 5.4. The Data Processing Company has carried out the necessary technical and safety management measures against the information being accidentally or illegally destroyed, lost or deteriorated, and against the information coming into the knowledge of unauthorised persons, is misused or is processed in other ways in violation with the act of the processing of personal data. On your request - with due observance to the service fee of the Data Processing Company - they shall supply you with sufficient information to demonstrate that the above mentioned technical and safety management measures have been made.
    5. 5.5. For the Customer Information, Other Information and Insurance Information which the Insurance Product Provider is the data processor after such information is disclosed by UBI Solutions to the Insurance Product Provider, UBI Solutions shall not be responsible for the processing, filing and further disclosure of such information.
    6. 5.6. For the Billing Information which the Payment System Provider is the data processor, UBI Solutions shall not be responsible for the collection, processing, filing and disclosure of such information.
  7. SAFETY MEASURES
    1. 6.1. UBI Solutions will use its reasonable efforts to ensure that the Customer Information, Other Information and Insurance Information that are collected and stored by UBI Solutions will not be disclosed, transferred, given to, or illegally used by unauthorised persons.
    2. 6.2. With respect to this, UBI Solutions will regularly audit its system in order to prevent such possible vulnerabilities and attacks. However, since the internet is not a secure environment, UBI Solutions cannot, at all times, ensure or warrant the safety of information you transmit to UBI Solutions. Customer Information, Other Information and Insurance Information sent via the Platform are not encrypted, and UBI Solutions therefore advises you to prudently communicate any confidential information through the internet.
    3. 6.3. UBI Solutions may provide audit records for all activities conducted in the Platform if requested by the authorised institution for legal purposes as mandated by the applicable laws and regulations.
    4. 6.4. UBI Solutions shall not be responsible for any data collected, filed, processed or disclosed by the Payment System Provider, Data Processing Company, or Insurance Product Provider (if any), or any other relevant third-party.
  8. LOST OR STOLEN INFORMATION
  9. If your credit card, debit card, account username, or account password is lost, stolen, or used without permission, you must promptly contact us through our Customer Service at [insert UBI Solutions’s call center, if any] and/or send an email to info@onoff.insure. In such an event, we will deem you to have cancelled your credit card number, account username, or account password in our system and will update our records accordingly.

  10. ACCESS, CORRECTION AND DELETION
    1. 8.1. Access
    2. Upon written request to UBI Solutions via the contact information stated in Clause 9 of this Privacy Policy, UBI Solutions shall inform you of the purpose of the processing, regarding who receives the information and from where the information originates. UBI Solutions will provide the above mentioned as soon as reasonably possible.

    3. 8.2. Correction and Deletion
    4. If you discover that the information that UBI Solutions, as the data controller, is processing or requesting the Data Processing Company to process information regarding you that is incorrect or misleading, UBI Solutions shall make the correction at your request. We recommend that you - if possible - make the correction of such errors yourself. You may at any time correct or delete any content and information in the Platform for which you are the data controller (please see Clause 4.2 of this Privacy Policy). If your personal data changes, or if you no longer wish to appear in the Platform, you may update or delete the information by logging in to your user profile. When your profile is deleted, all the data associated with your user profile is deleted.

  11. ACCESS, CORRECTION AND DELETION
  12. Our users are given the opportunity to "opt out", so that their information is not used for purposes not directly related to placement, processing, or fulfilment of a product order when we ask for the information. If you would like to "opt out" and not have us send you material that we think may be of interest to you, such as product information and promotional mailings/emails from us and Platform and companies we own, then you can notify us in one of the following two ways:

    1. 9.1. Writing to us at:
    2. Menara Prima, Level 9
      Jalan DR. Ide Anak Agung Gde Agung, RT/RW 5/2
      Kuningan Timur, Setia Budi
      Jakarta Selatan 12950

    3. 9.2. Emailing us at:
    4. info@onoff.insure

  13. CHANGES IN THE PRIVACY POLICY
    1. 10.1. UBI Solutions may at any time make changes to this Privacy Policy with future effect. We will provide reasonable advance notice of any such changes. UBI Solutions shall inform the users of the Platform of such changes when the users log in to the Platform. If you wish, UBI Solutions will inform you to your email registered in our data on any substantial changes of the Privacy Policy.
    2. 10.2. You agree that the continued use of the Platform after any posted modified version of the Privacy Policy is your acceptance of the modified Privacy Policy.
  14. DISCLOSURE REQUIRED BY LAW
    1. 11.1. We may disclose Personal Information when required by law or when such action is necessary in order to comply with the edicts of the law or a court order or legal process carried out against UBI Solutions or any of its officers or principals.
    2. 11.2. We reserve the right to disclose such information when UBI Solutions reasonably believes that it is needed to identify, contact, or carry out legal action against a party who may be violating UBI Solutions’s Terms and Conditions or may be causing injury to or interference with UBI Solutions’s rights or property, registered customers or potential customers of UBI Solutions, or anyone else that could be harmed by such activities.
  15. GOVERNING LANGUAGE
  16. This Privacy Policy is made in both Indonesian and English language in compliance with Law of the Republic of Indonesia Number 24 of 2009 on National Flag, Language, Coat of Arms, and Anthem which is agreed and fully understood by you. If there is any dispute on the interpretation of this Privacy Policy between Indonesian version and English version, the Indonesian version shall prevail.

    In case of inquiries regarding UBI Solutions’s Privacy Policy, our processing of personal data, correction of data or your relations to us in general, you are welcomed to contact UBI Solutions by email at info@onoff.insure.