Thank you for visiting Smartfren’s official website and/or application, including its derivative websites and applications, features, social media, and other media provided by Smartfren (“Smartfren Platform”). Smartfren are commits to protect and safeguard your (“User” or “You” or “Your”) information when using Smartfren’s products and/or services, including Smartfren services and/or Smartfren Platforms (“Smartfren’s Products and/or Services”). This Privacy Policy explains how Smartfren obtain, collect, use, disclose, process, manage, analyze, display, stores, update, delete and protect personal data information (“Data”) that You can provide to/obtained by Smartfren related to Smartfren’s Products and/or Services.

You guarantee that any and all data/information that You provided in written form or other forms to use the Smartfren’s Product and/or Service is truly yours and not obtained from personal information belonging to third parties without legal permission and its current (valid) data, so that all matters arising in connection with the provision and correctness/accuracy of such data are Your full responsibility.

You are advised to read this Privacy Policy prior to Your access or use the Smartfren’s Products and/or Services and submit any personal Data. By accessing and using this Smartfren’s Products and/or Services, You give Your consent to, obtain, collect, use, disclo

se, process, manage, analyze, display, stores, delete, update and destroy Personal Data in accordance with this Privacy Policy. Therefore, You hereby agree to be bound by this Privacy Policy including the terms and conditions of Smartfren’s Products and/or Services (“Term of Use Agreement”).

This Privacy Policy apply to: (i) all Smartfren’s Products and/or Services offered by Smartfren, subject to the terms and conditions of each Smartfren’s Product and/or Services; (ii) all communication systems/media used by Smartfren from time to time, including but not limited to applications, social media, and other media that may exist in the future; (iii) Users, prospective customers of Smartfren’s Products and/or Services, and visitors to the Smartfren Platform, including third parties that have collaborated with Smartfren, contractors, vendors, and our business partners.

1. “Personal Data” refers to information that identifies You as an individual, whether true or not, which can be used to identify You, either on its own or together with other information that Smartfren have or are likely to access. Personal Data that we collect and process may include:
   • Your first and last name, Your address, date of birth, occupation, e-mail address, identity number;
   • Seller affiliations and/or IP address;
   • Cookies and/or statistical/analytical data, such as Your browsing behavior, including device data (device, network/connection) and application version when accessing Smartfren, to the extent You can be identified through this;
   • User activity while using the Smartfren Platform, such as page visits, clicks, responses to activities, and transaction outputs;
   • Demographic information (e.g., age range, marital status, gender);
   • Product-specific information (e.g., preferences, closed user groups (CUGs), friends and family You choose to include in your service package, credit limits);
   • Service account information (e.g., call usage data, account balance, transaction history, credit information, billing, loyalty points);
   • Your Contact in Smartfren (e.g., records or recordings of calls You make to our contact centers, live chat features, emails or letters sent, or other records of any contact with Smartfren);
   • Geographic location information, such as location obtained from your IP address or GPS, base stations, bluetooth or Wi-Fi signals, satellites, telecommunication towers, and information about how You interact with and use Smartfren’s Product and/or Services, for example, when You choose to enable location services on the device You use to access the Service;
   • Documentation that helps Smartfren verify the accuracy of the information You provide, such as identity proof;
   • Social media links or public profiles, and any personal information visible within them, which You may provide to Smartfren for customer support transactions;
   • Account passwords that You may create; and
   • Other personal information You may provide to us while using Smartfren’s Product and/or Services.
   • This Privacy Policy only applies to Personal Data that we have or control.
2. Smartfren collect Your Personal Data when You use Smartfren services or communicate with Smartfren. In this case, You may provide Your Personal Data directly to Smartfren, or it may be shared with Smartfren by our affiliates, payment channels, or other third parties, as per Your consent given to these third parties.
3. IInformation collected by Smartfren includes the Personal Data You provide, recorded and/or obtained from other sources cooperating with Smartfren when You access/use Smartfren Products and/or Services, including but not limited to when You:
   • Register or update your account on Smartfren’s Products and/or Services; and/or
   • Contact or communicate with Smartfren, such as inquiring about products/services and/or expecting feedback; and/or
   • Interact with Smartfren Platform, such as submitting application forms, completing surveys sent by Smartfren or on behalf of Smartfren (If Your browser enables internet cookies, it may facilitate us in tracking personal preferences, visited pages, and more); and/or
   • Perform mobile commerce transactions online on or through Smartfren’s Products and/or Services; and/or
   • Register for activities, missions, quizzes, contests, games, competition or other prize draws; and/or
   • Interact on Smartfren Platfrom and digital Smartfren media; and/or
   • Purchase or use the services available on Smartfren’s Products and/or Services; and/or
   • Where You are a customer of a company acquire by Smartfren or a customer of a company involved in Smartfren corporate actions; and/or
   • Provide Your consent for other companies to share information about You; and/or
   • Grant permission for access to Your location data; and/or
   • Visit Smartfren’s facilities such as customer service centers and/or office buildings equipped with CCTV as part of security measures; and/or
   • Grant permission for access information about the device and/or telecommunication network used.
4. The data that Smartfren collect about You and how Smartfren collect it may vary depending on the type of Smartfren’s Products and/or Services You access or use, how You use the Smartfren’s Products and/or Services, and how You interact with us, even if You are not a User. The Personal Data You provide, recorded, and/or obtained from other sources cooperating with Smartfren when You access/use Smartfren’s Products and/or Services may be used by Smartfren, including but not limited to:
   • Communicating and/or responding to You, including directing You to the appropriate customer service representative to respond to Your questions and/or complaints;
   • Informing You about products, services, promotions, news, such as value-added services (VAS), financial technology, Internet of Things (IoT), digital/enterprise products, and more;
   • Research/analysis, development, modification, updating, or testing to improve the security and quality of Smartfren’s Products and/or Services;
   • Verifying, processing, and providing rewards related to Your entitlement in contests/draws/quizzes/games/missions/other activities You perform through Smartfren’s Products and/or Services;
   • Processing, verifying the accuracy of information on applications and/or any form of registration and/or mobile commerce transactions and/or communications made/done by You;
   • Processing requests, activities, or transactions You perform through Smartfren’s Products and/or Services;
   • Conducting internal activities related to providing Smartfren services, including resolving issues, data analysis, testing, research, statistical purposes, and surveys;
   • Other purposes related to the provision of services by Smartfren and/or for benefit of Smartfren, including giving promotion of products/services from third parties that collaborates with Smartfren that Smartfren believes has the relevancy with , or may be of interest to You;
   • Fulfilling legitimate interests while considering Smartfren interests, needs, and balancing those with Your rights, including but not limited to monitoring or investigating and taking further action on transactions that are [suspected] to be fraudulent or in violation of the Terms of Use Agreement or applicable laws or norms, including maintaining the security of Smartfren network and services;
   • Fulfilling legal obligations under applicable laws, including but not limited to requirements for investigation, reporting to regulators, assisting in detecting and preventing fraud, tax evasion, and financial crimes, and fulfilling other obligations under applicable laws from time to time; and
   • Your explicit valid consent for the processing of Personal Data carried out by Smartfren for the purpose of allowing Users to use or enjoy Smartfren’s Products and/or Services. Your valid consent may be mandatory or optional. Mandatory consent pertains to processing related to billing and routing to allow you to make incoming and outgoing calls, SMS, and data or internet services on Your device, including but not limited to processing information related to MDN numbers You contact, credit limit checks for postpaid accounts, or remaining prepaid deposit (credit) when applying for a Smartfren’s Product and/or Service, how much data You use, the sites You visit, and when You do it. This is necessary to enable Smartfren to bill You based on Your usage.
   • Each time Smartfren process Your data based on the above conditions, Smartfren assess its business interests and ensure that these interests do not override Your rights.
5. You understand and accept that Smartfren may also disclose Your Personal Data to Our affiliates, or other parties as permitted or required by applicable laws, such as government authorities or regulators, or others as necessary, for the following purposes:
   • For or in connection with negotiations over mergers, sale of shares or assets of the company, financing, acquisition, divestiture, or dissolution of all or part of our business; or
   • If Smartfren believe that disclosure is reasonably necessary to (i) comply with the law, regulation, legal process, or government/regulatory request; (ii) assist in any investigation or legal process; and (iii) protect the security or integrity of Smartfren’s Product and/or Services, or services contained on the Smartfren Platform, or any of Smartfren’s users or the public from harm or illegal activity.

1. The information obtained by Smartfren from You will be stored for a certain period as long as you continue to use Smartfren’s Products and/or Services and/or in accordance with applicable laws and regulations. Smartfren may keep Personal Data in either printed copies or electronic format in data centers or archive warehouses managed by Smartfren or by data storage service providers appointed by Smartfren. All of our facilities, systems, and products are equipped with necessary security controls to ensure the protection of Personal Data. The storage period may vary depending on the type of information and the legally required storage period, ongoing judicial processes, business needs, intellectual property rights enforcement, agreements, operational needs, and archiving. In the event that your Personal Data is deleted from Smartfren’s system, the data will be removed or destroyed using appropriate security protocols so that it cannot be reconstructed or read by unauthorized parties.
2. Smartfren will not sell, trade, or transfer information You provide to unrelated third party. Smartfren may provide relevant information obtained from You or recorded by Smartfren to parties related to the provision of services to You and/or for Smartfren’s interests, including but not limited to:
   • Company/third party assigned by Smartfren to assist with application processing, investigation, and/or verification;
   • Other party required by Smartfren to perform a job that necessitates knowledge of Your information, including but not limited to service provision to You, processing transactions/activities You are doing through Smartfren’s Products and/or Services, handling complaints/issues/obstacles/other matters You raise concerning Smartfren’s Products and/or Services, or communications You make through public media;
   • Third party with whom You have agreed to receive offers of products and/or services and who need Your information as part of the consideration or requirement in processing applications for such products and/or services, including but not limited to purchase transactions, Smartfren service usage transactions, and other relevant information;
   • Third party through which You access Smartfren’s Products and/or Services and/or conduct transactions/activities involving Smartfren’s services or other services available on the Smartfren Platform through the platform belonging to the third party.
3. In addition to the purposes referred to in Clause III. (1) above, Smartfren may share information You provided whenever being ordered by law or if that steps need is required to
   • fulfill the compliance to the law or court/legal process, including in the event of a dispute between Smartfren and You;
   • protecting towards misuse or unauthorized use of the Smartfren’s Products and/or Services.
4. You hereby release and discharge Smartfren from any claims, demands, and/or lawsuits related to the granting of access to the said information.

To maintain trust and safeguard the information obtained from You, Smartfren makes the best efforts to implement physical, technical, and administrative security measures to protect Your Personal Data and Smartfren network from unauthorized access, including:

1. Implementing reasonable security measures and strict compliance with privacy and security practices;
2. Obtaining certification for Information Security Management Systems (ISMS) ISO 27001;
3. Conducting regular audits and data reviews to improve our operational standards;
4. Restricting access to Personal Data only to personnel who need to know such data;
5. Retaining information while your account is active and  during the period that Smartfren is required to retain such information under applicable laws or regulation;
6. Destroying or disposing of information when it is no longer needed, in accordance with relevant regulations.

Below Smartfren set out details on how you can exercise your rights. If you have a question or cannot find the answer, please contact Smartfren’s customer services.

Smartfren have the right to refuse Your request to access, correct and/or delete, some or all of your Personal Data that we control, if or is required based on applicable laws and regulations, especially if the request could have an impact on matters such as but not limited to:

1. efforts or steps in order to implement or enforce legal regulations, including the process of investigation, inquiry, and prosecution; and/or
2. the implementation of population administration, social security, taxation, customs, and integrated business licensing services electronically; and/or
3. the interests of supervising the financial services sector, monetary, payment systems, and the stability of the financial system in the context of organizing the state; and/or
4. endanger Your safety, physical or mental health and/or others; and/or
5. there is an impact of disclosing other people’s Personal Data; and/or
6. contrary to the interests of state defence and security and/or
7. the reason for the request is irrelevant to You and/or the Personal Data processing activities Smartfren carry out.

Smartfren may be able to charge administrative fees for each of Your requests in accordance with applicable laws and regulations.

Right to access Personal Data

 You have the right to request a copy of the Personal Data Smartfren holds about You. To make this request as an individual or an authorized third party, You can contact the Smartfren customer service who will provides informations on the mechanism for doing this.

Right to correct Personal Data

You have the right to correct the information held about You if it is inaccurate. You are encouraged to be active in ensuring the accuracy and updating of Your data from time to time.

Right to data portability

You have the right to obtain and/or use Your Personal Data which You provide to Smartfren under certain conditions. You may use and send Your Personal Data to other Personal Data controllers, as long as the systems used can communicate sercurely with each other  in accordance with regulations, for example by allowing You to integrate Your data with third party platforms that Smartfren work with or enable You to download your monthly bill through Smartfren official channels with the structure and/or format that is commonly used.

Right to object to the use of Personal Data

You have the right, in certain circumstances, to object to Smartfren processing Your Personal Data. For more information or to exercise this right, please contact Smartfren customer service. If this relates to an automated decision being made on Your behalf (meaning without human involvement), You can still inform Smartfren and Smartfren will first review Your request.

Right to withdraw agreement to the use of Personal Data

You have the right, in certain circumstances, to withdraw the consent to the processing of Personal Data that You previously provided by contacting Smartfren customer service. However, the unavailability of Your Personal Data causes us to be unable to verify and process Your purchases, so You may be unable to use certain Smartfren’s Products and/or Services.

If You still want to use Smartfren’s Products and/or Services, you can only withdraw partial consent to the use of Personal Data that is not used to provide Smartfren’s Products and/or Services to You.

Right to limit the use of Your data

If You feel the Personal Data that Smartfren holds about You is inaccurate, or You believe Smartfren should not be processing Your Personal Data, then You can contact Smartfren customer service team to discuss Your rights. In certain circumstances and in accordance with Smartfren’s policies, You have the right to ask Smartfren to restrict processing.

Right to delete Your data

Smartfren strives to only process and store Your Personal Data for as long as Smartfren need it. In certain circumstances You have the right to ask Smartfren to delete your Personal Data stored by Smartfren. If You feel that Smartfren is storing Your Personal Data longer than Smartfren need, You should first checking whether Your subscription contract with Smartfren has ended, by contacting Smartfren’s customer service. If Your contract with Smartfren has ended, Smartfren may still have a legitimate reason to process Your Personal Data.

To exercise Your rights, you are obliged to continue to follow all policies, procedures and stages that Smartfren have set. In the event of a  to terminate the services, this remains subject to Smartfren’s approval to the extent permitted by law

We may need to transfer Your information to other companies or service providers in countries outside Indonesia (such as Singapore, UK, US, and European Countries) in the event that our servers or our suppliers and service providers are based outside Indonesia, or if You use Smartfren Products and/or Services while visiting a country outside Indonesia. In such cases, we will ensure that Your information is well protected and ensure that such companies or service providers have security standards that are equivalent to or higher than our security standards.

1. “Cookies” are files containing information sent by a website to Your hard drive or memory card through a web browser when You use or access Smartfren’s Products and/or Services, such as (i) Your Internet Protocol (IP) address; (ii) the type of browser and operating system (OS) You use; (iii) the day, date, and time when You access Smartfren’s Products and/or Services; (iv) click-stream data that helps monitor your activities when accessing Smartfren’s Products and/or Services; and (v) tools/features/links accessed by You. Cookies  perform to record important information that will assist You in using Smartfren’s Products and/or Services, in the event that You decided to re-visit the Smartfren’s Products and/or Services in the other day.
2. Smartfren uses Cookies for various purposes, including providing a different experience for You when visiting and/or revisiting Smartfren’s Products and/or Services, counting the number of users of Smartfren’s Products and/or Services, and specifically reminding You when You intend to make purchases and/or transactions, participate in quizzes, games, contests, competitions, or prize draws held through Smartfren’s Products and/or Services.
3. Use the “Option” in your browser to set preferences to not accept Cookies. Click “Help” to learn more about how to configure Cookie acceptance. If your settings result in rejecting all Cookies, You may not be able to access some important functions or features of Smartfren’s Products and/or Services, and You might only be able to use Smartfren’s Products and/or Services in a limited way.
4. “Tracking” refers to the capability to trace your navigation interactions through Smartfren’s Products and/or Services. This tracking mechanism is used to provide You with the most suitable experience when using or accessing Smartfren’s Products and/or Services.

1. The information collected by Smartfren is intended for individuals who are competent and authorized according to Indonesian regulations/laws, meaning You must be at least 17 years old or have an Identity Card (KTP)
2. If You are not competent or underage, You may use Smartfren’s Products and/or Services only with the consent, permission, and supervision of your parents or guardians, subject to certain age restrictions on digital content that may be imposed by the Indonesian government.
3. If You are a parent or guardian overseeing a minor who wishes to use Smartfren’s Products and/or Services, and You accept this Privacy Policy on their behalf, You consent to the processing of their Personal Data in accordance with this Privacy Policy.
4. In the case of processing Personal Data of disabled persons, consent may be given by the disabled person themselves and/or their guardian.