This privacy policy sets out how PT Tumbuh Bersama Nano (“Nanovest”), as the manager of Nanovest application (“App”), collects, stores, uses, processes, transfers, discloses and protects user data and information (”Nanovest Privacy Policy”). Nanovest Privacy Policy shall apply for all use of services that are available in the App, including in the form of mobile applications, websites as well as software and other forms, that are used by an App user that is registered and verified by Nanovest (hereinafter referred to as the “User”). The User must read, comprehend, and approve Nanovest Privacy Policy as the User data will be used as a basis for Nanovest to provide higher quality services for the User.

 

In the event that the User does not permit processing of its data or information as set out under this Nanovest Privacy Policy, Nanovest does not recommend the user to use App services.

  1. DATA COLLECTION

 

User Data are collected by Nanovest in several ways, namely:

 

  1. through forms or applications by a potential user. Data collected at this stage are personal identities of the potential user that consist of, among others, Government ID number, full name according to Government ID, place and date of birth according to Government ID, address,, employment information, annual income, estimated net worth, and valid phone number and email address.

  2. banking data that will be registered upon the User upon consummation of cash out transactions;

  3. transaction activities data, search activities data on the App, news reading activities, bookmark or save activities, and other activities conducted by the User on the App;

  4. biometrics data provided by the user, being data consisting of facial features and other body parts uploaded by the User on the App;

  5. location data delivered by the system when reading App usages at a certain location or area;

  6. technical data obtained when User is using the App. Such technical data include Internet Protocol (IP) address, website information, duration of App usages or website visits, gadget when using the internet, advertisements, and other relevant matters;

  7. interaction data with our customer service;

  8. other data collection mechanism performed by Nanovest (including via the App);

  9. other sources in cooperation with Nanovest, where the User has permitted the transfer of User data.

 

Before a User may use the App and services provided by Nanovest, the User shall firstly be requested to approve this Privacy Policy (including on the collection of personal data as mentioned above). Specifically on personal data collection via local data access and system data that are in the User gadget, Nanovest shall request prior approval before having access to the same, including access to photos, voices, cameras, and other features of gadgets used by the User.

 

   2. USE OF DATA

 

Nanovest is entitled to use Users data once the User agrees to Nanovest Privacy PolicyData collected by Nanovest shall be used for the following matters:

 

  1. to identify the User including in the event of processing for User’s benefit relating to the verification, activation or non activation of User account, and other matters in connection with the User account.

  2. to facilitate and verify KYC processes on the system when the User is to perform a transaction;

  3. to register and grant access to the User data, to parties in cooperation with Nanovest in providing products offered on the app (Vendor), to register the User on the system provided by the Vendor.

  4. to process and facilitate orders and transaction payments of an investment product made by the User, including to notify the success or failure of the User transaction.

  5. to ease communication between Nanovest and the User via and for the usage of the App;

  6. to provide updates on the latest information, whether the App systems, App features, change in any policies whether required by Nanovest or the government that are affecting the App, and other information that may be shown or delivered to the User;

  7. to process and respond questions and feedbacks from the User;

  8. to update, maintain, develop, and personalize the App to conform with User preferences;

  9. to monitor, supervise and analyse transaction activities, search activities, structure and distribution of revenues and expenditures, in using the services provided by the App;

  10. to offer or provide services that are made available by its Affiliates (as defined in the General Terms and Conditions of the App); and

  11. to offer vouchers, rewards, bonuses, surveys, promotions, and advertisements to the User.

 

   3. DATA SHARING

 

Distribution or transfer of data performed by Nanovest shall only be for the purpose of using the App and to support the services and features offered by Nanovest on the App. Nanovest shall only distribute or transfer data in the event that the User has granted an approval to Nanovest to perform the same. Nanovest shall only provide User data and information to the following parties:

 

  1. A Party in cooperation with Nanovest to provide services on the App (“Vendor”), and

  2. Government agencies and officials, law enforcers, being the performance by Nanovest of its statutory obligations to make periodical reports and to submit a report on a suspicious transaction performed by the User;

 

Nano shall not sell or lease User data and information to third parties. Nanovest also has a policy that Nanovest shall only provide data to the foregoing parties to the extent that such data and information are requested by it. Nanovest shall use reasonable endeavors to reject any request for User data and information that are deemed to be irrelevant with the requests from the foregoing parties.

   4. DATA STORAGE

 

User data and information on the App shall be stored as long as the same are being used for the purpose of data collection, and as long as the same is governed by the applicable laws and regulations. Nanovest shall cease to store any User data and information immediately in the event we are of the view that the data we collect no longer in accordance with the objective of data collection, and the storage of such data is no longer required for business purposes and is not permitted or required by the applicable laws.

   5. DATA AMENDMENT AND ACCESS

 

Subject to the provisions of the applicable laws, the User may request to Nanovest, and Nanovest may also grant access to the User, to amend personal data and information by firstly contacting the customer service. Prior to granting access to the User, Nanovest is entitled to seek the underlying reasons for such change of User personal data and information.

 

Nanovest is entitled to reject any User request to access, or correct, any or all User personal information that we hold or control as may be permitted or required by the applicable laws. This may include circumstances where such personal information may contain references to other individuals or where the request for such access or correction are deemed by us to be trivial, outrageous, inappropriate, and unreasonable.

 

The User may contact us via contacts as set out under point 10 of this Privacy Policy.

   6. DATA DELETION

 

To the extent permitted by the applicable laws, the User is entitled to request us to delete User personal data that are stored in Nanovest systems. Upon the User request, we will attempt to delete the User’s personal data from our system, unless permitted or required otherwise by the applicable laws. Nanovest shall also cease to collect, use, or disclose User personal data, unless permitted or required by the applicable laws. Please note that by requesting us to delete the User’s personal data, we may not be able to continue providing our services to the User.

 

In relation to this Data Deletion, the User may contact us via contacts as set out under point 10 of this Privacy Policy.

 

   7. DATA SECURITY

 

Confidentiality of User data and information is the utmost importance of Nanovest. Nanovest shall use all reasonable endeavours to protect and secure User data and information from any access, collection, usage, or disclosure by an authorized person and against any process in violation of the laws, unintentional losses, destruction and damages or any similar risks. However, it should be known that transmission of information through the Internet is not completely secured and prone of hacking risks. While we will do our best in protecting User data and information, the User acknowledges that Nanovest may not be able to guarantee the integrity and accuracy of any data and information that the User sent through the Internet, or guarantee that such User data and information will not be intercepted, accessed, disclosed, modified, or destroyed by an authorized third party, due to reasons outside of Nanovest control. Nanovest shall be responsible to maintain the confidentiality of the User account and the User shall not share the details of the User account, including the password and the One Time Password (OTP), to any person and the User shall also secure and fully responsible over the security of the device being used by the User.

 

In implementing the App, Nanovest has also complied with the applicable laws in relation to the storage of data in an advanced Data Centre and Data Recovery Centre in accordance with the provisions of the laws and regulations, as well as has equipped safety systems on the App that are in accordance with the laws and regulations.

   8. AMENDMENTS TO THE PRIVACY POLICY

 

Nanovest, in our own discretion, from time to time will perform evaluations to ensure that this Nanovest Privacy Policy is consistent with the current development and development of the applicable laws. Nanovest shall notify to the User of any amendment to Nanovest Privacy Policy, via public news that may be seen and accessed by the User on the App.The User agrees that it is the personal responsibility of the User to read and review any amendment to Nanovest Privacy Policy. In the event of any questions in relation to the amendment of this privacy policy, the User may contact Nanovest customer service via the App or to the contact available on the App and this Privacy Policy.

   9. APPROVAL AND ACKNOWLEDGEMENT

By using this platform, the User acknowledges that the User has read and understood this Privacy Policy and the User has agreed to all terms of Nanovest Privacy Policy. Specifically, the User agrees and permits any actions undertaken by Nanovest in accordance with Nanovest Privacy Policy. Continuous use of this platform following a notice on amendment to this policy shall be deemed your acceptance of such amendment.

 

 

The User may withdraw its approval for any or all User data and information collection, use, or disclosure or distribution at any time by providing reasonable written notification to us via contact details as set out below. The User may also withdraw its approval to us to send certain communication and information to the User via “opt-out” or “unsubscribe” facilities that are available in our message to You. Subject to the circumstances and nature of the approval that the User withdraws, the User shall understand that acknowledge that upon such withdrawal of approval, the User may no longer be able to use the App as well as the services attached thereto. Withdrawal of approval by the User may result in discontinuation of User account or User contractual relationship with us and all Nanovest Affiliates, with prejudice to any outstanding rights and obligations. Upon receiving User notice to withdraw the approval to collect, use or disclose or distribute User data and information, we will notify the User of any consequences of such withdrawal so that the User may decide such intention to withdraw.

   10. CONTACT US

 

Should the User have any questions in relation to the User Privacy Policy or should the User intend to gain any access of its personal data and information, please contact the following: [email protected]

11. SPECIFIC PRIVACY POLICY ON THE GLOBAL STOCK INVESTMENT FEATURE ON THE APP

 

In connection with Global Stock Investment that is implemented in cooperation between Nanovest with a United States of America stockbroker, provider of stock trading services online application to retail investors (), there are several requirements specifically requested by Broker in relation to the strict United States of America regulations. While nearly all matters are accommodated for in this Privacy Policy, the following items shall be specifically governed on the App:

 

Cross Jurisdictional Data Sharing

User data and information may be stored or managed outside of the Republic of Indonesia by Broker. Nanovest shall comply with the applicable laws and regulations as well as use reasonable endeavors to ensure that Broker or its affiliates and Nanovest in foreign countries will provide data protection and place a level of protection that is comparable with our commitment hereunder.

 

Data Deletion

User personal data that are stored by Nanovest and used for performing transactions shall be data which accuracy has been verified. Personal data shall also be in an encrypted form. In accordance with the applicable laws and regulations, in the event that the User is no longer an App User, Nanovest as the Electronic System provider shall store the User Personal Data for a minimum period of 5 (five) years as of the last date when the owner of personal data is an App User. Data deletion shall be undertaken by Nanovest in accordance with the applicable laws and regulations.

 

Specific Security System

In supporting User data safety quality, Nanovest shall implement a policy that the User must register an 4-digit numerical PIN so that the User account is not easily hackable. Nanovest shall suggest the User to use such configuration while registering its password.

 

Furthermore, to maintain data security and use of App, the App is arranged as such to allow maintenance of User data security and transaction.

Privacy Policy

Last updated: 1st December 2021