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, delete, and protect personal information (“Data”) that You can provide to/obtained by Smartfren related to Smartfren’s Products and/or Services.

You are advised to read this Privacy Policy prior to Your access/use the Smartfren’s Products and/or Services and share any Data. By using this Smartfren’s Products and/or Services, You give consent to, obtain, collect, use, disclose, process, manage, analyze, display, stores, delete, and destroy 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").

1. Information collected by Smartfren is information/Data that You provided, recorded and/or collectd from any sources that have collaboration with Smartfren when You access/use Smartfren’s Products and/or Services, including but not limited to when You are:

• registering yourself or updating Your account on Smartfren’s Products and/or Services; and/or
• connecting or making communication with Smartfren, among others asking for products/services and/or inquiring forfeedback); and/or
• filling up survey sent by Smartfren or sent on behalf of Smartfren; and/or
• making mobile commerce transaction thru online or thru Smartfren’s Products and/or Services;and/or
• registering yourself for any activity, mission, quiz, contest, game, challenge, or any other lucky draw; and/or
• using service(s) that available on Smartfren’s Products and/or Services; and/or
• grant permission to access location data of yourself; and/or
• grant permission to access Your device and/or other network information You are using.

2. Information/Data that Smartfren collects is information/Data that You provided, recorded and/or collected from anyr sources that have collaboration with Smartfren when You access/use Smartfren Products and/or Services, can be used by Smartfren, including but not limited to, for:

• Making communication and/or giving feedback to You, of which including redirecting You to the customer care agent to give the right respond ftoor any of Your questions/inquiries;
• giving information regarding product, service, promotion, news, et cetera, to You;
• analyzing, developing or testing to increase security, product and service quality of Smartfren’s Products and/or Services;
• verifying, processing, and giving prize related to Your rights as of contest/lucky draw/quiz/game/mission/other activity that You do through Smartfren’s Products and/or Services;
• processing, checking the accuracy of information in-app and/or any type of registration and/or any type of mobile commerce transaction and/or communication You made;
• processing request, activity, or transactions that You do through Smartfren’s Products and/or Services;
• performing internal activity related to providing Smartfren services, include creating solution for issues, data analysis, testing, research, statistical and survey purposes;
• other purposes related to the provision of services by smartfren and / or for the benefit of smartfren, including among others related to the delivery of product / service offerings from other parties related to smartfren which smartfren thinks will be of interest to you; and
• monitoring or investigating and performing any further action for transaction(s) that is considred to be suspicious or fraud under the definitions in Terms of Use or applicable regulations.

1. Information that Smartfren collect from You will be stored for a certain period of time. Smartfren will not sell, exchange, or transmit the information You provided to any non-relevant third party. Smartfren may share relevant information that collected from You or recorded by Smartfren, to the parties that are related to providing service to You and/or for Smartfren’s needs and interests, of which including convey offering of product/service offers from other parties that collaborating with Smartfren that Smartfren think relevant or important for You, to the extent that party agrees to protect Your information, including but not limited to:

• company/third party that being assigned by Smartfren to provide support in the application process, investigation and/or verification;
• other party that on behalf of Smartfren is required to perform a task that within the execution requires to know Your information, among others related to providing services to You, processing transaction/activity/activity that You are doing through Smartfren’s Products and/or Services, issue complaint/trouble/obstacles/other things that You address related to Smartfren’s Products and/or Services or communication that You address through public media;
• third party to whom You have agreed to accept offers for their product and/or service and this third party needs Your information as one of the consideration or requirement in processing the application for the submission of the said product and/or service, including but not limited to purchase transaction, usage transaction of Smartfren’s services, and other relevant information;
• a third party where You are accessing Smartfren’s Products and/or Services and/or conduct transactions/activities/activities for Smartfren’s services or other services contained in the mySF application through the platform belonging to the third party. platform belongs to the third party.

2. 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

   You, hereby release and discharge Smartfren against any demand, claims, and/or lawsuit related to the granting of access to the said information.

To protect the trust and the security of information You provided, Smartfren will:

1. perform a reasonable information security effort;
2. keep the information to the extent Your account is active and during the period that Smartfren have to keep such information under the applicable law or regulation;
3. destroyed the said information, if such information is no longer needed, according to the applicable law or regulations

Below we explain the details of how you can exercise your rights. If you have any question or cannot find the answer, please contact our Customer Care team.

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

• endanger your safety, physical or mental health and/or others; and/or
• there is an impact of disclosing other people’s Personal Data; and/or
• contrary to the interests of state defence and security and/or
• the reason for the request is irrelevant to you and/or the personal data processing activities we carry out.

We 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 may visit the “Contact Us” section which provides details on how to do so. Or you can contact our Customer Care team.

Right to correct personal data

You have the right to correct the information held about you if it is inaccurate. If the information we hold about you is inaccurate or needs updating, you can contact our Customer Care team. 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 be able to carry the personal data that you provide to us under certain conditions. We also ensure that you can carry and send your data to other parties or to other Personal Data Controllers, as long as the systems used can communicate with each other safely according to regulations, for example by allowing you to integrate your data with third party platforms that we work with or enable you to download your monthly bill through our 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 information. For more information or to exercise this right, please contact Smartfren Customer Care. If this relates to an automated decision being made on your behalf (meaning without human involvement), you can still inform us, and we 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 agreement to the processing of personal data that you previously provided by contacting Smartfren Customer Care. However, the unavailability of your personal data information causes us to be unable to verify and process your purchases, so you may be unable to use certain products and services.

If you still want to use our products and services, you can only withdraw partial agreement to the use of personal data that is not used to provide services to you.

Right to delete your data

Smartfren endeavours to only process and store your data for as long as we need it. In certain circumstances you have the right to ask us to delete your personal data that we hold. If you feel that we are holding your data for longer than we need, it is worth first checking whether your subscription contract with Smartfren has ended, which you can do through the Customer Care team. If your contract with Smartfren has ended, we may still have a legitimate reason to process your personal data. For more information on retention periods, see the section in this privacy policy entitled Retention.

1. "Cookies" is a type of file that contain information shared by a website to hard drive or memory card thru a web browser when You are using or accessing Smartfren’s Products and/or Services, such as (i) Your Internet Protocol (IP) address; and (ii) the type of browser and Operating System (OS) that You use; and (iii) day, date and time when You are accessing Smartfren’s Products and/or Services; and (iv) data from click-streams that more or less function to monitor Your activity when You are accessing Smartfren’s Products and/or Services; and (v) tools/feature/link You access. Cookies perform to record important information that helps 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 multiple purposes, of which Smartfren try to give You different experience whenever You visit the Smartfren’s Products and/or Services, counting the number of users in the Smartfren’s Products and/or Services, also remind You for special events such as purchase, joining quiz, game, contest, challenge, or rewarding lucky draws held through Smartfren’s Products and/or Services.

3. Use the "Option" in Your browser to set options not to accept Cookies. Click "Help" to find out more about how to set Cookies preference. In the case of rejecting all Cookies options, You may not be able to access several functions or important features in Smartfren’s Products and/or Services and hence You may be only able to use a limited function in the Smartfren’s Products and/or Services.

4. “Tracking” is the capability to track Your navigation in the interactions through Smartfren’s Products and/or Services. This tracking mechanism is used to give You the most relevant experience when using or accessing Smartfren’s Products and/or Services.

1. This Privacy Policy is only intended for Your information collected when You are using or accessing Smartfren’s Products and/or Services, not for information that is collected thru offline.

2. To the extent permitted by applicable laws in Indonesia, You can contact Smartfren to recall Your acceptance towards obtaining, collecting, using, disclosure, processing, managing, analyzing, displaying, and storing Your Data where whenever this happen, You understand the consequences that You are not able to use partial or all features on Smartfren Products and/or Services.

3. Smartfren may provides link to other websites outside the Smartfren’s Platform. In the event that You decided to use such link, it advisable for You to read and understand the mentioned third party 'privacy policy.'. Smartfren is not responsible for any content / material that provided by such third party's website including the policy for that third party.

4. Smartfren’s Products and/or Services, as of the Terms of Use oblige all Smartfren’s Products and/or Services users to have the Resident Identification Card (Kartu Tanda Penduduk) and Family Card (Kartu Keluarga) due to Smartfren’s Platform provides contents that suitable for users with 17 years old and above age. Should You believe that Smartfren’s Products and/or Services may have personal data from children below the age of what relevant jurisdiction apply without consent from their parents or trustee/guardian, please contact Smartfren at customercare@smartfren.com.

5. In the event of change of control or change of ownership of all or part of Smartfren's business, including Smartfren's Products and/or Services, Your Data may be part of such asset acquisition.

6. Smartfren will goint to continuously develop and Smartfren may amend this Privacy Policy from time to time accodring to such development or in the context of adjusting to changes in the applicable laws and regulations. Smartfren will display the latest version in the Smartfren’s Platform.

7. Should You have any further inquiries to this Privacy Policy, You may contact Smartfren thru email address at customercare@smartfren.com or tools/features that available in the Smartfren’s Platform.

This English version is an unofficial translation of the original Indonesian version and is provided for your convenience. If there are differences in interpretation or ambiguity between the English version and the Indonesian version, the Indonesian version will prevail. Should You have doubt to the accuracy of the information contained in the English translation, We advise You to refer to the text of Indonesian version which is the official version.

Last Updated [11/04/2022]