Welcome to Cairin. Thank you for visiting the Cairin Website and/or Application. Before accessing and/or using the Services available on the Cairin Website and/or Application, please carefully read the Terms and Conditions of Use (“Terms and Conditions”) stated on this page.

By clicking, accessing, and/or using the Services available on the Cairin Website and/or Application, you agree in writing that you have read, understood, accepted, and agreed to these Terms and Conditions, and that you are legally bound by them and by other documents and explanations contained within the Website and/or Application. If you do not agree to these Terms and Conditions, please DO NOT access or use any of the Services provided by Cairin.

These Terms and Conditions may be modified at any time without prior notice. Any decision made pursuant to these Terms and Conditions shall be final and binding. We encourage you to regularly review the Terms and Conditions to stay informed about any updates. If you do not agree with the updated Terms and Conditions, you must stop accessing or using the Services. Otherwise, you will be deemed to have agreed to and be bound by the updated Terms and Conditions.

By accepting these Terms and Conditions, you agree that this document shall be legally binding as if it were personally signed and executed by you in writing.

1. DEFINITION AND INTERPRETATION

In these Terms and Conditions, unless expressly stated otherwise, the following terms shall have the meanings assigned below:

“You” refers to any prospective Lender, prospective Borrower, Borrower, Lender, or user who accesses and uses the Cairin Website and/or Application.

“Application” means the Cairin mobile application for Android and iOS, operated and owned by us.

“Cookie” means a file used by Cairin’s server to identify your device.

“FAQ” refers to the Frequently Asked Questions section available on the Cairin Website.

“Service” refers to the Information Technology-Based Joint Financing Service provided through the Website and Application, which connects Lenders with Borrowers and is administered by Cairin.

“E-mail Service” refers to the email service we provide to you, accessible by sending an email to cs@cairin.id.

“Live Chat Services” refers to the live chat feature we provide, accessible through our Website.

“Phone Service” refers to the telephone support we provide, accessible by calling 021 - 24163377.

“OJK” refers to the Financial Services Authority (Otoritas Jasa Keuangan) of the Republic of Indonesia.

“Lender” refers to a company, institution, or individual who places funds in Cairin’s account to be disbursed as a loan to a Borrower through the Website and/or Application.

“Borrower” refers to an individual of Indonesian nationality.

“Force Majeure Event” refers to any circumstance or event beyond the reasonable control of a party affecting the general public in the party’s country or region, which results in the party’s inability to comply with or perform its obligations under these Terms and Conditions in a timely manner. Such events include but are not limited to industrial action or labor disputes, civil unrest, war or threats of war, criminal or terrorist acts, government actions or regulations, telecommunications or utility failures, power outages, fire, explosions, natural disasters, epidemics, quarantine restrictions, and public transportation shutdowns.

“Website” refers to www.cairin.id, including all domains and sub-domains operated and owned by us.

“Cairin” or “We” PT Idana Solusi Sejahtera, established under the laws of the Republic of Indonesia as the provider of the Services.

2. GENERAL TERMS OF USE

2.1 The services available on this Website and/or Application are intended for and may only be used by:

(a) individual users who are at least 21 years old and possess the legal capacity, rights, and authority necessary to agree to these Terms and Conditions; and

(b) individual users who are Indonesian citizens. Cairin may, at its sole discretion, grant approval to users under 21 years old.

2.2 You shall use the Services available on the Website and/or Application solely for lawful purposes and not in violation of any applicable laws.

2.3 All information provided by you, including but not limited to personal data, must be accurate and truthful.

2.4 Loan limits through the Application range from IDR 200,000 (Two Hundred Thousand Rupiah) to IDR 80,000,000 (Eighty Million Rupiah). However, if the prospective Borrower meets certain criteria, we may increase the loan limit in accordance with other applicable terms and conditions, particularly considering the funding facility limits adjusted to your transaction capability.

2.5 Cairin does not charge any fees in connection with loan applications submitted by prospective Borrowers.

2.6 Cairin reserves the right to conduct feasibility assessments on prospective Borrowers. During this process, Cairin may contact institutions, companies, or individuals to obtain information, verify, and confirm details related to the prospective Borrower, including (but not limited to) legal and credit history records. Prospective Borrowers are required to provide consent and authorization for Cairin to undertake these actions.

3. PERSONAL DATA MATTERS

3.1 GENERAL

By using the Services, you consent to Cairin collecting, storing, processing, disclosing, accessing, reviewing, and/or utilizing your personal data (including sensitive personal information) obtained either directly from you or from other lawful sources, including but not limited to accessing your device’s camera, location, and microphone.

We ensure that all personal data transmitted by you through the Website and/or Application is securely protected and encrypted, including through the use of available SSL/TLS technology.

Cairin agrees to maintain the confidentiality of all personal data and shall not use such data for any purpose other than providing loan facilities. However, this does not apply to:

(i) prevention of fraud and/or matters related to anti-money laundering and counter-terrorism financing;

(ii) personal data that is publicly known and was not obtained through any unlawful breach;

(iii) personal data lawfully obtained by Cairin without violating confidentiality from other sources;

(iv) personal data required to be disclosed by law, government, or authorized agencies under applicable regulations;

(v) personal data disclosed in any litigation process;

(vi) persons acting as legal counsel, colleagues, or authorized third parties in accordance with legal provisions;

(vii) matters required by statutory regulations.

By using the Services and accessing the Website and/or Application, you acknowledge and agree that all communications from Cairin related to the Services will be delivered electronically via email, telephone, or published on the Website and/or Application.

You agree to receive all documents, notices, and agreements electronically arising from your use of the Services via the Website and/or Application, whether as a Fund Provider or Borrower. Your consent to any such electronic documents, notices, and agreements is given through electronic signature and shall be fully binding and enforceable upon you as a user of the Services via the Website and/or Application, including all rights and obligations arising from such consent.

4. ACCURACY OF PERSONAL DATA

4.1 By accessing the Website and/or Application and using the Services, you warrant that all personal data you provide through the Website and/or Application is genuine and accurate. The personal data you submit must be true, accurate, complete, up-to-date, and not misleading. In the event of any document forgery or other criminal acts committed by you, Cairin reserves the right to pursue legal action, including reporting such matters to the relevant authorities.

4.2 You acknowledge your obligation to:

(a) promptly update and notify Cairin of any changes to your personal data as soon as such changes occur; and

(b) maintain the confidentiality of your password and personal data.

4.3 If Cairin discovers, either immediately or at a later time, that the personal data you have provided is false, suspected to be fraudulent, and/or inaccurate, Cairin reserves the right to block your access to the Website and Application. You shall be fully responsible for any damages and losses, whether material or immaterial, arising or that may arise from any inaccuracies in the personal data you provide.

5. COOKIES POLICY

This Website uses Cookies, which you must consent to in order to fully enjoy the features of the Website. The Cookies we use record which parts of the Website you visit and the duration of your visits. You have the right to refuse the use of Cookies by configuring your web browser settings. Please note that such configurations may interfere with some functionalities of the Website.

6. INTELLECTUAL PROPERTY RIGHTS

6.1 The intellectual property rights of this Website and/or Application, including but not limited to copyrights, patents, and trademarks owned by or licensed to Cairin, are fully owned by and remain the permanent assets of Cairin.

6.2 You are permitted to view and print content provided on the Website and Application; however:

(a) all such copies remain the intellectual property of Cairin and third parties licensed by us; and

(b) you must not alter, in any way, printed copies of materials, including removing any copyright or other proprietary notices contained in the Website and/or Application.

6.3 You agree not to use any part of this Website and Application to:

(a) introduce or intentionally or unintentionally transmit or distribute any viruses, worms, Trojan horses, time bombs, backdoors, or any other computer codes, files, or programs designed to disrupt, damage, or limit the functionality of any software, hardware, telecommunications equipment, or degrade the quality, disrupt the display, or damage the functionality of the Website and Application;

(b) upload, post, email, or otherwise transmit or receive links to any content that facilitates data hacking;

(c) hack or attempt to hack any part of the Website and Application;

(d) upload, email, or transmit links to any content that infringes on the intellectual property rights of third parties;

(e) circumventing or attempting to circumvent any security measures of the Website and Application;

(f) allowing any third party to perform any of the actions described above;

(g) if you use content from the Website and Application but fail to comply with these terms, your rights to use the Website and Application will be immediately revoked;

(h) no links from other websites to this Website and Application are permitted without our prior written consent. You are not entitled to rename, modify, or redistribute content from the Website and Application without our authorization.

7. OTHER APPLICABLE DOCUMENTS

7.1 In addition to these Terms and Conditions, the following also apply to your use of the Services through the Cairin Website and Application:

(a) Loan Terms and Conditions; and

(b) Other agreements with Cairin that govern your use of the Services.

7.2 In the event of any conflict between these Terms and Conditions and any other agreements applicable to specific aspects of the Services, the other agreements shall prevail with respect to the specific aspects of the Services to which those agreements apply.

8. AMENDMENTS TO THE TERMS AND CONDITIONS

8.1 Cairin reserves the right to amend these General Terms and Conditions at its sole discretion from time to time. Any changes to these Terms and Conditions shall take effect immediately upon being posted on the Website and/or Application.

8.2 You acknowledge and agree that by continuing to use the Services through the Website and/or Application after such changes are made, you are deemed to accept and be bound by the updated Terms and Conditions.

9. SEVERABILITY

If any provision or part of these Terms and Conditions is declared wholly or partially invalid or unenforceable under any applicable law or regulation to any extent, such provision or part shall be considered severable from these Terms and Conditions and shall not affect the validity or enforceability of the remaining provisions. Cairin’s failure to enforce any rights or provisions of these Terms and Conditions shall not be construed as a waiver of such rights or provisions under any circumstances.

10. LIMITATION OF LIABILITY

10.1 Cairin and its employees shall not be liable and shall have no obligation to provide compensation for any breach of these Terms and Conditions, Loan Terms and Conditions, or other agreements with Cairin governing your use of the Services that is caused by you.

10.2 Please be aware that messages transmitted via internet connections cannot be guaranteed to be completely secure and may be delayed, lost, or altered. We are not responsible for messages lost, altered by third parties, or delayed, and shall not be materially liable to you or any other party for damages or any consequences arising from messages sent by you to us or by us to you via the internet connection.

11. FORCE MAJEURE EVENTS

No party shall be held liable for any failure to perform its obligations under these Terms and Conditions if such failure is caused by a Force Majeure Event. Provided always that, if possible, the affected party shall resume performance of its obligations promptly after the Force Majeure Event causing such failure ceases or subsides.

12. INDEMNITY

You agree to release, indemnify, and hold harmless Cairin, its affiliates, shareholders, directors, commissioners, employees, subcontractors, suppliers, and agents from and against any claims, lawsuits, demands, losses, damages, including legal consultant fees, arising from your breach of these Terms and Conditions or any other provisions established by Cairin.

13. COLLECTION MECHANISM

Cairin has the right to take all necessary actions in accordance with applicable regulations, including conducting collections internally, together with the Funding Providers, or by appointing competent third parties to perform collection activities against the Borrower in accordance with the law, if the Borrower fails to fulfill all payment obligations related to their loan application. Please be informed that based on your written agreement to these Terms and Conditions, loan collection activities through the Cairin Application are conducted by Cairin’s team every day, Monday through Sunday, including national holidays, from 08:00 to 20:00 local time at the Borrower’s address or domicile provided through the Cairin Application.

14. RISK MITIGATION

Please be informed that the risk mitigation measures Cairin may take in the event of a default by the Borrower include:

(a) conducting a risk analysis of the Borrower’s loan application;

(b) verifying the identity and authenticity of documents of prospective Borrowers and Funding Providers;

(c) conducting reasonable collections in accordance with Article 13 of these Terms and Conditions;

(d) facilitating the transfer of funding risk; and

15. TERMINATION

You agree that in the event of any violation by you of the provisions in these Terms and Conditions or applicable law, Cairin may unilaterally and without prior notice delete your account on the Website and Application, restrict your access to the Website and Application, or terminate the Services to you. You agree that any material or immaterial losses arising from the deletion of your account and/or restriction of access as mentioned above shall be your sole responsibility.

16. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms and Conditions and any non-contractual obligations arising from or in connection with them shall be governed by the laws of the Republic of Indonesia.

You agree that any legal actions or disputes arising from or related to the use of the Website and Application shall be finally resolved and adjudicated by the South Jakarta District Court.

17. CONTACT US

For further information, you may visit our FAQ page or contact us via telephone at 021 - 24163377, live chat service, or email at cs@cairin.id

This Privacy Policy is established to protect the privacy and confidentiality of users of the Cairin Platform. Users are expected to read this Privacy Policy before using any services provided through the Platform by clicking, accessing, and/or utilizing the services therein.

By accessing and using the services on this Platform, you are deemed to have read, understood, accepted, and agreed in writing to the contents of this Privacy Policy. If you do not agree with this Privacy Policy, please DO NOT access or use the services available on the Cairin Website or Application.

By accepting this Privacy Policy, you agree that it is legally binding as though this agreement were personally signed and executed in writing.

1. DEFINITION/INTERPRETATION

Unless stated otherwise within other sections of this Privacy Policy, the following terms shall have the meanings as defined below:

“You” (and all grammatical variations thereof) refers to the Recipient, the Lender, or any other person using the Platform and/or Services, whether registered or not.

“Personal Data” includes all data, statements, information, and documents, whether electronic or non-electronic (excluding Emergency Contact Numbers), relating to or concerning the User (either Recipient or Lender, as applicable) and/or related parties (including but not limited to family members, colleagues, employees, companies, or service providers of the User, where required), which are received or accessed by Cairin from the User, submitted, provided, or disclosed by the User to Cairin with the User’s consent, and stored and managed in relation to the provision of services on the Platform and the User’s utilization thereof.

“Default” means an event in which the Recipient has violated the loan repayment terms, including interest, penalties, and other financial obligations as stated in the Loan Agreement, for any reason whatsoever, whether intentional or due to negligence. This includes, but is not limited to, breaching the repayment schedule and/or loan amount as outlined in the Loan Agreement or its amendments from time to time (if any).

“We” or “Cairin”, depending on context, refers to PT Idana Solusi Sejahtera, operating the “Cairin” platform— a licensed and regulated financial technology company supervised by the Financial Services Authority (OJK), conducting LPBBTI activities through the Platform and subject to all relevant laws and regulations governing LPBBTI, including but not limited to OJK Regulation No. 40 of 2024 (“POJK 40”) on Information Technology-Based Joint Financing Services and its implementing regulations for the purpose of providing loans to Recipients. “We” or “Cairin” also includes Cairin's authorized employees and representatives.

“Power of attorney” refers to the authorization granted in accordance with Article 1792 of the Indonesian Civil Code by the Lender to Cairin to represent and act for and on behalf of, as well as in the best interest of, the Lender in order to:

(a) Declare agreement, draft, negotiate, sign, implement, and/or restructure the Financing Agreement;

(b) Collect repayments from the Borrower under the agreed-upon Financing Agreement, receive and return the funds from such repayments to the Lender; and

(c) other related actions as necessary required for the implementation of Funding Agreement, compliance to POJK 10, circular letter from OJK and laws and regulations that affect or need to be taken into account regarding LPBBTI, agreements between Lender and Cairin and the fulfillment of rights and obligations of the Lender based on the agreement between the Lender and the Borrower.

“Service” refers to the financial service provided by Cairin through the Platform that facilitates the meeting of Lenders and Recipients for the purpose of conducting LPBBTI activities related to the distribution of Loans to Recipients.

“LPBBTI” stands for Information Technology-Based Joint Financing Services, also known as peer-to-peer lending, which channels Loans from Lenders to Recipients in accordance with the terms and implementation as governed by POJK 40 and SEOJK 19.

“Emergency Contact” refers to the phone number of an individual listed by the Recipient during the loan application process on the Platform. This number, with the prior consent of its owner, may be contacted by Cairin in the event that the Recipient is categorized as being in Default.

“Inactive Emergency Contact” has the meaning as defined in Article 4.4 of this Privacy Policy.

“Platform” refers to the website and/or mobile version of the site developed, owned, and operated by Cairin, currently accessible at www.cairin.id, including any future changes to the URL.

“Lender” refers to a party registered on the Platform who provides and disburses Loans to Recipients through the Platform.

“Recipient” refers to a party registered on the Platform to receive funding in the form of Loans from Lenders through the Platform.

“User” refers to the Lender, as a party to the agreement between the Lender and Cairin, and the Recipient, as a party to the agreement between the Lender and the Recipient, both of whom are registered on the Platform.

“Loan” refers to the loan facility (including interest, penalties, and other financial obligations) disbursed by the Lender to the Recipient through the Platform, based on an agreement between the Lender and the Recipient.

“POJK 40” refers to Financial Services Authority Regulation No. 40/2024 concerning Information Technology-Based Joint Financing Services, as amended, supplemented, or modified from time to time.

“SEOJK 19” refers to Circular Letter No. 19/SEOJK.06/2023 of the Financial Services Authority of the Republic of Indonesia concerning the Implementation of Information Technology-Based Joint Financing Services.

“ITE Law” refers to Law No. 11 of 2008 concerning Electronic Information and Transactions, as most recently amended by Law No. 19 of 2016, including all implementing regulations, amendments, modifications, and/or additions made from time to time.

“PDP Law” refers to Law No. 27 of 2022 on Personal Data Protection, including all implementing regulations, amendments, modifications, and/or additions made from time to time.

2. INTRODUCTION

2.1 By obtaining a Loan from the Lender through the Cairin application—based on the agreement between the Lender and the Recipient—and for as long as the Recipient remains a party to any agreement with the Lender and holds financial obligations under such agreement, the Recipient is deemed by law to have accepted all provisions of this Privacy Policy, particularly those concerning the use of Emergency Contact Numbers as stipulated in Article 4 of this Policy. This acceptance is made voluntarily, without coercion or fraud, and without the need for any formality or procedural requirements for its legal validity.

2.2 The Recipient’s consent as referred to in Article 2.1 above shall remain valid unconditionally and irrevocably until the termination of the legal relationship and the full settlement of all financial obligations by the Recipient under the agreement with the Lender.

2.3 The Recipient’s electronic consent as referred to in Article 2.2 above shall be:

(a) deemed equivalent to consent as defined in Article 1320 of the Indonesian Civil Code as a valid condition of a contract;

(b) qualified as a valid legal means of evidence under Article 5 paragraph (1) of the Electronic Information and Transactions Law (ITE Law); and

(c) recognized as a legal evidentiary instrument under the civil procedure framework pursuant to Article 1865 of the Indonesian Civil Code.

2.4 Cairin has ensured transparency and thorough disclosure regarding the contents of this Privacy Policy, including the use of Emergency Contact Numbers during the loan application process as detailed in Article 4. Therefore, the Recipient is considered to have thoroughly understood the Privacy Policy, as evidenced by the unequivocal acceptance of the Loan through the Platform.

2.5 With the enforcement of the provisions concerning the use of Emergency Contact Numbers as regulated in Article 4 of this Privacy Policy, Cairin expects that:

(a) The Recipient will act as a responsible consumer by fulfilling their promises and commitments to repay the Loan in accordance with the agreement with the Lender, just as Cairin has fulfilled its responsibility to disburse the Loan efficiently, securely, and effectively to the Recipient, with the entire transaction record and application process flow recorded within Cairin’s information system; and

(b) The Recipient will exercise good faith in fulfilling their repayment obligations on time and in full, avoiding any disputes related to Default with Cairin. In doing so, the Recipient can be categorized as a responsible borrower in a responsible lending ecosystem that complies with applicable laws and regulations.

3. PERSONAL DATA

Use of Personal Data

3.1 During your use of the Services, we are entitled to request, obtain, collect, store, manage, and use your Personal Data (where necessary), which may be obtained through, but not limited to, the following means:

(a) completion of forms or data entries on the Platform;

(b) device information, including data on applications downloaded by the User. The downloaded application data includes the application name, package name, download time, and installation time. Purpose: To monitor and collect information on the applications downloaded by Users in order to identify and analyze their behavior, assess loan risks, and detect potential money laundering activities. If our automated detection system flags a risk during transaction processing or loan approval, the User’s transaction will be rejected;

(c) visits to and usage of the Platform while the User accesses it; and

(d) other information obtained via the Platform, email, phone, or other media.

3.2 You hereby consent that we are entitled to request, obtain, collect, process, store, and use the Personal Data you provide through the Platform for, but not limited to, the following purposes:

(i) applications or applications for obtaining loans;

(ii) process or application for registration as a Lender or Borrower; and/or

(iii) your profile;

(b) risk assessment, statistical analysis, and trend planning, including data processing, statistical and credit analysis, risk assessment, anti-money laundering (AML) procedures, development and management of credit scoring models, credit background checks, and storing your credit history and that of your authorized representatives for current and future reference;

(c) managing Cairin’s relationship with you, including providing you with Platform-related information and enabling your access to the Services;

(d) sending notifications via email;

(e) contacting you regarding your requests;

(f) fraud prevention and detection, including the use of voice recognition technology to analyze recordings of your phone conversations with us;

(g) general business purposes, such as verifying your identity and assessing your credit reputation;

(h) identifying you when you contact us or visit the Platform;

(i) sending commercial marketing and non-marketing communications to you;

(j) sending notifications or email newsletters if previously requested by you;

(k) providing sufficient information on the Platform to identify you to Lenders and/or Recipients;

(l) allowing you to participate in our interactive feature services;

(m) permitting banks, financial institutions, or authorized third parties to perform limited status checks on your data in our databases or Services;

(n) handling inquiries or complaints made by or about you in relation to the Platform and retaining them to prevent fraud;

(o) verifying your compliance with the terms and conditions governing your use of the Platform;

(p) conducting surveys, research, evaluations, and/or product or Service development by Cairin or relevant stakeholders;

(q) managing your escrow account with the designated escrow account provider;

(r) performing AML (anti-money laundering) and counter-terrorism financing checks in the financial services sector;

(s) fulfilling legal, regulatory, and compliance obligations applicable to Cairin, the Platform, and its Services, in accordance with applicable laws and any relevant agreements;

(t) executing orders or policies issued by the government, regulatory authorities, or competent agencies; and

(u) notifying you of any changes to the Platform and/or the Services.

3.3 Personal Data that you submit to us for publication on the Platform will be used in accordance with the purpose for which it was submitted and the consent you provided.

3.4 We may disclose your Personal Data if:

(a) required by applicable laws or regulations;

(b) there is an ongoing or upcoming legal process;

(c) there are suspicions of criminal acts, including but not limited to fraud or money laundering;

(d) it is required by competent authorities or government bodies; or

(e) we have obtained your written consent.

3.5 If you provide incorrect or inaccurate information, or if we suspect fraudulent activity, we reserve the right to record such information in your credit history and share it with the appropriate legal authorities or fraud prevention agencies.

Storage of Personal Data

3.6 All Personal Data provided by you and/or received by us in accordance with this Privacy Policy shall be securely stored within the territory of the Republic of Indonesia.

3.7 Cairin shall retain Users’ Personal Data for a minimum period of five (5) years, or for as long as deemed necessary to protect Cairin’s legitimate interests, or as otherwise required by applicable laws and regulations.

Security of Personal Data

3.8 We will take all reasonable steps and actions to prevent the loss, misuse, or alteration of your Personal Data by unauthorized parties.

3.9 We further guarantee that all Personal Data submitted to us will be stored securely on our servers. Our security systems comply with industry standards, and we continuously monitor internet developments to ensure our systems remain up to date. We also conduct periodic testing of our systems to ensure our security mechanisms are current, and we strictly comply with applicable data protection laws and regulations in Indonesia.

3.10 Despite the preventive measures we take, we cannot fully guarantee the security of data transmitted to us over the internet, as there may be unauthorized third parties who unlawfully access or use such data without our consent. Nonetheless, we will make our best efforts to limit unauthorized access to your Personal Data.

3.11 When registering on the Platform, you will be required to create your own personal password. You are responsible for maintaining the confidentiality of this password. We strongly advise you not to share or disclose your password to any unauthorized parties. We will never request your password, except for the purpose of logging into the Platform.

Return and Destruction of Personal Data

3.12 Your Personal Data may only be destroyed if:

(a) the applicable retention period of five (5) years has lapsed or as required by applicable laws and regulations; or

(b) requested by you, unless otherwise specified by applicable laws and regulations.

3.13 Destruction as referred to in Article 3.12 includes the deletion, in whole or in part, of documents relating to your Personal Data stored by us, such that the data can no longer be displayed or retrieved in our electronic systems, unless you provide new Personal Data.

Modification of Personal Data

3.14 We understand that you may need to update or correct your information from time to time. When an update is required, you may submit a written request via email with the relevant details. We will assist in updating and/or correcting your information if such changes are deemed necessary.

Return and Deletion of Personal Data

3.15 You have the right to request the return of your Personal Data previously submitted to us, subject to the following conditions:

(a) you are not currently bound by any agreement related to the Services provided through the Platform, including agreements between Lenders and Recipients or between Lenders and Cairin;

(b) you do not hold any rights in relation to the Services on the Platform, including but not limited to rights of repayment or collection;

(c) you do not have any financial obligations, outstanding debts, or similar liabilities related to the Services;

(d) you are not in the process of applying for a loan, including undergoing verification and assessment by Cairin; and

(e) you are no longer an active registered User (i.e., you have deactivated your account).

3.16 Requests for the return of Personal Data must be submitted to us via email at cs@cairin.id, along with valid identification (a copy of your national ID or passport) and the reason for the request.

3.17 You have the right to request the deletion of your Personal Data by providing written notice at least fourteen (14) business days prior to the requested deletion date, stating the type or form of Personal Data to be deleted. Such data must be proven to have been obtained from, requested by, or required by Cairin. The deletion of Personal Data must be carried out in accordance with applicable regulations, including the Personal Data Protection Law (PDP Law).

4. USE OF EMERGENCY CONTACT NUMBER

Purpose of Emergency Contact Number Usage

4.1 The Emergency Contact Number provided by the Recipient during the loan application process ("Loan Application") will be used exclusively by Cairin to contact the owner of said Emergency Contact Number when the Recipient is in a state of Default, and only after prior consent has been obtained from the owner of the Emergency Contact Number regarding its inclusion.

Cairin’s Right to Contact the Emergency Contact

4.2 As an essential condition for utilizing the Loan through the Platform, the Recipient hereby authorizes Cairin—with notification to and/or prior approval from the Emergency Contact Number’s owner—to contact the said party ("Emergency Contact Owner") in the event that the Recipient is in Default, for the following purposes:

(a) to search for or trace the whereabouts of the Recipient when the Recipient has not repaid the Loan and cannot be reached or is difficult to contact via the registered mobile number listed on the Platform at the time of the Loan Application;

(b) to request assistance from the Emergency Contact Owner in reminding the Recipient to make and complete the Loan repayment; and/or

(c) to request the Emergency Contact Owner to convey a message from Cairin regarding the obligation to repay the Loan and the Default status—without demanding any payment from the Emergency Contact Owner.

4.3 Cairin may contact the Emergency Contact Owner for the above purposes via, but not limited to, direct phone calls, SMS (Short Message Service), WhatsApp, and/or other methods in accordance with applicable laws and regulations. In corresponding with the Emergency Contact Owner, Cairin shall refrain from any form of intimidation, threats, or other unlawful conduct, including refraining from sending the Recipient’s photo to the Emergency Contact Owner.

Preventive Measures Regarding “Inactive Emergency Contact Numbers”

4.4 The Emergency Contact Number listed by the Recipient during the Loan Application process and recorded on the Platform will be considered an “Inactive Emergency Contact Number” if:

(a) it is unanswered or receives no response;

(b) it is unregistered, inactive, non-functional, or permanently unused; and/or

(c) it has been reassigned to a third party unrelated to the Recipient or is used by someone who claims not to know the Recipient.

Release of Liability for Cairin

4.5 The Recipient hereby releases, defends, and holds harmless Cairin and/or the Lender (including their employees, directors, commissioners, shareholders, representatives, agents, attorneys, and/or affiliates) from any loss, expense, cost, or liability arising from or in connection with:

(a) disputes with third parties related to the Emergency Contact Number for any reason or cause of dispute;

(b) infringement of rights or damages suffered by third parties or any party in relation to the Emergency Contact Number;

(c) sanctions, investigations, inquiries, inspections, audits, or any consequences arising from or related to violations of laws and/or regulations, government policies, or court/arbitration decisions resulting from or connected to Cairin’s exercise of rights under this clause or efforts to contact, access, trace, obtain, and/or use the Emergency Contact Number.

5. USER RIGHTS

In connection with the use of the Services on the Platform, Users have the right to:

(a) the confidentiality of their Personal Data and Emergency Contact Number;

(b) submit a complaint to the Minister in the event of a dispute regarding the failure of Personal Data protection by us;

(c) access or request the completion, correction, modification, or update of their Personal Data without disrupting the management system, unless otherwise stipulated by applicable laws and regulations;

(d) access or request a copy of the history of their submitted Personal Data as long as it remains in accordance with applicable laws and regulations;

(e) request the deletion of their Personal Data managed by us, unless otherwise required by law; and

(f) determine the classification of their Personal Data as confidential or non-confidential (if necessary).

6. DISCLAIMER OF LIABILITY

6.1 You agree not to hold us liable for any violations or non-compliance with this Privacy Policy or the protection of Personal Data under the following circumstances:

(a) where acts of nature or unforeseeable events occur that result in damage to or destruction of the equipment and/or systems used to secure, store, or process the User’s Personal Data;

(b) where the Personal Data was already publicly available or discoverable before it was submitted to us;

(c) where unauthorized access, hacking, misuse, modification, alteration, or disruption occurs despite our reasonable efforts to verify, secure, and protect the Personal Data we collect;

(d) regarding the accuracy (except for Personal Data verified by Cairin in accordance with its policy), validity, legality, and completeness of your Personal Data—we are not obligated to notify you or any third party of such issues unless required by law; and/or

(e) where misuse of Personal Data or information occurs as a result of criminal acts, fraud, or any wrongdoing committed by third parties beyond our control or instruction.

6.2 We will make reasonable efforts to provide written notification to you via email in the event of a failure to protect the confidentiality of your Personal Data in the management of the Platform—either caused by us or once we become aware of such failure from a third party. Such notice will include the following:

(a) the reason or cause of the failure in protecting Personal Data confidentiality;

(b) written notice via email to you no later than fourteen (14) calendar days from the time the failure is identified;

(c) the provision of a contact person who can be easily reached by you in relation to the management of your Personal Data.

7. COOKIES

7.1 By visiting and using the Platform, you acknowledge that cookies may be installed on your device. Cookies are files that store information such as your browsing history or collect internet log data and visitor behavior information. When you return to the Platform, these cookies help us tailor content to better suit your needs. These cookies do not individually track Users, and all our cookie data is encrypted and unreadable by other platforms.

7.2 Although your computer or device will automatically accept cookies, you have the option to modify your browser settings to reject cookies by deleting the installed cookies from your device at any time through your browser software configuration. However, if cookies are deleted or prevented from being installed on your device, you may not be able to benefit from certain Services on the Platform.

8. PRODUCT AND SERVICE OFFERS AND/OR MARKETING

Please note that, based on your written consent to this Privacy Policy, we may offer various products and services to you through the Cairin team from Monday to Sunday, including public holidays, between 08:00 and 20:00 local time. If you choose not to receive such offers, please contact us at cs@cairin.id.

9. SOCIAL MEDIA ACCESS

9.1 In providing Services through the Platform and for the purpose of credit risk assessment, we may request your permission to access your social media accounts, including but not limited to Instagram, Twitter, Facebook, Google+, and/or LinkedIn.

9.2 You are not required to grant access to your social media accounts. However, please note that access to your social media data may increase your chances of being approved for a loan with us.

9.3 If you grant us access to your social media account data, please understand that such data will only be used for the following purposes:

(a) identity verification;

(b) mitigation of identity fraud risk;

(c) statistical and quantitative analysis;

(d) regulatory control;

(e) providing information and responding to inquiries; and

(f) preventing fraud, money laundering, and other criminal activities.

9.4 We will not use your data for any purposes other than those stated above, including but not limited to:

(a) sharing or selling your data, directly or indirectly, to any third party;

(b) posting any content to or on your social media accounts, including but not limited to references to your association with Cairin;

(c) contacting any of your connections on your social media network.

10. CHANGES TO THE PRIVACY POLICY

10.1 This Privacy Policy may be updated, revised, or modified from time to time to reflect changes in legal, regulatory, or operational requirements. We recommend that you review this Privacy Policy periodically to stay informed of any updates or changes.

10.2 By continuing to access and use the Platform and Services after such changes are published, you are deemed to have agreed to the updated version of the Privacy Policy.

10.3 Any material changes to this Privacy Policy will be communicated to you via the contact information you provided, or through notifications on the Platform.

11. MISCELLANEOUS

This Privacy Policy has been prepared in accordance with applicable laws and regulations, including but not limited to POJK 40, SEOJK 19, the Electronic Information and Transactions Law (ITE Law), the Personal Data Protection Law (PDP Law), and other relevant regulations.

12. CONTACT

If you have any questions, comments, or requests regarding this Privacy Policy, you may contact us at cs@cairin.id.