Privacy Policy for Fonesia.com

Fonesia.com (“we,” “our,” or “us”) is a trusted digital escrow platform (Rekening Bersama) fully committed to protecting the privacy, security, and rights of our users (“you” or “your”). Our services are compliant with the legal standards set by the Otoritas Jasa Keuangan (OJK) of Indonesia. This Privacy Policy outlines, in excruciatingly detailed and comprehensive terms, how we collect, process, use, disclose, retain, and protect your personal information when you interact with our platform, access our website, use our applications, or engage in any transactions through Fonesia.com. We recommend that you read this document in full—even though it is extraordinarily long—to understand your rights and our practices.

1. Scope and Application

This Privacy Policy applies to all information collected through our services, whether accessed via desktop, mobile browser, native application, or any other device, platform, or method. This policy covers all users including but not limited to buyers, sellers, affiliates, vendors, partners, third-party service providers, and internal stakeholders.

2. Information We Collect

We collect several types of information to facilitate transactions and to ensure legal compliance and operational excellence. These include but are not limited to:

a. Personal Identification Information

• Full name

• Date of birth

• National ID (KTP/Paspor/SIM)

• Taxpayer Identification Number (NPWP)

• Photographic identification

• Selfies for biometric validation

• Digital signatures

b. Contact Information

• Email address

• Phone numbers

• Physical address (billing and shipping)

• Emergency contact details

c. Financial Information

• Bank account number

• E-wallet details

• Credit/debit card information (if applicable)

• Transaction history

• Escrow-related communications

d. Device and Technical Information

• IP address

• MAC address

• Browser type

• Operating system

• Device type and unique device identifiers

• GPS location data

• Clickstream data

e. Behavioral Data

• Pages visited

• Links clicked

• Session duration

• Scroll behavior

• Heatmap tracking

3. Use of Information

We utilize your data to operate, enhance, and personalize your experience. This includes verifying identities, processing transactions, delivering customer support, conducting audits, sending alerts, and improving the performance of our systems.

4. Data Storage and Retention

Your data is stored on secure servers located within jurisdictional compliance zones. We retain personal data for as long as necessary to fulfill our legal, contractual, and operational obligations.

5. Legal Basis for Processing

We process data based on your consent, legitimate interest, legal obligations, and contractual necessity.

6. Disclosure of Information

We may share data with trusted third-party service providers, regulatory authorities, legal enforcement bodies, and affiliated entities only when legally required or contractually permitted.

7. Biometric Data Policy

We collect facial recognition data for identity validation. This information is encrypted, stored separately, and never shared with unauthorized entities.

8. Cookies and Tracking Technologies

We use cookies, beacons, scripts, and similar technologies to gather behavioral data and improve user experience.

9. Third-Party Services

This policy does not apply to third-party websites or platforms linked from Fonesia.com. We advise reviewing their respective privacy policies.

10. Children’s Privacy

Fonesia.com does not knowingly collect data from individuals under 18 years of age.

11. Security Measures

We implement SSL encryption, multi-factor authentication, and real-time monitoring systems to secure your data.

12. International Transfers

If data is transferred internationally, it is done in compliance with applicable data protection regulations.

13. User Rights

You have the right to access, rectify, delete, restrict processing, object to processing, and data portability as per applicable law.

14. Consent Management

You may withdraw your consent at any time. Withdrawal will not affect processing prior to that point.

15. Data Breach Notification

In the event of a breach, affected users will be notified within 72 hours with full details.

16. Whistleblower Protection

Internal stakeholders are protected under our whistleblower policy when reporting unethical data practices.

17. Data Minimization

We only collect data that is necessary for our operational and compliance needs.

18. AI and Automated Decision-Making

We employ AI for fraud detection and performance analytics. Human oversight is enforced.

19. Vendor Management

We audit all third-party vendors for data security compliance.

20. Pseudonymization and Anonymization

Data may be pseudonymized or anonymized for research, analytics, or legal reporting.

21. User Preferences and Settings

You may adjust your privacy settings and notification preferences through your account dashboard.

22. Behavioral Profiling

Behavioral data is used solely for service enhancement and is never sold to advertisers.

23. Cross-Border Disputes

Disputes related to international users are subject to arbitration under Indonesian law.

24. Consent for Marketing

We only send promotional emails or messages with explicit user consent.

25. Regulatory Compliance

We comply with Indonesian UU ITE, GDPR (where applicable), and OJK’s regulatory framework.

26. Blockchain Record Integrity

For escrow services, transaction data may be recorded on secure, immutable blockchain logs.

27. Internal Access Control

Only authorized employees may access personal data on a need-to-know basis.

28. Training and Awareness

Our staff undergo routine privacy and cybersecurity training.

29. Auditing and Monitoring

Periodic audits ensure data policy adherence and incident response readiness.

30. Legacy Data

Archived data is stored with reduced access and additional encryption layers.

31. Data Deletion Requests

You may formally request complete data erasure subject to legal limitations.

32. Two-Factor Authentication (2FA)

You may enable 2FA to enhance account security.

33. Incident Response

We maintain a structured protocol to handle security incidents promptly and transparently.

34. Policy Updates

Users will be notified via email or dashboard of material changes to this Privacy Policy.

35. Accessibility

This Privacy Policy is designed to be accessible to users with disabilities.

36. VPN and Proxy Use

VPN usage is permitted but may require additional verification steps.

37. Biometrics Revocation

Users may revoke consent for biometric data at any time with written request.

38. Integration with Government Systems

Where legally required, identity verification may be integrated with government databases.

39. AI Review Board

An internal board reviews all AI-related features to ensure compliance and ethical alignment.

40. Temporary Session Data

Session data is retained only for the duration of an active session unless opted otherwise.

41. Cross-Platform Synchronization

Your preferences and data may be synchronized across devices securely.

42. Non-Discrimination

We do not discriminate users who exercise their privacy rights.

43. Offline Access Protection

Cached data for offline use is encrypted and cleared after a defined period.

44. End-of-Life Data Protocols

In cases of user death, a data succession protocol is available for verified relatives.

45. Biannual Policy Review

This policy is reviewed and updated at least twice a year.

46. External Ethical Audits

We may appoint independent auditors to review our privacy practices.

47. Licensing and Certifications

Our platform holds licenses and certifications that reflect compliance with privacy standards.

48. Custom User Agreements

Enterprise clients may request tailored privacy terms via special agreements.

49. Consent Logs

All user consent is logged with timestamp and context.

50. Your Acknowledgment

By using Fonesia.com, you acknowledge you have read and understood this Privacy Policy in its entirety, no matter how lengthy it may be. This document serves as a binding agreement between you and Fonesia.com.