TRUEMONEY APPLICATION TERMS AND CONDITIONS
(TrueMoney Wallet Indonesia)
These Terms and Conditions applies to all Users of TRUEMONEY Application which Services are
provided by PT Witami Tunai Mandiri ("TRUEMONEY INDONESIA") or (“Our”) in
connection with the use and access of TRUEMONEY Application.
1. TRUEMONEY INDONESIA is a server-based electronic money operator established and
managed by PT. Witami Tunai Mandiri domiciled in Millennium Centennial Center, 36th
Floor, Jl. Jend Sudirman Kav 25, Kuningan-Setiabudi, South Jakarta, 12920, which is duly
licensed and supervised by Bank Indonesia, namely:
a) Electronic Money Issuer as concluded in Letter No. 16/129/DKSP dated July 18, 2014
as extended by Letter No. 20/259/DKSP/Srt/B dated July 12, 2018 issued by the
Payment System Policy Department or “DKSP” (Departemen Kebijakan Sistem
b) Fund Transfer Provider as concluded in Certificate No. 16/152/DKSP/58 dated July
2. TRUEMONEY ID means the identity of TRUEMONEY Application Users for the purpose of
accessing the Services, and the mobile application.
3. KYC means Know Your Customer Principle as a series of further stages of Customer Due
Diligence, KYC is an action for the identification, verification, and monitoring process of
prospective Users conducted by TRUEMONEY INDONESIA prior to the prospective Users
being approved by TRUEMONEY INDONESIA as users of TRUEMONEY Application services.
4. Dormant Account means registered account of TRUEMONEY Agent or TRUEMONEY Member
which within a certain period of time does no Transaction .
5. Services consists of Electronic Money and Fund Transfer services that allow Users to have
limit balance in TRUEMONEY Application.
6. TRUEMONEY Agent means any certain individuals or entities partnering with TRUEMONEY
INDONESIA to distribute Services to Members and non-Members, through Android-based
7. Merchant means any retail stores or third parties under agreement with TRUEMONEY
INDONESIA that offer Products and Services to Users.
8. Members mean TRUEMONEY Application Users to whom CDD or KYC has been or has not
9. Users mean any individuals who use TRUEMONEY Application Services.
10. Unregistered Users mean TRUEMONEY Application Users to whom CDD or KYC process has
not been conducted thus the benefits must be distinguished from Registered Users in
accordance with applicable Bank Indonesia regulations.
11. Registered Users mean TRUEMONEY Application Users to whom CDD or KYC process is
conducted which shall be provided with benefits in accordance with applicable Bank
Indonesia regulations and the maximum total transaction amount per month
(accumulatively) is IDR 20,000,000 (twenty million Rupiah).
12. Partner Channel means is a third party that cooperates with TRUEMONEY INDONESIA in
providing TRUEMONEY Application Services to TRUEMONEY Agents and TRUEMONEY
13. Password means a combination of letters and numbers created by Users to access
TRUEMONEY A pplication and can be changed by Users.
14. TRUEMONEY PIN (Personal Identification Number) is confidential information and only
known by Users and must be entered / input by Users for the use of TRUEMONEY
Application Services. TRUEMONEY ID, Password and PIN are used to prove that Users are
entitled to TRUEMONEY Application Services.
15. OTP (One Time Password) means random code sent via SMS to respective Users.
16. Products and Services means any goods and/or services advertised or offered on
TRUEMONEY Application and/or Merchants.
17. Transaction means all financial activities involving the User's TRUEMONEY Application
balance, including but not limited to: debit, credit, transfer, top-up, cash out, purchase of
Product and Services available on TRUEMONEY Application and/or Merchant applications
made online or offline.
18. Personal Data means any information from which an individual can be identified
independently or through a combination of other information in our possession (e.g.,
directly or indirectly through our systems).
II. REGISTRATION REQUIREMENTS
1. Prospective Users who register through TRUEMONEY Application shall fill in Personal Data
including but not limited to Name, Date of Birth, Phone Number/Mobile Number, Email,
Identity Card Number (or Resident Identification Number - as applicable for Indonesian
citizens), and must upload their scanned of valid proof of identity. Prospective Users who
register through TRUEMONEY Application shall undergo KYC process to be classified as
Registered Members, while Users who have not undergone KYC process will be classified as
2. Users then need to read and agree to this TRUEMONEY INDONESIA Terms and Conditions
3. Users can then use TRUEMONEY Application Services to make Transactions for Products and
Services provided and make Transactions at TRUEMONEY merchant website or
III. GENERAL TERMS AND CONDITIONS
1. When first using TRUEMONEY Application Services, Users must register an account and log
in using the PIN provided by TRUEMONEY INDONESIA via SMS . Users are asked to change
their PIN the first time they log in, with a new PIN according to the User ’s wishes.
2. Users hereby agree and warrant that Personal Data and all data for each Transaction are
accurate, correct and complete. TRUEMONEY INDONESIA shall not be responsible for any
impact that may arise due to negligence, incompleteness, obscurity, or inaccuracy of
order/data from Users.
3. Any Transaction commanded by Users in TRUEMONEY Application shall be executed and
irrevocable upon such Users providing PIN for verification.
4. Each command approved by Users stored in TRUEMONEY INDONESIA data center is valid
data received as evidence from the relevant Users and shall be valid command to
TRUEMONEY Application to carry out the Transaction.
5. TRUEMONEY Application accepts and executes every order from Users as valid order under
the terms of PIN and for such purpose TRUEMONEY INDONESIA shall have no obligation to
examine or investigate the authenticity or validity or authority of the relevant Users’
TRUEMONEY ID, Password and PIN or to assess or prove the accuracy or completion of the
order or command of the intended Transaction, and thus, the order shall be legally binding
on the User accordingly.
6. TRUEMONEY INDONESIA shall have the right not to carry out the order from Users, if:
a. Users account balance in TRUEMONEY Application is not sufficient to make Transaction.
b. TRUEMONEY INDONESIA knows or has reason to suspect that fraud or crime has been or
will be committed.
c. Users have not completed KYC process – therefore, such Users cannot use certain
features such as peer to peer transfer (sending money to fellow TRUEMONEY
Application Users), cashing out, and transferring to bank accounts.
7. For any possibility of data discrepancy in any transaction made by Users in TRUEMONEY A
pplication service or on Partner Channel, data reconciliation shall always refer to the data
owned by TRUEMONEY INDONESIA.
8. As proof that the Transaction ordered by Users has been successfully carried out by
TRUEMONEY Application, Users will receive notification about the Transaction through the
user dashboard in the User's TRUEMONEY Application.
9. Users agree and acknowledge that: by carrying out Transaction through TRUEMONEY
Application, all Users’ orders received by TRUEMONEY Application shall be treated as valid
evidence even though no written document is made and/or signed document is issued.
Proof of order from Users to TRUEMONEY Application is sent electronically and stored in
TRUEMONEY INDONESIA data center and/or stored in other form of information and data
storage at TRUEMONEY INDONESIA, either in the form of written documents, records,
computer printouts and/or copies, which shall be valid evidence therefore its validity, truth
10. In relation to Unregistered TRUEMONEY Users, the maximum account limit balance shall be
IDR 2,000,000 (two million Rupiah); t he Services obtained is only in the form of top-up
11. Whilst with respect to Registered TRUEMONEY Users, the maximum account limit balance
shall be IDR 10,000,000 (ten million Rupiah); the Services obtained is in the form of
top-up, disbursement, balance transfer to fellow Users and to bank accounts, as well as
12. Users shall not receive any interest on the placement of funds in TRUEMONEY Application
13. Users’ funds placed in TRUEMONEY Application are not protected by Deposit Insurance
14. Users may contact and report to TRUEMONEY INDONESIA Customer Service phone number
(08041000100) in case of loss of sim card or smartphone device with the number registered
at TRUEMONEY Application so as to be blocked. The report needs to include the ID/SIM card
number that registered in TRUEMONEY INDONESIA system.
15. Users are required to update frequently in case of any changes to Personal Data by calling
TRUEMONEY Customer Service phone number (08041000100).
16. TRUEMONEY INDONESIA shall only be obliged to bear the direct loss suffered by Users
provided that such loss is evidently due to TRUEMONEY INDONESIA's fault, with a maximum
amount of the nominal amount of the relevant or disputed transaction.
IV. TRUEMONEY ID, PASSWORD AND PIN
1. TRUEMONEY ID and PIN are confidential codes and the authority to use them rests with the
Users. TRUEMONEY ID is permanent and cannot be changed.
2. Users are required to secure their TRUEMONEY ID, Password and PIN as confidential
information and are thus requested not to share them with anyone. Be careful when using
TRUEMONEY ID, Password and PIN so as they are not visible and known to others.
3. Users are advised to change their password and PIN periodically.
4. Shall Users be aware or suspect that TRUEMONEY ID, Password and PIN for TRUEMONEY
Application has been discovered by any unauthorized person, Users are obliged to
immediately make changes to their PIN.
5. All orders and Transactions based on any unauthorized use of TRUEMONEY ID, Password
and PIN by unauthorized parties shall be the responsibility of the relevant Users.
6. Users hereby declare that the use of TRUEMONEY ID, Password, and PIN in each order for
TRUEMONEY Application transaction shall also serve as authorization from Users for
TRUEMONEY Application to carry out Transactions, but is not limited to debiting the Users
account balance available on TRUEMONEY Application in context of executing the ordered
7. All misuse of TRUEMONEY ID, Password or PIN shall be the responsibility of Users. Users
hereby hold TRUEMONEY INDONESIA harmless from any and all claims that may arise, both
from third parties and the User himself as a result of misuse of TRUEMONEY's ID, Password
V. TERMINATION OF ACCESS TO SERVICES
1. Access to TRUEMONEY Application Services will be terminated by TRUEMONEY INDONESIA
a. Users request to permanently stop accessing TRUEMONEY Application Services,
because, among other things:
i. Users forget about access to TRUEMONEY ID, Password and PIN.
ii. Users close all accounts accessible through TRUEMONEY Application Service.
iii. TRUEMONEY Application account is included in fraud investigation.
b. Evidence of receipt of written report from Users regarding Users’ TRUEMONEY ID,
Password and PIN being allegedly or already known by other unauthorized parties.
c. TRUEMONEY INDONESIA implements compliance with applicable laws and regulations.
2. In the event that Members wish to report a loss of balance, request for blocking and
reactivation due to the termination of access to the above-mentioned Services, Users must
contact TRUEMONEY Customer Service via the Customer Service phone number or email
address as written in the 'Contact' menu in TRUEMONEY Application.
VI. LIMITATION OF LIABILITY
Users shall hold TRUEMONEY INDONESIA harmless from any claim, shall TRUEMONEY
INDONESIA be unable to carry out the order for Transaction from Users, either partially or
wholly, due to any events or causes beyond the control of TRUEMONEY Application including
but not limited to hindrance due to computer virus or Trojan Horses system or components that
may hinder TRUEMONEY Application Services, or computer systems, Internet Service Users or
Providers, natural disaster, war, riot, malfunctioning equipment, system or transmission, power
failures, telecommunication disruption, government policy, banking system failure, and any
other events or reasons beyond TRUEMONEY INDONESIA's control or ability.
VII. DORMANT ACCOUNT AND DORMANT ACCOUNT FEE
1. Provisions for inactive accounts (hereinafter referred to as “Dormant Accounts”) shall apply
to TRUEMONEY Agents and TRUEMONEY Members.
2. TRUEMONEY Agents shall be considered inactive or Dormant in case of no Transactions for
3 (three) consecutive months. TRUEMONEY Agents authorize TRUEMONEY INDONESIA
to deduct the Agents’ balance and charge the Dormant Account Fee with 30 (thirty) days'
notice as of 4 June 2021 (hereinafter referred to as "Dormant Account Fee"). Agents
Dormant Accounts hereby waive Articles 1813, 1814 and 1816 of Indonesian Civil Code
and grant TRUEMONEY INDONESIA the irrevocable right and power to charge Dormant
Account Fee with notice 30 (thirty) days’ prior notice with the following conditions:
a) Dormant Account fee of IDR 5,000 (five thousand Rupiah) will be charged monthly for
any Dormant Accounts that meet the above criteria. The fee will be charged to any
Dormant Accounts that has not made any Transaction for 3 ( three) consecutive
months (retroactive). TRUEMONEY INDONESIA will deduct the remaining Dormant
Account balance if it is less than IDR 5,000 (five thousand Rupiah).
b) Thereafter, Dormant Fee will increase to IDR 25,000 (twenty-five thousand Rupiah) for
each additional consecutive month of inactivity (i.e., from the 7th month after being
declared dormant and continuously inactivity).
c) Furthermore, if Agent Dormant Accounts balance fall below the applicable Dormant
Account Fee (IDR 5,000 (five thousand Rupiah) or IDR 25,000 (twenty five thousand
Rupiah)) charged to the respective account in the relevant month, where TRUEMONEY
INDONESIA is not able to charge Dormant Account Fee that meet a and b criteria as
above, subject to prior notification to Dormant Accounts , TRUEMONEY INDONESIA
shall reserve the right and receive irrevocable power to close such accounts
permanently in case of an empty balance or IDR 0 (zero Rupiah) and charge Dormant
Account Fee in the amount of remaining balance of respective Dormant Accounts.
d) If the Dormant Agent conduct a Transaction in his/her account, the status of such
Account becomes active and will no longer be dormant and will not be charged Dormant
Account Fee in the following month until the Agent re-enters the Dormant Account
For the purposes of this provision, "Transaction" means the completion of all financial
activities involving the Users’ TRUEMONEY Application balance, including but not limited to:
debit, credit, transfer, top-up, cash out, purchase of Products and Services available at
TRUEMONEY INDONESIA p latform and website or the merchant application carried out
online or offline, as Your instruction.
3. Member is considered inactive or d ormant in the event that there is no Transaction for 6
(six) consecutive months. Dormant Account Fee will be charged automatically in the 7th
(seventh) month. TRUEMONEY Member authorizes TRUEMONEY INDONESIA to deduct the
Member, balance and charge Dormant Account Fee with 30 (thirty) days. notice from 1
December 2022. Dormant Member hereby waive Articles 1813, 1814 and 1816 of
Indonesian Civil Code and grant TRUEMONEY INDONESIA the irrevocable right and power to
charge Dormant Account Fee with the following conditions:
a. Dormant Account Fee of IDR 5,000 (five thousand Rupiah) will be charged every month
for Dormant Member Account that meet the criteria mentioned above. The fee will be
charged on the 7 (seventh) months to Dormant Member Account that have not made
Transactions for 6 (six) consecutive months back (retroactive). TRUEMONEY INDONESIA
will deduct the remaining Dormant Account balance if it is less than IDR 5,000 (five
b. Furthermore, if the Dormant Member Account balance amounts to under the applicable
Dormant Account Fee, TRUEMONEY INDONESIA reserves the right to charge a Dormant
Account Fee in the amount of any remaining Dormant Account balance.
c. Subject to prior notice to the Dormant Member Account, TRUEMONEY INDONESIA
reserves the right and accepts the power of attorney for which TRUEMONEY INDONESIA
will permanently close the Dormant Member Account if the balance is empty or IDR 0
d. If Dormant Member re-enters a Transaction in his/her Account, then the status of the
account becomes active and no longer dormant and will not be charged Dormant
Account Fee in the following month until the Member re-enters the Dormant Account
4. In connection with the closure of Dormant Accounts by TRUEMONEY INDONESIA, the
TRUEMONEY Agents, and TRUEMONEY Member hereby agree to waive the enforcement of
Articles 1266 and 1267 of Indonesian Civil Code, unless TRUEMONEY Agent or TRUEMONEY
Member closes their Dormant Account themselves.
5. These provisions regarding Dormant Accounts are notified on 1 November 2022 and are
effective within the next one month, on 1 December 2022.
1. Only Registered Users (KYC) can withdraw the existing balance on TRUEMONEY Application.
Withdrawal can only be made through TRUEMONEY Partner Channel. Fees for this
Withdrawal may differ according to the policy of each Partner Channel.
2. In each balance Withdrawal made, TRUEMONEY INDONESIA shall reserve the right to
disclose the User’s full name or Identity as registered User to partners. Shall there be any
discrepancy in the User's identity, TRUEMONEY INDONESIA shall not be responsible for such
difference in identity and shall reserve the right to refuse any balance Withdrawal
transactions indicated as suspicious until the correct identity of the valid User is obtained.
3. TRUEMONEY INDONESIA shall not be responsible in case of misuse of balance Withdrawal
transactions. Users fully understand and shall be responsible for maintaining the security
and confidentiality of every detail of balance withdrawal information.
4. Any disruption or loss that may arise related to Withdrawal due to system failure in the
service ecosystem of TRUEMONEY INDONESIA or Partners including any other cooperating
third parties, shall fully not be the responsibility of TRUEMONEY INDONESIA. Furthermore,
shall there be any complaints from Users submitted to TRUEMONEY INDONESIA,
TRUEMONEY INDONESIA will help to resolve this problem together with partners including
any other third parties involved in Withdrawal process to follow up immediately.
TRUEMONEY INDONESIA shall not be responsible for any technical problem/system
disturbance occurring beyond TRUEMONEY INDONESIA's control (force majeure).
IX. REJECTION OF TRANSACTION
We can refuse to carry out Transaction by You, shall our system find any suspicious transaction
pattern, partial or complete violation of Terms and Conditions and/or difference in your identity
data in our possession, and shall it not meet the provisions as required by the applicable
Our Services may be interrupted by certain events or matters beyond our authority and control
(Force Majeure), including but not limited to natural disaster, power failures, telecommunication
disturbance, government policy, and any other matters beyond our authority and control. You
therefore agree to release Us from any claim, shall We be unable to fulfill Your instructions
through TRUEMONEY INDONESIA account either partially or wholly due to Force Majeure.
X. INTELLECTUAL PROPERTY RIGHTS
Graphics, logos, photos, images, names, words, letters, numbers, text, color settings and
element combinations of any intellectual property rights available through TRUEMONEY
Application services are owned by TRUEMONEY INDONESIA or its suppliers or Merchants. Such
trademarks shall not be used for any matters unrelated to Products and Services in any way that
may cause confusion among TRUEMONEY Application Users or harm TRUEMONEY INDONESIA or
its suppliers or Merchants. TRUEMONEY Application Users are prohibited from copying,
reproducing or using it for profit and in any way without the prior written consent of
TRUEMONEY INDONESIA or its suppliers or Merchants.
Personal Data and our data protection practices.
Shall any part of these Terms and Conditions become invalid or unenforceable due to applicable
laws and regulations, Users agree that such invalidity shall not affect all other parts of these
Terms and Conditions. We will endeavor to change such provisions in order to be valid and not
violate any other legal provisions so that they can reflect the same purpose of their respective
XIII. GOVERNING LAW AND DISPUTE RESOLUTION
By using TRUEMONEY Application Service, Users agree to be bound by these Terms and
Conditions and that their interpretation shall be subject to the provisions of the Law of the
Republic of Indonesia. Any legal action or dispute that may arise in connection with TRUEMONEY
Application Service, must be resolved in South Jakarta District Court or without prejudice to
TRUEMONEY INDONESIA's right to submit any claim to another competent district court in
1. Each User can contact TRUEMONEY INDONESIA Customer Service by telephone or e-mail
address as stated in the 'Contact' menu on TRUEMONEY Application for any questions,
complaints or problems related to Transaction and difficulties in accessing TRUEMONEY
Application Services. Customer complaints will be resolved within a maximum of 14
(fourteen) business days. TRUEMONEY INDONESIA Customer Service will confirm to each
User the status of the complaint if the complaint has been resolved or inform the relevant
User if the resolution will take more than 14 (fourteen) business days as it requires further
2. We shall reserve the right to make any changes to websites, policies, these terms of service,
and these Terms and Conditions at any time upon providing notification to Users in the
media we provide. All changes, additions, deletions, modifications and others that we make
in connection with these services shall automatically take effect within 1x24 hours after they
are downloaded and posted on TRUEMONEY Application. Users are advised to constantly
read and inquire every notification that we convey to TRUEMONEY INDONESIA media.
Therefore, Users hereby agree to be bound by any changes we make to the websites,
policies, these terms of service, and these Terms and Conditions.
3. We declare that Merchants are independent contractors who are not associated with
TRUEMONEY INDONESIA or any of our subsidiaries, employees, management or other
4. Users agree that TRUEMONEY INDONESIA may use Users’ Personal Data for internal data
analysis purposes if necessary.
Your use of TRUEMONEY INDONESIA account and/or TRUEMONEY INDONESIA Services shall
constitute as your agreement to comply with (i) these Terms; (ii) General Terms and
Conditions for use of TRUEMONEY Application; (iii) specific Terms and Conditions that apply
to any services or promotions or marketing campaigns available on the Application, or
ADDENDUM A – Policy Privacy
disclose Users “Personal Data”, “personally identifiable information” or other personal information
(collectively, “Personal Data”) in connection with Users access and use on TRUEMONEY Application.
As more fully described in Terms and Conditions for TRUEMONEY INDONESIA (“Terms and
Conditions”), TRUEMONEY Application is an integrated service application designed by TRUEMONEY
INDONESIA for users. TRUEMONEY Application provides gateway for TRUEMONEY Application
registered Users to participate in various activities, including accessing information or promotions,
and making payments.
TRUEMONEY Application is provided free of charge to registered users. TRUEMONEY INDONESIA is a
non-bank institution that has obtained license to perform stored value facility under the supervision
regarding TRUEMONEY INDONESIA, please read the related section at TRUEMONEY Application.
From time to time, it is necessary for Users to provide us with Personal Data in connection with
Users, access to and use of TRUEMONEY Application. By agreeing to Terms and Conditions or by
continuing to access or use TRUEMONEY Application, Users will be deemed to have agreed to and
Shall a User not provide us with such Personal Data, we will remain be unable to provide full Services
to such User within TRUEMONEY Application or to comply with laws or guidelines issued by
regulatory bodies or relevant authorities.
A. PERSONAL DATA COLLECTION
We may obtain Users Personal Data from various sources (e.g. from Users or through third parties),
1. Information obtained (directly or indirectly) about the Users’ mobile device or other hardware
used to access TRUEMONEY Application (including the Users’ IP address, geographic location,
browser/platform type and version, internet service provider, operating system, source
referral/exit page, length of visit/use, page view and any search terms used by Users) (“Device
2. Information obtained (directly or indirectly) when Users register for TRUEMONEY INDONESIA
account as TRUEMONEY Application Users, including Users’ name, date of birth, address, phone
number and email address (“Registration Information”).
3. Information obtained (directly or indirectly) during the use of TRUEMONEY INDONESIA account,
including bank account numbers, billing and shipping information, transaction data, and any
other information from Users checks or payment command (“Account Information”).
4. Information obtained (directly or indirectly) when Users utilize virtual account provided by
TRUEMONEY INDONESIA to receive electronic money and/or electronic wallet payments from
the payer, whether you are service provider or Merchant, TRUEMONEY INDONESIA may collect
certain information related to your utilization including but not limited to services and/or goods
transacted, the amount you collect from each transaction, withdrawal or settlement account
details and withdrawal or settlement history.
5. TRUEMONEY INDONESIA may also collect your Personal Data from third parties (including agent,
vendor, supplier, contractor, our partner, and any other parties who provide services to us,
perform function on our behalf, or who cooperate with us). In such cases, we will only collect
your Personal Data for or in connection with the purposes involving such third parties or the
purposes of our collaboration with such third parties (as the case may be).
6. Device Information, Registration Information and Account Information forementioned or any
other information may be accessed or collected (automatically or manually) at the time of Users
registration with TRUEMONEY INDONESIA account as TRUEMONEY Application Users and/or
during Users using TRUEMONEY Application and TRUEMONEY INDONESIA account. The above
information that we obtain may be Users’ Personal Data. We have taken measures to ensure
that we do not collect more information (whether such information is Personal Data or not)
from Users other than what is necessary for us to provide our Services to Users, to perform the
account, comply with our legal obligations, protect our legal rights, and to conduct our business.
B. USE OF PERSONAL DATA
We will use the Personal Data we collect about Users for the following purposes:
1. Verify the Users’ eligibility to use any of features and functions of TRUEMONEY Application.
2. Process Users registration with TRUEMONEY INDONESIA account as TRUEMONEY Application
Users, maintain and manage Users registration.
3. Provide related Services and customer services to Users regarding the use of Users’ TRUEMONEY
account, including, cooperating with TRUEMONEY INDONESIA to facilitate the settlement of the
purchase price of goods and services, delivery, and related services for purchase, refund,
sending notification about Users transaction, and respond to Users question, feedback, claim or
4. Provide related Services and customer services to Users regarding the use of TRUEMONEY
Application, to facilitate Users in identifying other TRUEMONEY Application Users when Users
are checking their mobile phone contact through TRUEMONEY Application.
5. Improve and expand our offerings by researching and developing new functions of TRUEMONEY
Application or other new products and services that we may offer from time to time.
6. Conduct research, statistical analysis or surveys, either orally or in writing, to manage and
protect our business including our information technology infrastructure, to measure the
performance of TRUEMONEY Application and any other Services we offer and to ensure Users
satisfaction with our Services.
7. Analyze trends, usage and other behaviors (whether individually or in the aggregate), which
helps us better understand how our Users and our collective Users base access and use
TRUEMONEY Application and the underlying commercial activities they undertake, including for
the purpose of improving our Services and responding to customer questions and preferences.
8. As we have obtained the Users’ consent in accordance with applicable law and as referred to in
section D below, we may provide direct marketing information to Users related to the services
offered by us and our affiliates and selected third parties using the Users’ Personal Data, to
contact Users, including by phone, text (SMS), email, and mail.
9. Manage risk, conduct creditworthiness and capability inspection, or assess, detect, investigate,
prevent and/or resolve fraud or other potentially prohibited or illegal activities and otherwise
protect the integrity of our information technology platform.
10. Detect, investigate, prevent or remedy violations against Terms and Conditions, any applicable
internal TRUEMONEY Application policies, industry standards, guidelines, relevant laws or
11. Make any disclosures as required by any country's laws or regulations applicable to us or our
affiliates, government officials, or third parties, including any card associations or other payment
networks. Disclosure may also be made pursuant to any subpoena, court order or other legal
process or requirement in any country applicable to us or our affiliates (including money
laundering and anti-terrorism reporting requirements).
12. Make any disclosures to prevent harm or financial loss, to report suspected illegal activity or to
address claims or potential claims brought against us or our affiliates.
13. Any other legitimate business purposes, such as protecting Users from harm, protecting lives,
keeping our systems and products safe, and protecting our rights and/or other property.
We may also use Users’ Personal Data in any other ways for which we provide specific notice at the
time of collection or for which Users have subsequently consented.
C. DISCLOSURE OF PERSONAL DATA
Users’ Personal Data in our possession will be kept confidential, however we may provide such
information to the following parties (domestic or overseas) for the purposes specified in B.1 to B.3
1. TRUEMONEY INDONESIA accounts and other TRUEMONEY INDONESIA Services wholly or partly
owned by group companies.
2. Any agents, contractors or third party service providers who cooperate with us in providing
Services to Users, including for fraud prevention, billing collection, data entry, database
management, promotion, marketing, customer service, technology services, products and
services alerts, and payment extension services.
3. Any entities with whom we maintain business referrals or other commercial arrangements,
including affiliated parties, third parties or entities commercially involved with TRUEMONEY
4. Merchants and other organizations, such as payment networks or financial institutions, through
which the payments are made using TRUEMONEY Application, or other entities that allow the
use of TRUEMONEY Application.
5. Third party financial institutions, banks, collection agencies, and credit agencies.
6. Third party marketing service providers.
7. Professional advisors, law enforcement agencies, insurance companies, governments, and
regulatory authorities or other institutions to which TRUEMONEY INDONESIA is obliged to make
disclosures under the requirements of any applicable law, regulation or commercial
arrangements, including arrangements with any card associations or payment networks.
8. Entities involved in any merger, acquisition, financing transaction or joint venture with us.
D. DIRECT MARKETING
As set out in B.7, TRUEMONEY INDONESIA may intend to use Users’ Personal Data in direct
marketing activities and, in the future, will obtain Users’ consent with respect to the scope and
means intended for such direct marketing activities. Where Users give further consent, then please
1. Certain Personal Data that we collect from time to time may be used in direct marketing and
2. We may offer Users the promotion of goods and services deemed relevant to Users for which
Users’ further consent will be specifically obtained. This may include goods and Services that we,
our affiliates, our business partners or selected third parties offer, including any payment and
3. We may provide Users Personal Data to certain third parties for their use in marketing their own
goods and Services, including (i) our affiliates, (ii) business partners and (iii) other third parties.
4. Users consent for the use of Users’ Personal Data for direct marketing purposes will be
requested by checking the “opt in” box or any other positive indication of no objection.
5. Shall at any time Users not want us to continue to use or provide Users’ Personal Data to others
for use in direct marketing as described above and in the relevant agreement, then Users may
exercise the Users’ "quit" right by notifying us.
E. SECURITY MEASURES AND RETENTION
We take all reasonable measures, including technical, administrative and physical safeguards to help
protect Users’ Personal Data that we process, from any loss, misuse and unauthorized access,
disclosure, alteration and destruction.
We will retain and endeavor our service providers to retain Users’ Personal Data only for a period of
Policy and all applicable regulatory requirements.
For registered users of TRUEMONEY INDONESIA account, Registration Information and User Account
Information (if any) can be viewed and edited in TRUEMONEY Application through the User's
TRUEMONEY INDONESIA account, which is protected with password or PIN code. We recommend
that Users do not disclose their passwords or PIN codes to anyone. Our personnel will never ask
anyone for password by unsolicited phone call or unsolicited email. Users shall not store their login
information (e.g., user ID and password) on shared or public computers.
discretion from time to time, to ensure that this policy is consistent with our future developments,
will notify you of the changes via public notice published on Application or to your email address
regularly for the latest information on our data processing and data protection practices, and that
your continued use of Application or communication with us, or access to and use of services
Policy and all amendments thereto.
the Republic of Indonesia.
resolved in the South Jakarta District Court or without prejudice to TRUEMONEY INDONESIA
right to file a claim with another competent district court in Indonesia.
By using TRUEMONEY Application, Users acknowledge that Users have read and understand this
I. FURTHER INFORMATION
Data or "opt-out" or if Users want to submit any question or complaint, please contact Customer
PT. Witami Tunai Mandiri
Millenium Centennial Center, 36 th Floor
Jl. Jend Sudirman Kav 25, Kuningan-Setiabudi, South Jakarta,
Special Capital Region of Jakarta
Contact Center: 0804-1000-100