Privacy Policy

The privacy policy is a regulation that contains your account and information you provide to the company. This contains the following:

·         Overview

·         Request for Change

·         Information that the company collects

·         Transaction Information

·         Your Information from Third Parties

·         Additional Verification

·         Website Traffic Information

·         Use of “Cookies”

·         Customer Correspondence Service

·         Questionnaires, Surveys and Data Profiles

·         Acceptance or Non-Member Request

·         Use and disclosure of information

·         Information Limitation for Other Customers

·         Information is limited to third parties

·         Customer Contact



o   The Company has the right to ask you to provide your personal information and your bank account data for security and convenience in making transactions.

o   This provision contains information owned by the Company.

o   The Company takes great care of your personal information and will use your personal information in accordance with the conditions stated in this provision.

o   The Company will not sell or rent your personal data or list of Company customers to third parties.

o   Under certain conditions, the Company has the right to provide your personal information to third parties who have legality of cooperation with the Company.

o   This provision applies to all services provided in WinPay.

o   By accepting the User’s Policies and Conditions in the registration, you agree to the Management of your personal information in accordance with the explanation in the Terms.

o   This provision is included in Company Regulations.

o   Your personal information will be stored by the Company and processed on the Company’s servers.

o   The company guarantees to store and send your personal information securely and confidentially.


Notification of Change

o   This provision will be updated due to the addition of new services to the WinPay program.

o   This provision will change from time to time due to the addition of new WinPay services or the suggestions that the Company receives from the customers.

o   If the Company finds that there is a mismatch between digital personal information data that has been received from you and your personal data that has been updated, then you have the right to choose which data will be managed by the Company.

o   The Company will send a notification email whenever there are changes to the Policies and Regulations. This does not apply to Users who have closed an account.

o   The company will provide information on changes to the Terms clearly on the WinPay website, so that you can find out the latest information about developments from SmarCash. Please check the WinPay website at at any time to find out the latest version of the Company Privacy Policy.

o   The Company is not responsible for the activities of Third Party operations, except those containing data provided by Third Parties on the WinPay website.


Information that the Company collects to access your WinPay account, include:

1.       Full name

2.       Company Name (if any)

3.       Address

4.       Phone number

5.       Website URL (if any)

6.       Email address

To make transactions using WinPay, you should provide all the information that the Company needs with valid data. This information will be very necessary for the Company to:

1.       Perform transaction process

2.       Issue a new password

3.       Protect you from fraud

4.       To make it easier for the Company to contact you


The company has the right to suspend an account that does not meet the above requirements and freeze the funds until the investigation process is complete.

If you choose to register additional products or features offered by the Company, you will be asked to provide additional information to meet the requirements of the feature or product.


Transaction Information

If you use WinPay to send money to other parties or request money from other parties, the Company will ask you to provide information related to each transaction including the number of transactions and email addresses of the other party.

The company will store information for every transaction you make through WinPay.

The company also collects the IP Address of each computer or device that you use to access your WinPay account, to help detect possible instances of illegal transactions.

Your Information from Third Parties

In an effort to protect all of the Company’s customers against fraud, the Company will verify with third parties the information you provide.


Additional Verification

·         In an effort to overcome fraud and fraud, the Company requires additional verification.

·         The company will ask you to provide additional information (scan KTP, Family Card, passbook, etc.) to make a withdrawal in the account.

·         If you cannot verify the information that you provide to the Company, the Company has the right to suspend the account and freeze your funds until the investigation process is complete.

Website Traffic Information

·         The Company will automatically receive the website’s IP Address you visit when you are still connected to the WinPay website.

·         The Company will collect any page information on the WinPay website that you visit when you are on the WinPay site, the type of browser you are using, and when you access the WinPay website.

·         The Company will use this information to better understand the Company’s customer preferences and to manage the Company’s server load, so that in the end to improve WinPay services and your experience with the Company.

·         The company does not track the websites that you visit before or after you leave the WinPay website.

Use of “Cookies”

·         “Cookies” are small files of data that reside on your computer and allow the Company to recognize you as a WinPay customer if you return to the WinPay site using the same computer and browser.

·         The company sends “session cookies” to your computer if and when you log in to your account by entering your email address and password.

·         These cookies allow the Company to recognize you if you visit several pages of the Company’s website during the same session, so you do not have to re-enter your password several times.

·         After you log out or close the browser, these session cookies will end and have no effect whatsoever.

·         The Company also uses longer-lasting cookies to display your e-mail address on the WinPay sign-in form, so you no longer need to rewrite the e-mail address every time you log in to the Company account.

·         The Company is not responsible for any damage that occurs to the hardware and / or software that you have if the damage is due to the system “Cookies” from any aspect.


Customer Service correspondence

·         If you send a correspondent to the Company, the Company has the right to save the correspondent in order to measure and improve WinPay customer service, and to investigate potential fraud and violations of the Terms of Use.

·         The company will periodically delete records in accordance with the provisions in force in the Republic of Indonesia Legislation and international provisions.

Questionnaire, Survey and Profile Data

·         Companies can offer questionnaires and surveys to Users for gathering demographic information or to find out the wishes and needs of Users. The use of information collected will be explained in detail in the survey process itself.

·         If the Company collects personal information from Company Users in a questionnaire or survey, Users will be notified how this information will be used before they participate in a survey or questionnaire.

Recipient or Non-member Applicant

·         When a member sends a payment to a non-member or requests for payment from someone who is not registered as a member of the Company, the Company will request member information to submit to the Company the name and/or e-mail address of another party, for the benefit of the member trying to contact non -member, so thatmembers can see the complete record of the transaction, including unauthorized transactions.

·         This information is stored indefinitely and the Company will not open it to non-members.

·         These non-members have the same right to access and correct their information (assuming that their e-mail address is correct and can reach them) as other people use WinPay.

The Use and Disclosure of Information

·         The Company collects, stores and processes your personal information on WinPay servers.

·         The company uses your personal information that comes from your information or data requested by the Company to provide services and to process transactions, for customer service, to determine your eligibility to accept product offers or special features, and to improve WinPay products and services.

·         The company uses the information you provide to access certain services from third parties on your behalf and take actions that you ask the Company to do.

·         The company provides access to individual user information only to companies that need it to fulfill customer service requests.

Information Limitation for Other Customers

·         Your information (user name, name and date of transaction) will be sent to customers of other companies that make transaction with you through WinPay.

·         The company will not provide financial information and bank accounts used in the process of transactions between Users and other parties through WinPay to other parties, unless the Company is requested by the police, prosecutors, court and related agencies, because it causes lawsuits that must be obeyed.

·         Companies that can give other customers the amount of payment you receive from customers who are “GOLD” or “PLATINUM” and other overall measurements that provide information about you with other customers.

Limitation of Information to Third Parties other than Customers

·         The company will not either sell or rent your personal information to third parties.

·         The company will not share your personal information with third parties, except in certain circumstances with your permission.

·         Third parties have limitations to manage information used for other purposes beyond the agreements made by the Company.

·         The company discloses the information collected (as described above) with other companies that conduct marketing services on behalf of the Company or other financial institutions that work with the Company in a marketing agreement.

·         These companies were previously subject to agreements with the Company and other legal restrictions that prohibit the use of information except for the purpose of marketing WinPay products and services, unless you give a consent to use as intended by a Third Party.

·         The company shares information in good faith to cooperate in investigations related to fraud or other legal activities, or to investigate violations of Company Policies & Rules. In particular, if the Company conducts a fraud investigation and concludes that one party has been involved in fraudulent practices, the Company may provide entity contact information (excluding bank accounts or credit card information) to the victims who requested it.

·         The company has the right to disclose information in response to a warrant, subpoena, court order, retribution, order of recipients referred to by the court or other comparable litigation, including subpoenas from private parties in civil actions.

·         The company discloses your information to your agent or legal representative (the power of attorney you appoint or the guardian appointed to you).

·         The company shares data with the Company’s business partners and for public relations. For example, the Company can disclose the amount in certain presentations of users from Jakarta. However, this information is not related to personal information.

·         In the future the Company has the right to merge or be acquired by another company. If an acquisition occurs, the successor company will have access to information managed by the Company, including customer account information, and will continue to be bound to this Policy until there are changes as described above.

·         The company shares information with all subsidiaries and joint ventures to help coordinate the services that the Company provides to you, implement the terms and conditions and promote trust and security.

Contact with Customers

·         The company communicates with customers regularly through e-mail to provide the requested services, and the Company also communicates via email or telephone to resolve customers’ complaints or to investigate suspicious transactions.

·         The company uses your e-mail address to confirm the opening of a WinPay account, to send notifications of payments that you send or receive through WinPay, send information about important changes to WinPay products or services, and send notifications and other information requested by law.

·         The company will also use your e-mail address to send other forms of communication that you can control including, tips, newsletters, customer surveys, and special information from third parties. In connection with an independent audit of the Company’s financial statements and operations, the auditor may seek and contact Company’s customers to ensure that Company records are accurate. However, this auditor cannot use personal information for other purposes.


The security policy includes the following:

·         Information Security

·         Company Account Security

·         Access and Change Account Information

·         Contact us

Information Security

·         The company handles customer information with high information security standards.

·         The company limits the access to your personal information only to employees who need it in order to provide products or services to you.

·         The company maintains physical, electronic and security procedures in accordance with government regulations to safeguard your non-public information.

·         The security of your account also depends on protecting your password. Do not give passwords to other people. A representative from the Company never asks for your password, if there is an e-mail or other communication requesting your password, please be careful and this activity is considered invalid and suspicious.

·         If you give a password to a third party for any reason, including a third party that has promised to provide additional services such as account aggregation, then the third party will have access to your account and personal information, and you are responsible for the actions taken because they use your password.

·         If you believe someone else has accessed your password, immediately change the password and immediately contact the Company

Security COMPANY Account

In order to maintain the security of a WinPay user account, here are some things you must do:

·         It is prohibited to publish virtual account numbers (16 digits, letter and number combinations) that WinPay creates for users

·         Please immediately do a Company Account Verification

·         Companies have the right to suspend users’ accounts that intentionally publish virtual account numbers for deviant purposes.

·         Access and Change Account Information

·         You can review the personal information that you provide to the Company and make certain changes by contacting the Company.

·         Changes will be permitted as long as your account status is NEWBIE, you will not be permitted to make changes if your account status is SILVER / GOLD / PLATINUM. This is needed to prevent fraud, by ensuring that parties trying to commit fraud will not change the Company account information so that it cannot be detected.

·         You can also close the account through the WinPay website. If you close your account, the Company will record the account in the data base as “CLOSED” but the Company keeps your information in the database. This is necessary to prevent fraud, by ensuring that people who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account again.

·         However, if you close your account, your personal information will not be used by the Company for further purposes or sold or shared with third parties, unless needed to prevent fraud and help law enforcement, or as required by law. You are not allowed to use a username that contains word elements from the Company, the Company system will automatically cancel the username

Contact the company

If you have policy questions, please go directly to the FAQ page or Contact the Company page

·         Hacking

If you conduct an experiment or action other than the agreed conditions (hacking, modification, damaging, etc.) and all illegal activities against the Company’s software system, the Company will follow up on these actions by taking legal action.

·         Password

The company will never ask for your password. Never give your password to anyone. The company will not be responsible for losses suffered by users as a result of misuse of passwords.


·         Do not directly click on the link in the email that comes from the Company. Email may come from scammers who try to steal your information. First, make sure that the link is true from the Company by contacting Company support.

·         Keep your computer security updated. Your computer is the way to the company, bank account or other online account that you have. Many of these accounts are only limited to the security of your computer. So make sure you update anti-viruses, firewalls, spyware detection/removal, and others that are on your computer.

·         Use a trusted computer. Do not use someone else’s computer to log in to the Company account.

·         Use a trusted internet connection. The best is the cable connection in your home.

·         Never tell your Password or PIN to someone else.

·         Make changes to PINs or Passwords regularly.

·         Make sure your computer is free of viruses.

·         Perform transactions carefully at each step/stage

·         Make sure the transaction is complete. Once you have done any transaction, do not forget to SIGN OUT or LOG OUT

·         Learn and understand in advance the user’s agreement, privacy and security policies and terms and conditions before registering/registering for the use of the website and/or WinPay services.