Privacy Policy

This Policy explains the types of personal data Pivot may collect, how data is used, stored, shared, and the choices available to users.

By using Pivot services, you agree to the processing of personal data as described in this Privacy Policy.

1. Data We Collect

We may collect and process the following categories of data:

a. Account and Identity Information

Including but not limited to:

• Name
• Email address
• Profile photo
• Phone number
• Account authentication information
• Third-party account information used for login

b. User Profile Information

Including:

• Username
• Language preferences
• Service usage preferences
• Account settings
• Other profile information provided by the user

c. Identity Verification Information

Where required for security, compliance, or certain transactions, we may request:

• Full name
• Address
• Identity documents
• Other verification information required by law or internal policy

d. Financial and Payment Information

Including:

• Bank account information
• Payment information
• Deposit history
• Withdrawal history
• Wallet transaction history
• Other information needed to process transactions

e. Trading Information

Including:

• Trading account information
• Trading activity
• Positions and transaction history
• Trading preferences
• Account performance information
• Other data needed to provide trading services

f. Service Usage Information

Including:

• Interactions with application features
• Use of educational features
• Use of market analysis features
• Use of artificial intelligence (AI) based features
• Activity history within the services

g. Communication Information

Including:

• Messages sent through communication features
• Customer support history
• Communications through email, website, or other official channels

h. Device and Technical Information

Including:

• Device type
• Operating system
• IP address
• Browser information
• Activity logs
• Application usage data
• Security and abuse prevention information

i. Website and Marketing Information

Including:

• Contact form data
• Registration data
• Marketing campaign data
• Referral data
• Cookies and similar technologies
• Website usage analytics

2. How We Collect Data

We may obtain data through:

• Information you provide directly.
• Your activity when using the application or website.
• Third-party login providers.
• Business partners and service providers that help operate the services.
• Security and fraud prevention systems.
• Analytics technologies, cookies, and marketing tools.
• System records generated during service usage.

3. Purposes for Using Data

We use personal data to:

• Create, manage, and secure user accounts.
• Provide trading, wallet, payment, and related features.
• Provide market analysis, educational content, and AI-based features.
• Process transactions and account activity.
• Send notifications related to services, security, transactions, and promotions.
• Provide customer service and handle complaints.
• Improve product, service, feature, and user experience quality.
• Analyze service usage and marketing effectiveness.
• Prevent fraud, abuse, money laundering, and other illegal activities.
• Meet applicable legal, regulatory, audit, and compliance obligations.

4. Basis for Data Processing

We process personal data based on one or more of the following legal bases:

• User consent.
• Performance of an agreement or provision of services to users.
• Compliance with legal obligations.
• Legitimate interests in operating, securing, and developing the services.
• Other legal bases permitted by applicable laws and regulations.

5. Sharing Data with Third Parties

We may share personal data with third parties to the extent necessary to operate the services, including:

• Broker partners or trading service providers.
• Payment providers and financial institutions.
• Authentication service providers.
• Cloud, hosting, and technology infrastructure providers.
• Analytics, communication, and customer support providers.
• Artificial intelligence (AI), market data, news, and other support service providers.
• Legal consultants, auditors, and professional advisers.
• Regulators, government authorities, or law enforcement where required by law.

We do not sell users' personal data to third parties.

6. International Data Transfers

In operating the services, personal data may be processed or stored by service providers located outside Indonesia.

In such cases, we will seek to apply reasonable protective measures in accordance with applicable regulations to maintain the security and confidentiality of personal data.

7. Data Storage and Retention

We retain personal data for as long as needed to:

• Provide services to users.
• Meet legal and regulatory obligations.
• Handle disputes and investigations.
• Conduct audit and compliance activities.
• Maintain service security.

After data is no longer needed, we may delete, destroy, or anonymize the data in accordance with internal policies and applicable regulations.

8. Data Security

We apply reasonable technical and organizational measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.

However, no method of data transmission or storage can be guaranteed to be fully secure. Therefore, users are also responsible for maintaining the security of their accounts, devices, and access credentials.

9. User Rights

In accordance with applicable regulations, users may have the right to:

• Obtain information about personal data processing.
• Access the personal data we store.
• Update or correct inaccurate data.
• Request deletion of personal data under certain conditions.
• Withdraw previously given consent.
• Object to or restrict certain processing.
• Submit a complaint to the competent authority.

To protect data security, we may request identity verification before processing such requests.

10. Children's Data

Pivot services are not intended for individuals under 18 years of age or the minimum age determined by applicable law.

We do not knowingly collect children's personal data. If we become aware that a child's data has been collected without valid consent, we will take reasonable steps to delete the data.

11. Cookies and Similar Technologies

Pivot websites and services may use cookies, local storage, pixels, SDKs, analytics, and similar technologies to:

• Operate service functions.
• Remember user preferences.
• Measure service performance.
• Analyze website and application usage.
• Support marketing and promotional activities.
• Improve service security.

Users can manage cookie preferences through their browser or device settings.

12. Communications and Marketing

We may send information about:

• Products and services.
• Feature updates.
• Education and market information.
• Promotions and marketing campaigns.
• Other information relevant to the services.

Users may stop receiving marketing communications at any time through the available mechanism. However, we may still send communications related to account security, transactions, or legal obligations.

13. Security Incidents

If a security incident affects users' personal data, we will conduct investigation, mitigation, and notification in accordance with applicable legal requirements.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in services, technology, operational needs, or applicable regulations.

The latest version will be published through the application, website, or other official media. Use of the services after changes take effect is deemed acceptance of the updated Privacy Policy.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights regarding personal data, please contact us by email at contact@bersamapivot.online