Privacy Policy

Your personal data and assets are our highest priority. We are fully committed to safeguarding them.

Tumbuh Payline collects and stores data essential to your trading activity on this trading platform. The methods we use to collect and store this data are detailed in the Privacy Policy below.

The following principles guide our policy:

• We are committed to providing complete transparency about how we collect and store your personal data:

We want you to clearly understand how we collect and process your data, so you can make informed decisions. This official website follows clear guidelines and procedures for handling data. Our policy details the specific methods we use, giving you transparent, concrete information about how your data is used. You are in control.

Whenever we determine you should be notified, we will provide updates promptly. Transparency is at the heart of how we operate.

Our dedicated support team is available to answer any questions about our processes, including our obligations under the laws of Indonesia. Please contact us at: info@tumbuh-payline.com

• We do not use personal data for any purpose other than as described in our Privacy Policy.

We may process personal data for purposes such as ensuring the proper operation of Tumbuh Payline services and facilitating connections between trader-members and third-party trading platforms. We also use this data to maintain and improve functions on our official website and services, protect our rights, and comply with regulatory and other legal requirements. Additionally, we process personal data as needed to deliver administrative and other business functions related to the Services we provide to you, the client.

To improve our services and tailor them to your preferences and needs, Tumbuh Payline uses personal data.

• To access and use essential tools designed to protect your personal data and safeguard your rights:

You can contact us at any time to access all personal data we hold about you. We can also update or delete it upon request. If needed, we will facilitate the transfer of your data to you or to a designated third party. These services are available to help you exercise your rights to privacy and control.

• Safeguard your personal data:

We employ banking-grade security measures. Although a 100% guarantee is not possible, we are committed to continuously upgrading our systems and strengthening the safeguards we have in place.

We maintain a comprehensive privacy policy and industry-leading security protocols.

1. The Scope?

This policy sets out our procedures for the collection, processing, and sharing of any data relating to a natural person.

These policy terms apply to all identifiable natural persons. This includes anyone who is identified, or can be identified, through data entrusted to us or data that we can access and/or combine.

As defined in the Privacy Policy, data processing specifically refers to the storage, management, and organization of personal data.

We do not collect, and will not knowingly collect, information from individuals under 18. We also prohibit anyone under 18 from using our platform. If we become aware of a user under 18, or of any data relating to a person under 18, we will delete it immediately.

2. What personal data do we retain?

When you register with us, we collect the personal data required to deliver our services. When needed, we may also request additional data to verify account ownership. To maintain and improve the quality of our services, we collect and analyse information about how you use our platform and, where applicable, the services of our third-party partners.

3. You are under no obligation to disclose your personal data to the company.

While you are not obligated to share your data with us, choosing not to do so may limit the services we can provide and may restrict your ability to use our platform.

4. What personal data do we collect? When you visit our official website, we may collect the following personal data:

We do not collect information that can personally identify you. We do collect details such as your specific account activity, your IP address, and the date and time you access our services. For maintenance, security, and support, we retain system crash reports, browser information, and the type of device used to access your account. We also record the language associated with your account.

Regarding personal data collection, we only collect and retain the information you consent to share when you connect, via our service, with a third party trading platform.

Personal data you share with third-party platforms may include your full name, address, phone number, and email address.

5. Why does the company need my personal data, and is it legal for them to collect it?

The company collects, stores, and processes your personal data solely for the purposes described in this Policy. All such use and processing comply with applicable laws in Indonesia.

The company will only handle, process, or transmit your data in compliance with the applicable laws in Indonesia. The following are the legal grounds for this processing:

• You consent to the company storing and processing your personal data. By submitting your information through our official website or other channels, you also authorize us to transfer it to the relevant third-party trading platform when required. Your consent applies to the processing of your personal data for one or more specified purposes.
• To enhance our services, establish or defend legal claims, and pursue other legitimate interests, the company may need to store and process your personal data.
• Data processing is necessary to comply with legal obligations.

If you would like more information about the data processing we are required to perform, please contact us by email.

Below is a list of the specific purposes for which we may process your personal data, along with the applicable legal bases.

6. Disclosure of Personal Data to Third Parties

To store and process IP addresses, conduct user surveys and analysis, and deliver related services, the company may share anonymized personal data with verified third-party service providers.

At your request, we may share certain personal data you provide with third-party services. In such cases, the use of your data will be governed by that company’s privacy policy. This may include multiple digital trading platforms.

To better serve our clients and improve our services, the company may share personal information with its affiliates and partner companies.

Where required by law, or to protect our rights and property and those of our third-party partners, we may disclose data to competent law enforcement or regulatory authorities.

In connection with significant corporate transactions—such as a sale of the company, fundraising, or obtaining a loan—we may share relevant data in a lawful and appropriate manner. This also applies in the event of a merger, restructuring, consolidation, or bankruptcy, in accordance with applicable law.

Use of Cookies and Third-Party Services

We may use cookies and similar technologies for site analytics and, in cooperation with our advertising partners, in compliance with applicable laws and industry standards.

Cookies are small data files stored on your device when you visit our official website. We use them to collect information about your browsing behavior and preferences so we can personalize and enhance your experience. Cookies help us remember your settings and tailor our services accordingly. We also use them for site analytics and to compile statistics for performance monitoring and strategic planning.

Generally, the site uses two types of cookies. Session cookies are stored only for the duration of your visit and are deleted when you close your browser. Persistent cookies remain in your browser after your session ends. They help the site recognize you as a returning visitor and make it easier to use the site.

Types of cookies:

We may use cookies where necessary, in line with their intended purposes:

Cookies are blocked or have been deleted

If you wish to delete or block cookies, please do so via your browser settings. Refer to the links below for step-by-step instructions for the most popular browsers.

• firefox
• Microsoft Edge
• Google Chrome
• safari

If you block cookies, some operations and site features will not function as intended.

ONLINE TRACKING NOTICE

Your personal data will be retained for as long as necessary to fulfill the purposes described in this policy. It may be kept longer if required by local laws, regulations, or company policies.

At your request and discretion, we will share your personal data with third-party trading platforms for a period of 12 months. After this period ends, and with your consent, we will continue sharing the data for an additional 12 months.

As part of our operations, we regularly review all personal data to determine whether it remains necessary.

9. Transfers of personal data to third countries or international organizations

When necessary to deliver our services or for security reasons, personal data may be transferred to third countries (outside your country of residence) or to international organizations using verified security protocols. We apply stringent data protection standards to safeguard your information and ensure you retain access to legal remedies and rights in all circumstances.

Across the EEA (European Economic Area), all residents are protected under data protection laws and safeguards.

• All data transfers are conducted under EU legal jurisdiction and competence and comply with the data protection standards set out in Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”).
• All data transfers between public entities or authorities comply with Article 46(2) and are governed by a legally binding, enforceable agreement.
• The European Commission’s Standard Contractual Clauses, issued under Article 46(2)(c) of the GDPR, establish the conditions for data transfers, and such transfers are conducted in accordance with these Clauses. You can review the Clauses on the European Commission’s official website at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For more information about the specific security measures the company uses to protect your personal data during international (third-country) transfers, please send your request to info@wealthwaydigital.uk

10. Protection of Personal Data

Personal data is protected using the highest-level technical and organizational measures, aligned with industry best-practice standards. These measures are designed to prevent unlawful or accidental destruction, loss, or alteration of the data.

While we apply the highest level of care and follow gold-standard data protection procedures as required by law, we cannot guarantee that your personal data will be entirely error-free in all circumstances. Accordingly, we cannot be held liable for any disclosure of personal data or for incidental, non-material, or consequential damages. This includes events beyond our control, such as transmission errors, unauthorized access by third parties, or other similar causes.

If we are legally required by regulators or other lawful authorities, we may need to disclose your personal data to them. Once disclosed under such legal obligations, we cannot control how those authorities handle, store, or safeguard your data.

Data sent over the internet, including personal information, carries a risk of interception and is not completely secure. The Company cannot guarantee the security of any information transmitted online.

11. Links to Third-Party Websites

This website may include links that take you away from our official website to third-party applications and websites. These parties are not affiliated with us and operate independently; we do not control them, and our Privacy Policy does not apply. They maintain their own procedures and priorities for collecting and processing personal data, and we are not responsible for their practices. Please use these links at your own discretion.

Always review a company’s privacy policy on its official website before sharing any personal data. Ensure their data collection, use, and processing practices align with your preferences and priorities. If you choose to share information, do so directly with the service provider.

12. Policy Amendments

We may update or modify this policy at any time. Any changes will be communicated via our official website and other appropriate channels. The updated version of the privacy policy will be posted on the website and, unless stated otherwise, will take effect immediately upon publication.

13. Your Rights Regarding Personal Data

You retain full control and the final say over how your personal data is used, including the right to verify its accuracy, correct any errors, and choose to delete it or restrict the scope and nature of our processing.

This page provides information relevant to EEA residents:

Your personal data is protected by the rights described here. You can exercise these rights immediately by emailing the address below.

Accessing Your Rights

If the personal data you have provided is accurate, you may access it at any time. All personal data we process is accessible to us and therefore verifiable.

You may request your personal data at any time for verification, and we will provide it in electronic format. If you require additional copies of the data we process beyond the initial copy, a reasonable fee may apply.

Rights granted by law and the privacy policy must not violate the rights of others. The company may refuse or limit access to personal data if providing such access would infringe the rights and freedoms of others.

Right to Correct Inaccuracies

If your personal data contains errors—whether due to omissions or inaccurate details—you or the Company may correct them to ensure proper processing.

Erasure Rights

You are entitled to request the deletion of your personal data in the following cases: 1) if your data has been processed without your consent or outside the scope of applicable law; 2) if you ask us to remove it and the Company has no legal obligation to retain it; 3) if you object to any further processing by us, even if it is lawful and based on our or a third-party provider’s legitimate interests; and 4) if we are legally required to delete your data.

The right to deletion does not apply where EU or member state law imposes legal obligations on us, or where the data is required to establish, exercise, or defend legal claims.

Right to Restrict Data Processing

You have the right to request a restriction on the processing of your personal data if you believe it contains inaccuracies.

If you request that the use of your personal data be restricted, we will delete your data unless one of the following applies: 1) applicable law in the European Union or any Member State prevents deletion; 2) with your consent, it is needed to defend against or pursue legal claims; or 3) it is necessary to protect the rights of another natural person.

Data Portability Rights

You have the right to access and review any personal data you have provided if you have consented, in any form, to its collection and to processing carried out by automated systems.

You may request that we transfer any or all of your personal data to another company or organization, where technically feasible. This does not affect your right to have your data deleted. We cannot process such a request if doing so would infringe on the rights or freedoms of another individual.

Right to object to data processing

While the Company may rely on its legitimate interests, or those of a third-party service provider, you have the right to object to the processing of your personal data and request that it stop. This right does not apply where there is a compelling legal basis to continue processing, including for the establishment, exercise, or defense of legal claims. In such circumstances, we may continue processing your personal data.

You may object at any time to the processing of your personal data for direct marketing purposes.

Your Right to Withdraw or Refuse Consent

You may withdraw your consent to our processing of your personal data at any time, and we will, where feasible, give it immediate effect. This withdrawal does not apply retroactively to processing carried out before you withdrew consent.

If you are dissatisfied for any reason, you have the right to lodge a complaint with any legal, regulatory, or other supervisory authority.

If you believe your rights and freedoms related to the processing of your personal data have been violated, each European Union Member State has an independent regulatory and supervisory authority to handle such matters. You may lodge a complaint with any of these authorities at your discretion.

Section 13 outlines the circumstances in which your personal data rights may be limited under European Union law or the laws of its Member States.

Once we receive your request concerning your personal data and its processing, we will provide access to the information you requested, as outlined in Section 13 of this policy. We may extend the response period by up to two months, depending on the volume of requests and the nature of your request. If an extension is required, we will notify you within one month of receiving your request.

We will provide the requested information electronically at no cost, unless doing so would conflict with applicable law or the provisions in Section 13. We may charge a reasonable fee or decline requests that are unfounded, excessive, or repetitive.

If we have reasonable doubts about the identity of the person requesting access to personal data, we may request additional proof of identity to protect data and ensure security.