Privacy Policy - WTI

PT Webull Technologies Indonesia


Webull Privacy Policy


Last Updated: 05 November 2024



Welcome to Webull!


At Webull, we take privacy and security seriously. PT Webull Technologies Indonesia and its affiliates (collectively, “Webull”, “we”, “our” or “us”) are committed to protecting the privacy and security of your Personal Information (defined below). This Privacy Policy (“Policy”) applies to the Personal Information processing activities conducted by Webull in the provision of our services, systems, websites, and apps (the “Services”), as the owner and operator of our mobile device applications and our websites.


Please note that this Policy exclusively applies to your usage of the Services without your registration for a broker-dealer account or other financial services of ours. If you choose to register for a broker-dealer account or other financial services, those services will be provided by one of our affiliates and may have a different privacy policy.


This Policy describes our policies regarding the collection, use, disclosure, transfer, processing, storage, and sharing of your Personal Information across our websites, application programming interfaces, text messages, email notifications, applications, buttons, and our other covered Services that are linked to this Policy, and from our partners and other third parties. By accessing and/or using our Services, that you have read and understood this Policy you acknowledge. This includes any Personal Information you choose to provide that is deemed sensitive under the applicable laws in Indonesia. This Policy is a legally binding agreement between you (“you” or “user”) and us.


When this Policy mentions “we” or “us”, it refers to PT Webull Technologies Indonesia as the data controller of your Personal Information under this Policy.


IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING AND UNINSTALL THE APP IMMEDIATELY.


If you have any questions about this Policy or the Services, please contact us (see HOW TO CONTACT US below).


This Policy will help you understand the following:


1. THE INFORMATION WE COLLECT


2. HOW WE USE YOUR PERSONAL INFORMATION


3. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES


4. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION


5. HOW WE PROTECT YOUR PERSONAL INFORMATION


6. RETENTION OF YOUR PERSONAL INFORMATION


7. RIGHTS OF THE DATA SUBJECTS


8. DELETION OF YOUR ACCOUNT


9. HOW WE PROTECT THE INFORMATION OF MINORS


10. THIRD-PARTY SITES


11. HOW YOUR INFORMATION MOVES GLOBALLY


12. HOW THIS PRIVACY POLICY IS UPDATED


13. LANGUAGE


14. HOW TO CONTACT US



1. THE INFORMATION WE COLLECT


Personal Information means information that identifies an individual, be it separately and/or in combination with other information, either directly or indirectly, through an electronic or non-electronic system (“Personal Information”).


When you use our Services, your Personal Information may be collected and used in the following scenarios:


• When you choose to create a Webull account using your email address or mobile phone number, we will collect these contact information. We may send emails, text messages, or push notifications to you. You may follow the relevant notice to unsubscribe to these Services.


• When you register with Webull using your existing Google account, Facebook account, or other third-party accounts, we will obtain your Personal Information from the third party, such as images of you, your nickname or username.


• If you do not have a Webull account or you chose to use Webull without a login, you will not be regarded as a client of Webull and there will be no business relationship between you and Webull.


• You may also add or link your mobile phone numbers, email addresses, third-party accounts to your existing Webull account. We will collect such additional information so that you can log in to Webull using this information.


• When you use our Services, we may automatically collect and store your usage information. This usage information includes how you access our Services, your actions on the Services, including your interactions with other users of the Services, photos, or media you upload to the Services, and other content you provide (collectively referred to as “Usage Information”).


• We will only access your device camera and photo album with your permission when you want to upload photos to Webull help center, update your account profile image, or post photos in Webull Community.


• We will only access your device microphone with your permission when you want to search for stocks with voice command.


• We will only access your device calendar with your permission when you want to add alerts or economic data to your calendars.


2. HOW WE USE YOUR PERSONAL INFORMATION


We will only use your Personal Information when the law allows us to. Please note that we may process your Personal Information based on more than one lawful ground (e.g., your consent, performance of a contract with you, necessary for our legitimate interests, or necessary to comply with a legal obligation) depending on the specific purpose for which we are using your Personal Information. Please contact us (see HOW TO CONTACT US below) if you need details about the specific legal grounds we are relying on to process your Personal Information where more than one ground has been set out. Most commonly, we use your Personal Information for the following purposes, legal grounds, or circumstances.


In relation to the Services


We will engage in these activities to manage our contractual relationship with you and necessary for our legitimate interests:


• to provide any of our Services to you;


• to develop and improve our Services;


• to send push notifications of our products, Services, and other information you may be interested in;


• to evaluate and improve the effectiveness of our promotions;


• to invite you to take surveys for the purpose of assessing our Services; and


• to assess potential risks relating to our Services.


Compliance


We engage in these activities necessary to comply with a legal obligation under applicable laws and regulations which are applicable to us:


• to verify your compliance with the terms and conditions governing the use of our Services, including but not limited to enforce our [TERM OF SERVICES] and this Policy, take precautions against liability or harm, investigate and respond to third-party claims or allegations, respond to court orders or official requests, protect the security or integrity of the Services, and protect the rights, property, or safety of us, or others;


• to comply with laws and regulations applicable to us in or outside of Indonesia;


• to respond to or take part in legal proceedings, including seeking professional advice;


• to comply with any mandatory investigations pursuant to applicable laws and regulations, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person, including but not limited to defense of legal claims as necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;


• to fulfil any legal, regulatory and compliance requirements that apply to us and our Services and Services based on the applicable laws and regulations, as well as compliance with applicable agreements relating to the implementation of our Services;


• to implement the instructions or policies of the government, regulatory bodies, or authorised agencies;


• to carry out our obligations in relation to any agreement with our business partners or contractors; and


• to process our internal processes such as audit and taxation matters.


Others


We will use your Personal Information under other circumstances, after your authorisation.


3. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES


Our website may use cookies and similar tracking technology to automatically collect and receive certain technical and usage information such as internet protocol address, browser, internet service provider and device type when you connect with our Services. Cookies are small packets of data that a website stores on your hard drive so that your device will remember information about your visit. The data collected through cookies and similar tracking technology enables us to personalize your experience with the Services, understand how you use them, maintain a persistent session, improve, and further develop the Services, and measure and optimize advertising and promotional effectiveness. We may use session cookies (which expire once you close your web browser), and persistent cookies (which stay on your computer until you delete them). Most browsers and mobile devices allow you to manage cookies in the settings. If you refuse a cookie, or if you delete cookies from your device, you may lose functionality and/or experience some inconvenience in your use of our Services. For example, you may not be able to sign in and access your account as quickly, or we may not be able to recognize you, your device, or your online preferences. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again. For more information, see DELETION OF YOUR ACCOUNT.


4. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR INFORMATION


We do not disclose your private Personal Information except in the limited circumstances described here.


Service providers. We engage service providers to perform certain functions and provide certain services. For example, we use a variety of third-party services to help us understand and improve the use of our Services, such as Google Analytics. We may share your private Personal Information with these service providers, subject to our obligations to adhere to this Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. We share your payment information, including your credit or debit card number, card expiration date, CVV code, and billing address with payment services providers to process payments, prevent, detect, and investigate fraud or other prohibited activities, facilitate dispute resolution such as chargebacks or refunds, and for other purposes associated with the acceptance of credit or debit cards.


Law and harm. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal processes, or governmental requests; to protect the safety of any person; to address fraud, security, or technical issues; or to protect our or our users’ rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to the request of a third-party, including a government, to disclose your information.


Business transfers and affiliates. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction. This Policy will apply to your information as transferred to the new entity. We may also disclose information about you to our corporate affiliates, including our affiliates that provide financial services, in order to help provide, understand, and improve our Services and our affiliates’ services.


Public information. We may share or disclose your public information, such as your public user profile information and public comments.


5. HOW WE PROTECT YOUR PERSONAL INFORMATION


Webull uses reasonable, industry standard security measures to protect information under our control from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We maintain appropriate physical, electronic, and procedural safeguards, including restricting access to Personal Information on a need-to-know basis, and limiting the amount and type of information available for downloading or transmittal. We also regularly conduct audits to ensure the effectiveness of our system. Please understand, however, that no security system is impenetrable. We cannot guarantee that our security measures will prevent hackers from illegally obtaining this information, or that our database and/or systems will not be subject to a cyber-attack.


We have established a data breach management plan. If there is a data breach involving the Personal Information of our users, we will activate the data breach management plan to contain the data breach to prevent data from being further compromised and take appropriate measures to inform you, including in the form of push notifications, public announcements, or other appropriate means.


You acknowledge that no safeguards are guaranteed to be completely effective. We strongly suggest that you perform all uploads in a secure internet environment and use a strong password for your account. Please contact us (see HOW TO CONTACT US below) immediately if you have reason to believe your account security has in any way been compromised.


6. RETENTION OF YOUR PERSONAL INFORMATION


Webull retains your Personal Information for as long as necessary to accomplish the purpose for which it was collected, to meet our legal and regulatory obligations including compliance with our records retention practices, or as required or permitted by applicable laws and as permitted to meet our legitimate interests.


7. RIGHTS OF THE DATA SUBJECTS


As a data subject, you are entitled to do the following:


a) request to access or have copies of your own Personal Information that is on our platforms;


b) modify, update, and/or rectify your Personal Information that is on our platforms in order to make it accurate;


c) request the transfer or portability of your Personal Information, where you can ask us to move, duplicate, or transfer your Personal Information from one data processing system to another, to the extent that it is technically possible and reasonable in terms of implementation costs;


d) request for the termination of the processing activities, erasure, and/or destruction of your Personal Information from our platforms, in accordance with the prevailing laws and regulations;


e) object to a decision-making based on an automated data processing, including profiling, that may produce legal effect or significant impact to you;


f) postpone or limit or the processing activity to your Personal Information proportionally, in accordance with the purposes of the processing of your Personal Information as set out in this Policy; and


g) revoke your consent to the processing activities to your Personal Information.


The requests as described above are to be conveyed to the contact address set out in this Policy (see HOW TO CONTACT US below). Additionally, if you are a registered user of our Services, we provide you with tools and account settings to access, correct, delete, or modify the Personal Information you provided to us in connection with your account. You also can download certain account information.


8. DELETION OF YOUR ACCOUNT


You can permanently delete your Webull account. When your account has been deactivated, information relating to your account, including your name, username, and public profile, is no longer viewable on our Services, including the Webull app. For up to 30 days after deactivation it is still possible to restore your account if it was accidentally or wrongfully deactivated. Absent a separate arrangement between you and us to extend your deactivation period, after 30 days, we will begin the process of deleting your account from our systems, which can take up to a week.


Keep in mind that search engines and other third parties may still retain copies of your public information, such as any posts and comments you made in the Webull Community, even after you have deleted the information from the Services or deactivated your account.


9. HOW WE PROTECT THE INFORMATION OF MINORS


The Services are not directed to children, we do not intentionally collect information from children, and we request that children not provide any Personal Information to us. If you have any concerns about your child’s privacy, please contact us (see HOW TO CONTACT US below). Should we discover that we have unintentionally collected Personal Information from your child without your consent, we will take steps to delete the information as soon as possible.


10. THIRD-PARTY SITES


Our Services or our communication with you may occasionally include links to websites, plug-ins, applications, or services provided by third parties. Please be aware that we have no control over these websites or services, and they have their own practices and policies. If you follow a link to visit any of these websites or use their services, we recommend that you review their privacy notices or statements to understand your rights. We are not responsible or liable for the practices, including data processing activities, of these third-party websites or services.


11. HOW YOUR INFORMATION MOVES GLOBALLY


We store your Personal Information on servers within the territory of the Republic of Indonesia and you will be deemed to accept such jurisdiction over your information.


Our products and Services are available across a number jurisdictions, each of which has different data protection laws that vary in the amount of protection they provide. In all cases, we will make reasonable efforts to ensure that your Personal Information is adequately and equally protected. In providing our Services, your Personal Information may be accessed by our affiliates in jurisdictions other than where you use our Services.


12. HOW THIS PRIVACY POLICY IS UPDATED


We may revise this Policy from time to time. The most current version of the Policy will govern our use of your information. If we make any change to this Policy that, in our sole discretion, is material, we will update the Policy on our website or our app without a separate notification sent to you. Please refer to the most updated version of this Policy on our Webull app or our website. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Policy.


While all Services of Webull are subject to this Policy, some Services have their own specific privacy notice or policy. Some specific privacy notice or policy may describe how we process your information in the performance of that service more specifically. If this Policy is inconsistent with the privacy notice or policy of a particular service, the privacy policy of that service shall prevail.


13. LANGUAGE


This Policy is made in both the English language and Indonesian language. In the event of any conflict between the English language version and the Indonesian language version of this Policy, the Indonesian language version will prevail.


14. HOW TO CONTACT US


If you have any questions, comments or suggestions about this Policy please contact us via email at support@webull.co.id.


We will normally reply to you within fifteen (15) business days.