Privacy Policy

Introduction

PT WATTLY CHARGE TECHNOLOGIES, operating under the brand name Wattly ("Wattly", "we", "us", or "our"), is a private limited liability company registered in the Republic of Indonesia under Business Identification Number (NIB) 2307250001243 and Tax Identification Number (NPWP) 1000000004218054.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, disclose, transfer, and protect personal data when you interact with Wattly.

PT WATTLY CHARGE TECHNOLOGIES acts as the personal data controller for personal data processed through Wattly services. We process personal data in accordance with applicable Indonesian laws and regulations, including Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection.

Legal company name

PT WATTLY CHARGE TECHNOLOGIES

Brand name

Wattly

NIB

2307250001243

NPWP

1000000004218054

Registered address

Jalan Batu Bidak Nomor 88B, Kerobokan Kaja, Kuta Utara, Kabupaten Badung, Bali 80361, Indonesia

Scope of this Privacy Policy

This Privacy Policy applies when you use or interact with:

• the Wattly mobile application;
• the Wattly web application and website;
• Wattly power bank rental stations and QR codes;
• Wattly customer support and business communication channels;
• payment, authentication, messaging, and other features made available through Wattly; and
• any other product or service that links to this Privacy Policy.

This policy applies to users, customers, visitors, prospective customers, and other persons who interact with Wattly. It does not govern independently operated third-party services. Those parties process personal data under their own terms and privacy policies.

Personal data we collect

The categories of personal data we collect depend on how you use Wattly and which features you choose.

3.1 Account and identification information

• full name, mobile phone number, and email address;
• account identifier, profile picture, preferred language, country, or region;
• account status, registration date, and communication preferences; and
• other information you choose to add to your profile.

3.2 Authentication and verification information

• email and supported third-party authentication status;
• Google, Apple, Meta, WeChat, or other third-party authentication identifiers, where enabled;
• login time, authentication method, and security events; and
• information made available by an authentication provider with your permission.

We do not receive or store the password you use for an independently operated Google, Apple, Meta, WeChat, or similar account.

3.3 Rental and station information

• rental start and end time, duration, price, and status;
• power bank identifier, station identifier, and station location;
• QR code scan, device ejection, return, and slot status;
• rental history, outstanding amounts, and account balance;
• reports concerning late, lost, damaged, or incorrectly returned equipment; and
• operational records required to investigate a rental or station issue.

3.4 Payment and transaction information

• transaction amount, currency, payment method, and payment status;
• transaction, invoice, receipt, refund, and reconciliation identifiers;
• wallet or Wattly account balance information;
• payment provider response and risk indicators; and
• chargeback, refund, dispute, and fraud-prevention records.

Payments may be processed by authorized third-party payment service providers. These providers may separately collect card, bank account, electronic wallet, QR payment, or other financial information. Wattly generally receives payment status and related transaction metadata rather than full payment card credentials.

3.5 Device and technical information

• device type, model, operating system, browser, and application version;
• IP address, device or application identifiers, language, and time zone;
• date and time of access, session information, and interaction logs;
• network, connectivity, crash, diagnostic, and performance information; and
• security, login, fraud-prevention, and authentication logs.

3.6 Location information

With your permission, we may process approximate or precise location information to show nearby stations, help identify return locations, provide location-based service information, prevent fraud or misuse, and improve service coverage. You may control location access through your device settings. Some location-dependent features may not function correctly if permission is disabled.

3.7 Camera access

The Wattly application may request access to your camera so that you can scan QR codes on Wattly rental stations. We do not use camera access for unrelated surveillance or continuous recording.

3.8 Customer support information

• your contact and account details;
• the content of messages and support requests;
• screenshots or photographs you voluntarily provide;
• relevant rental, station, return, and transaction information; and
• support history and resolution records.

3.9 Website, analytics, and cookie information

When you access our website or web application, we may collect visited pages, session duration, referral source, browser information, device information, approximate geographic location, and interaction data through cookies, local storage, analytics technologies, and server logs.

How we collect personal data

We may collect personal data:

• directly from you when you register, rent, pay, contact support, or update your account;
• automatically through the Wattly application, website, stations, and technical systems;
• from payment, authentication, communication, analytics, mapping, and security providers;
• from Wattly station operators and authorized operational partners when needed to provide or investigate a service;
• from business partners where permitted by law and necessary for a stated purpose; and
• from public or regulatory sources where necessary for compliance, fraud prevention, or business verification.

Purposes of processing

We process personal data where reasonably necessary to:

• create, verify, secure, and manage your Wattly account;
• authenticate users through phone, email, or supported third-party sign-in providers;
• display nearby stations and initiate, manage, complete, or investigate rentals;
• calculate rental charges, process payments, issue receipts, and manage refunds or disputes;
• identify returned, unreturned, late, lost, damaged, or incorrectly returned devices;
• send account, rental, payment, security, and support messages;
• provide customer support and resolve technical, account, payment, or station issues;
• detect, investigate, prevent, and respond to fraud, abuse, security threats, or unlawful conduct;
• maintain, troubleshoot, measure, and improve our services, stations, availability, and user experience;
• enforce our Terms and Conditions and protect Wattly, our users, and our partners;
• comply with legal, regulatory, tax, accounting, reporting, and lawful authority requirements; and
• communicate material changes to our services, terms, or privacy practices.

We will not use personal data for a materially incompatible purpose without providing appropriate notice and, where required, obtaining consent.

Legal bases for processing

Depending on the activity and applicable law, we may rely on one or more of the following legal bases:

• Consent: when you give clear permission, including for optional location access, marketing, or non-essential cookies where required.
• Performance of a contract: when processing is necessary to create your account, provide a rental, process payment, or perform our obligations to you.
• Legal obligation: when we must retain, use, or disclose information to comply with law, regulation, taxation, accounting, or a lawful request.
• Legitimate interests: when reasonably necessary to secure, operate, analyze, and improve Wattly, prevent fraud, resolve disputes, and protect users, provided those interests are not overridden by your rights.
• Protection of vital or public interests: where processing is permitted or required to protect a person or support a lawful public interest.

Where consent is the legal basis, you may withdraw it at any time. Withdrawal does not affect processing already performed lawfully before the withdrawal.

Service and marketing communications

We may send transactional or service-related communications concerning:

• account access and security;
• rental start, progress, return, completion, or overdue status;
• payment confirmation, failure, refund, chargeback, or outstanding balance;
• station availability, operational incidents, or customer support requests; and
• material changes to our services, legal terms, or privacy practices.

These messages may be necessary to provide the Wattly service and are not always treated as marketing. We may send promotional communications where permitted by law and, where required, after receiving consent. You may opt out of marketing at any time, but you may continue to receive necessary account, rental, payment, and security messages.

Disclosure of personal data

We may disclose personal data, only where reasonably necessary, to:

• payment service providers, banks, electronic wallets, and payment networks;
• email, push notification, voice, WhatsApp, and other communication providers;
• cloud hosting, storage, infrastructure, cybersecurity, and backup providers;
• authentication providers such as Google, Apple, Meta, or WeChat, where enabled;
• analytics, crash reporting, application monitoring, mapping, and location service providers;
• customer support, fraud prevention, identity verification, and risk management providers;
• Wattly station owners and authorized operational partners where necessary to provide or investigate a rental;
• auditors, accountants, insurers, lawyers, and other professional advisers;
• government authorities, regulators, courts, or law enforcement where required or permitted by law; and
• a successor or relevant counterparty in a lawful merger, acquisition, financing, restructuring, or transfer of all or part of our business.

International data transfers

Some service providers used by Wattly may operate or store information outside Indonesia. Where personal data is transferred internationally, we take reasonable steps to ensure that the transfer is conducted in accordance with applicable law and that an appropriate level of protection is maintained.

Safeguards may include contractual data protection obligations, security requirements, access controls, transfer assessments, and review of the recipient's privacy and security practices.

Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy. Retention may depend on:

• whether your account is active or a rental remains open;
• tax, accounting, payment, and regulatory recordkeeping requirements;
• fraud prevention, security, and service integrity requirements;
• refund, chargeback, dispute, complaint, and limitation periods;
• the establishment, exercise, or defense of legal claims; and
• legitimate and documented operational needs.

After account closure, certain account, rental, transaction, and communication records may be retained where required for legal compliance, payment reconciliation, fraud prevention, dispute resolution, or enforcement of agreements. When personal data is no longer required, we delete it, anonymize it, or securely restrict access, subject to applicable law.

Data security

We use reasonable administrative, organizational, physical, and technical safeguards designed to protect personal data against unauthorized access, accidental loss, unlawful use, alteration, disclosure, or destruction.

Measures may include encryption, access controls, authentication, logging, monitoring, backups, software maintenance, incident response procedures, and restrictions on employee and service-provider access.

No internet transmission, electronic storage system, or security measure can guarantee absolute security. You are responsible for protecting your device, account access, sign-in methods, and credentials. Never share your account credentials with another person.

Your rights and choices

Subject to applicable law and verification of your identity, you may have the right to:

• receive clear information about how your personal data is processed;
• request access to personal data associated with your account;
• request correction of inaccurate or incomplete personal data;
• request deletion or destruction of eligible personal data;
• withdraw consent where processing relies on consent;
• object to or request restriction of certain processing;
• request a copy of certain personal data in an appropriate form;
• request termination of processing in applicable circumstances; and
• submit a complaint regarding our handling of personal data.

These rights may be limited where processing or retention is necessary for legal compliance, tax or accounting records, payment reconciliation, fraud prevention, security, dispute resolution, contractual obligations, or legal claims.

To exercise a privacy right other than in-product account deletion, contact us using the details in Section 18. We may request information reasonably necessary to confirm your identity, locate your account, and protect your data from unauthorized requests. Account deletion is completed through the Wattly mobile application or H5/PWA version as described in Section 13.

Account and data deletion

You may delete your Wattly account only when your account has no outstanding debt, unpaid rental charges, or other amounts due to Wattly. If an outstanding amount exists, the account deletion function will not be available until the full amount has been paid and the account balance shows no debt.

Once all outstanding amounts have been paid, you may delete your account using either of the following Wattly services:

• the account deletion function in the Wattly mobile application; or
• the account deletion function in the Wattly H5/PWA version at https://cdb.wattly.id/h5new/.

You must sign in to the relevant Wattly service and confirm account deletion using the function provided in your account or profile settings. We may require you to confirm your identity again before deletion is completed. Uninstalling the mobile application, signing out, or ceasing to use Wattly does not delete your account.

After account deletion is confirmed, we will delete or anonymize eligible personal data within a reasonable period. We may retain records that are required for legal, payment, taxation, accounting, security, fraud prevention, dispute resolution, debt recovery, or regulatory compliance. Such retained records will remain protected and will not be used for unrelated purposes.

Children's privacy

Wattly services are intended for users aged 12 years and older. Users under the age of 18, or under the applicable age of legal majority, may use Wattly only with the consent and supervision of a parent or legal guardian where required by law. The parent or legal guardian is responsible for the minor's use of the account, rentals, and payments.

We do not knowingly allow children under the age of 12 to create or use a Wattly account. If we learn that personal data from a child under 12 was collected without valid authorization, we will take reasonable steps to delete or restrict that data. A parent or legal guardian may contact us using the details in Section 18.

If applicable law requires a higher minimum age or does not permit a minor to enter into a rental or payment agreement, the higher legal requirement will apply.

Third-party services

Wattly may integrate with or link to independently operated payment services, electronic wallets, authentication providers, maps, messaging services, app stores, social platforms, and external websites.

These third parties may collect and process information under their own terms and privacy policies. Their privacy practices are not controlled by this Privacy Policy. We encourage you to review the privacy notices of each third-party service you choose to use.

Cookies and similar technologies

Our website and web application may use cookies, local storage, and similar technologies to:

• maintain sessions and keep users signed in;
• remember language and service preferences;
• protect account and website security;
• measure performance and diagnose technical issues;
• understand how services are used; and
• support analytics or marketing where permitted.

Where required by law, non-essential cookies will be used only after appropriate consent. You may control cookies through your browser settings. Disabling some cookies or storage may affect website or web application functionality.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our services, legal requirements, security practices, business operations, or third-party integrations. The updated version will be published on the Wattly website with a revised "Last Updated" date.

Where required by law or where a change materially affects your rights, we may provide additional notice through the application, website, email, or another appropriate channel.