Effective Date: 18 April 2026

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PT. Ace Perkasa Globe, trading as 3on-pay (“3on-pay”, “we”, “us”, or “our”), respects your privacy and is committed to protecting personal information processed in connection with our merchant acquiring, payment processing, and related services.

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This Privacy Policy explains what personal information we collect, how and why we use it, how we protect it, when we may share it, and the rights available to individuals under applicable data protection laws.

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1. Who We Are

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PT. Ace Perkasa Globe, trading as 3on-pay, provides merchant acquiring, payment processing, and related payment services.

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For privacy-related questions, requests, or concerns, please contact us using the details provided in the Contact Ussection of this Privacy Policy.

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2. Personal Information We Collect

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Depending on the services we provide and your relationship with us, we may collect and process:

• Your name, business name, address, telephone number, email address, and other contact details;

• Merchant account, registration, and onboarding information;

• Business, financial, and transaction information;

• Payment and settlement information;

• Bank account details required to process merchant settlements;

• Information relating to transactions, refunds, chargebacks, disputes, and related activity;

• Identification and verification information where required for regulatory or compliance purposes;

• Device, technical, and usage information when you access or use our websites, platforms, or systems;

• Communications and correspondence between you and 3on-pay; and

• Information required to detect, investigate, and prevent fraud, financial crime, abuse, or other unlawful or unauthorised activity.

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We seek to collect only information that is reasonably necessary for the purposes for which it is processed.

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3. How We Use Personal Information

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We may use personal information to:

• Provide, administer, and support our merchant acquiring and payment services;

• Process, authorise, settle, and reconcile payment transactions;

• Verify merchants, customers, and authorised users;

• Communicate with merchants, customers, business partners, and service providers;

• Process refunds and manage disputes and chargebacks;

• Detect, investigate, and prevent fraud, money laundering, financial crime, and other unlawful activity;

• Maintain the security, availability, and integrity of our systems and services;

• Comply with applicable legal, regulatory, and contractual obligations;

• Respond to complaints, enquiries, and requests;

• Maintain appropriate business records, audit trails, and transaction records;

• Analyse and improve our services, systems, and customer experience; and

• Send service-related communications and, where legally permitted, marketing communications.

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4. Lawful Basis for Processing

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Where applicable, we process personal information on one or more of the following legal bases:

Contract: Where processing is necessary to provide our services, establish or perform an agreement, or take steps at your request before entering into an agreement.

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Legal Obligation: Where processing is necessary to comply with applicable laws, regulations, regulatory requirements, court orders, or other legal obligations.

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Legitimate Interests: Where processing is necessary for legitimate business purposes, such as security, fraud prevention, service administration, risk management, and business operations, provided that those interests are not overridden by applicable individual rights.

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Consent: Where we have requested and obtained your consent for a specific processing purpose.

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The applicable lawful basis will depend on the nature and circumstances of the processing.

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5. Payment Information

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Payment transactions may involve sensitive financial information. We process payment information only where necessary to provide payment and acquiring services, complete and settle transactions, manage refunds and disputes, prevent fraud, comply with legal and regulatory requirements, and perform related operational functions.

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Where card payment information is processed, we seek to minimise the personal information handled directly by 3on-pay. We may use specialist payment processors, card networks, acquiring partners, banks, and other service providers to facilitate payment processing.

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6. Sharing Personal Information

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We may share personal information where necessary and permitted by applicable law with:

• Banks, payment processors, acquiring institutions, card schemes, and payment networks;

• Fraud prevention, identity verification, and financial crime prevention providers;

• Technology, hosting, cybersecurity, infrastructure, and other service providers;

• Professional advisers, auditors, accountants, insurers, and consultants;

• Regulators, law enforcement agencies, courts, government authorities, or other competent authorities where legally required or permitted;

• Companies involved in a merger, acquisition, restructuring, financing, sale, or transfer of all or part of our business or assets; and

• Other parties where you have provided appropriate consent or where disclosure is otherwise permitted or required by law.

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Where third parties process personal information on our behalf, we seek to ensure appropriate contractual, technical, and organisational safeguards are in place.

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7. International Transfers

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Some of our service providers, technology providers, payment partners, or other business partners may process personal information outside the country in which it was originally collected.

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Where applicable law requires safeguards for international transfers, we will take appropriate measures to ensure that personal information receives an appropriate level of protection.

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8. Data Security

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We implement reasonable technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, misuse, alteration, destruction, or disclosure.

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However, no electronic transmission, communication, or storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of personal information transmitted to or stored by us.

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9. Data Retention

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We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide and administer our services;

• Maintain transaction, accounting, and business records;

• Resolve disputes and complaints;

• Detect and prevent fraud and financial crime;

• Meet contractual obligations; and

• Comply with applicable legal, regulatory, and reporting requirements.

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Retention periods may vary depending on the type and nature of the information and the applicable legal or regulatory requirements.

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10. Your Privacy Rights

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Depending on applicable law and your circumstances, you may have certain rights regarding your personal information, including the right to:

• Request access to personal information we hold about you;

• Request correction of inaccurate or incomplete information;

• Request deletion of personal information in appropriate circumstances;

• Request restriction of certain processing activities;

• Object to certain types of processing;

• Request portability of your personal information where applicable;

• Withdraw consent where processing is based on consent; and

• Lodge a complaint with the relevant data protection or privacy authority.

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These rights are subject to applicable legal limitations, exemptions, and conditions.

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If you wish to exercise a privacy right, please contact us using the details provided below.

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11. Cookies and Similar Technologies

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Our websites and online services may use cookies and similar technologies to:

• Operate and secure our websites and services;

• Remember preferences and settings;

• Understand how our websites are used;

• Analyse performance; and

• Improve our websites, services, and user experience.

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Where consent is legally required for non-essential cookies or similar technologies, we will provide an appropriate consent mechanism.

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12. Changes to This Privacy Policy

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We may update this Privacy Policy from time to time to reflect changes to our services, technology, business practices, legal requirements, or data protection practices.

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The latest version of this Privacy Policy will be made available through the appropriate 3on-pay website or service channel.

We recommend reviewing this Privacy Policy periodically to remain informed about how we process and protect personal information.

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13. Contact Us

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If you have any questions about this Privacy Policy, wish to exercise a privacy right, or have a concern about how your personal information is handled, please contact us:

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PT. Ace Perkasa Globe t/a 3on-pay

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Email: support@3on-pay.com

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Address:
PT. Ace Perkasa Globe t/a 3on-pay
CIBIS Nine Building Lt 11
JL. TB Simatupang No. 2
Cilandak Timur, Pasar Minggu
Jakarta Selatan 12560 Indonesia

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Company Registration Number: 1000000009024556