GENERAL TERMS AND CONDITIONS

TRANSACTION

A. Scope of Trading Activities

INDODAX allows Member to carry out trading activities on the INDODAX Platform, namely:

1. Purchase of Crypto Assets with Rupiah.

2. Sale of Crypto Assets with Rupiah.

3. Deposit money with Rupiah.

4. Make withdrawals in Rupiah.

5. Conduct barter trading between Crypto Assets against fellow users on the INDODAX Website.

6. To send Crypto Assets to other Member on the INDODAX's Website and Crypto Asset users outside the INDODAX Website.

7. Accept deposits in various forms of Crypto Assets.

B. Indodax Transaction Procedure

1. Buy and sell transactions on Indodax

Member must verify their Account first. After the Member's Account is verified, the Member can visit the market page. Next, Member can deposit or put some funds into the INDODAX Account. Member can immediately make buying and selling transactions by selecting the desired digital assets on the market page. Member can press the "Buy" button to make a purchase, and then Member can press the "Sell" button to sell digital assets at INDODAX.

2. Deposit on INDODAX

2.1 Rupiah Deposit

• • • • Member does the Know Your Customer (KYC) process on the INDODAX Account.
      • After going through the KYC process, Member can deposit Rupiah through the indodax.com website or the INDODAX application with features that have been prepared, namely pro and lite modes; if using the pro mode, you can click "deposit" on the home page. If using the lite mode, you can click "wallet." Then click "deposit".
      • Next, Member can choose a virtual account method with available banks. When making a Rupiah deposit, use an account with the same name as your Indodax Account.
      • After selecting the virtual bank, the Member is requested to copy the virtual account number that appears and then follow the instructions.
      • After the Member makes a fund transfer, the Customer Support Division will check the Member's deposit.

2.2 Crypto Asset Deposit

• • • • Member create an INDODAX Account and carry out the Know Your Customer (KYC) process on the INDODAX Account
      • After going through the KYC process, Member can deposit Rupiah through the indodax.com website or the INDODAX application with features that have been prepared, which are pro and lite modes. You can click "deposit" on the home page if you use pro mode. If using the lite mode, you can click "wallet" and then click "deposit."
      • Then, the Member can choose the Deposit option on the desired crypto asset
      • Member can select an available network and copy the wallet address, and Member can provide the address to the sender of the crypto asset to receive the asset.
      • The deposit will go to INDODAX Account after the crypto asset delivery transaction is confirmed on the blockchain network.
      • Suppose a Member makes a crypto asset deposit transaction error using a network that INDODAX does not support. In that case, the Customer Support team will submit a refund process to the relevant team so that the digital assets that enter the INDODAX wallet are returned to the digital asset sender.

3. Withdrawal on INDODAX

• • • Member create an INDODAX Account and carry out the Know Your Customer (KYC) process on the INDODAX Account
    • After passing the KYC stage, the Member can open the INDODAX wallet page through the Indodax.com website or the INDODAX application.
    • Member ensures that they already have an active rupiah balance, then Member can select the "withdraw IDR" option available.
    • Member can follow the instructions on the Rupiah withdrawal page and fill in the data in the provided column.
    • Member authorizes Two-Factor Authentication (Google Authenticator or SMS PIN) / biometrics in order to proceed with the rupiah withdrawal process.
    • After that, the Member must also confirm the withdrawal of Rupiah by clicking on the withdrawal confirmation e-mail sent to the e-mail registered to the Member's INDODAX Account.
    • After the Member confirms the withdrawal, the Member's withdrawal request will go to the Customer Support Team.
    • The Customer Support Team verifies the rupiah withdrawal request by checking the suitability of the name and destination account number submitted by the Member.
    • If appropriate, the Customer Support team will forward the Member's rupiah withdrawal request to the PG (Payment Gateway) to be processed and sent to the destination account.
    • If the account name does not match the Member's account name, the Customer Support team will reject the Member's withdrawal request and ask the Member to submit a withdrawal again with the appropriate data.

4. Transferring Digital Assets to Another Wallet

• • • Member create an INDODAX Account and carry out the Know Your Customer (KYC) process on the INDODAX Account.
    • After passing the KYC stage, the Member can open the INDODAX wallet page through the Indodax.com website or the INDODAX application.
    • Member ensure that they already have an active balance of crypto assets. Next, the Member can send crypto assets to another wallet.
    • Member can follow the instructions on the crypto asset delivery page and fill in the crypto asset withdrawal data in the fields provided.
    • Member authorizes Two-Factor Authentication (Google Authenticator or SMS PIN) / biometrics in order to proceed with the crypto asset withdrawal process.
    • After that, the Member must also confirm the withdrawal of digital assets by clicking on the withdrawal confirmation e-mail sent to the e-mail registered to the Member's INDODAX Account.
    • After the Member confirms that crypto assets have been sent to another wallet, the request will be entered into the INDODAX system.
    • The account system verifies and forwards the process of sending crypto assets to the destination wallet via the blockchain network.
    • If the process is successful, the transaction status will change to success, and this means that the crypto asset has been sent through the blockchain network to the destination wallet.
    • If the process fails, the transaction status will change to 'cancelled,' and the assets will be returned to the Member's wallet in INDODAX after being verified again by the INDODAX Customer Support Division.

C. Transaction Fees

Transaction fees in INDODAX, as seen from the online process, can be seen periodically and change at any time based on the rules and/or policies of INDODAX.

D. Refusal, Delay, and Cancellation of Transactions

1. INDODAX has the right to postpone and/or refuse transactions if INDODAX knows or, based on considerations, suspects that fraudulent activities and/or criminal acts have been and/or will be carried out.

2. The Member agrees and acknowledges that to the extent permitted by applicable legal provisions, INDODAX is obliged to refuse to process any transaction.

3. The Member acknowledges that INDODAX is subject to the laws about financial crimes, including but not limited to the Corruption Eradication Law and the Money Laundering Law applicable in Indonesia and internationally, all applicable laws and regulations in Indonesia and INDODAX's internal policies. Following this purpose, the Member agrees to provide all information requested by INDODAX to comply with these laws and regulations, including but not limited to information on the name, address, age, gender, personal identity information, income, occupation, assets, debts, sources of wealth, the purpose of opening an Account, investment objectives, any financial plans or other relevant financial information of the Member. If required by INDODAX, the Member also agrees to provide updated data on such information to INDODAX.

4. INDODAX is obliged to comply with laws, regulations, and requests of public and government agencies in different jurisdictions relating to preventing financing for terrorists and sanctioned parties, among others. This may cause INDODAX to prevent and investigate any payment orders and other information or communications sent to or by Member or on behalf of Member through the INDODAX system. This process may also involve INDODAX to conduct further investigation to determine whether the name appearing in any transaction made or to be made by the Member through his/her Account is the name of a terrorist.

5. INDODAX shall not be liable for any loss (whether direct and including but not limited to loss of profit or interest) or loss suffered by any party arising from any delay or omission of INDODAX to process any such payment order or other information or communication or to carry out any other obligation, caused in whole or in part by any action taken under number 4 of this Transaction Refusal and Delay provision.

6. INDODAX is authorized to monitor Member' Accounts, including but not limited to monitoring Rupiah and Crypto Asset transactions, to prevent financial crimes.

7. Member understands, comprehends, and agrees that every transaction made through INDODAX is final and cannot be cancelled by the Member.

E. Suspicious Transaction

1. In the event of suspicious transactions made through INDODAX services, INDODAX has the right to stop/deactivate the Member's Account, block transaction funds, and postpone transactions made by the Member until notification from INDODAX.

2. In the event of suspicious transactions and/or transactions that exceed the transaction volume limits set by INDODAX against the Member for any reason whatsoever, INDODAX has the right at any time to delay crediting funds to the Member's Account and/or block the Member's Account until the investigation process is completed within the period determined by INDODAX.

3. Suppose it is proven that the transactions mentioned in numbers 1 and 2 above regarding suspicious transactions are transactions that violate the SKU and/or applicable laws and regulations, then the Member hereby authorizes INDODAX to debit Crypto Assets in the INDODAX Crypto Wallet to compensate INDODAX for losses arising from these transactions, without reducing the right to claim compensation for all losses arising from these transactions and the Member hereby agrees that INDODAX is not obliged to return funds that have been delayed by INDODAX or blocked funds as referred to in number 2 of this provision regarding suspicious transactions.

4. INDODAX has the right to report all types of Member transactions that are suspected to be sufficient and/or have been proven suspicious to the authorized agency, namely the Financial Transaction Reports and Analysis Center ("PPATK") as a form of INDODAX's compliance with the laws and regulations of the Republic of Indonesia.

F. Transaction Security

INDODAX has implemented a network and security measures as an information security network against unauthorized access in the use, change, and/or disclosure of accounts, with security standards that are under the provisions of the applicable laws and regulations.
Apart from that, transaction security has also been implemented by INDODAX in each of its transactions (Rupiah deposits, digital asset deposits, Rupiah withdrawals, and Digital Asset Delivery to other Wallets).

a. Rupiah Deposit

Transaction security on Rupiah deposits is as follows:

• • • Deposits must be submitted by Member themself to their INDODAX Account.
    • INDODAX Member Accounts must have passed the Know Your Customer (KYC) process.
    • Deposit to an INDODAX Account must use the same bank account as the name on the Member's INDODAX Account.
    • Member can deposit into their INDODAX Account using the method provided and must ensure that the destination account number or payment code is correct.

b. Digital Asset Deposit

Transaction security on crypto asset deposits is as follows:

• • • INDODAX Member Accounts must have passed the Know Your Customer (KYC) stage.
    • Assets that want to be deposited into INDODAX must match those already available / listed on the INDODAX market.
    • Asset deposits made by fellow INDODAX Member can be made if they include the correct username name and have registered as an INDODAX Member.
    • Depositing Assets from an outside exchanger to INDODAX must ensure that it uses the same network as the ones supported by INDODAX.
    • For some assets with memos, you must include the correct INDODAX Account memo if you want to make a deposit.

c. Rupiah Withdrawal

The transaction security on withdraw Rupiah is as follows:

• • • INDODAX member accounts must have passed the Know Your Customer (KYC) stage.
    • Withdrawal must be submitted by the account owner (verified Member).
    • When withdrawing Rupiah, the name and destination account must be the same as the Account owner's name.
    • The destination bank account must be active.
    • If accessed through the INDODAX website, Rupiah withdrawal can be done with permission from the Google Authenticator PIN or SMS PIN.
    • If accessed through the INDODAX application, Rupiah withdrawal can be done with the authority of the Google Authenticator PIN or SMS PIN, but if you activate the biometric feature on the INDODAX application, the Rupiah Withdrawal process can be authorized with biometrics.
    • For the Rupiah Withdrawal transaction to be processed, Member must confirm the withdrawal of funds by clicking the withdrawal confirmation link sent to the e-mail after completing the withdrawal data-filling process.

d. Transferring Digital Assets to Another Wallet

The transaction security for transferring digital assets to another wallet is as follows:

• • • INDODAX Member Account must have passed the Know Your Customer (KYC) stage
    • Withdrawal must be submitted by the account owner (verified Member).
    • When withdrawing assets to another wallet, it must be noted that the destination wallet address and the network supported by the destination wallet are correct or in accordance with the network supported by INDODAX as the sending wallet.
    • For some assets that use memos, it is important to ensure that the destination wallet memo is correct.
    • The recipient's address wallet can be stored in the 'address management' feature when withdrawing digital assets.
    • It is possible to register the destination wallet address stored in 'address management' as a whitelisted address, but care must be taken that the destination wallet address or destination wallet memo is correct. The destination wallet address is registered as a whitelisted address with authorization in the form of Two-Factor Authentication (Google Authenticator or SMS PIN) / biometric and OTP e-mail sent to the e-mail registered in the INDODAX Account.
    • Withdrawing crypto assets without registering the destination wallet address as a whitelist address is possible. Authority is also done with Two-Factor Authentication (Google Authenticator or SMS PIN) / biometric, INDODAX Application PIN, and OTP e-mail sent to the e-mail registered in the INDODAX Account.

The inclusion of parties responsible for access in the use, change, and/or disclosure of accounts from third parties due to negligence and/or member error results in the risk borne by the Member, then INDODAX will not provide compensation and/or liability in any form to the Member or any other party for all risks, responsibilities, and demands of any kind that may arise in connection with the negligence/intent/error of the Member in providing information.

G. Withdrawal limit

1. The Member hereby agrees to comply with the withdrawal limits for both Crypto Assets and Rupiah applicable to the Member's Account and INDODAX, which in this case applies the principles of Anti-Money Laundering and Prevention of Financing of Terrorism (APU-PPT) and Proliferation of Weapons of Mass Destruction in accordance with the regulations of the Government of the Republic of Indonesia, is authorized and has the right not to process transactions that have exceeded the daily withdrawal limit of the amount determined by INDODAX.

2. The withdrawal limit resets or returns to 0 (zero) every 00.00 Western Indonesian Time (WIB).

3. The process of approving or rejecting an increase in the daily limit withdrawal limit is absolutely INDODAX's authority with consideration from the audit and Legal Division according to the request, transaction history, source of funds, and the intended use of the transaction and cannot be intervened. Member who are denied a limit increase can only reapply.

H. Downtime

Some of our system operations may experience performance degradation and be temporarily inaccessible to Member in the following cases:

1. Maintenance/Upgrade on some INDODAX Service infrastructure
In order to upgrade/improve infrastructure and your experience in using INDODAX Services for transactions, INDODAX may carry out maintenance and/or upgrade infrastructure at any time. INDODAX will first provide written notification to Members before this maintenance and/or infrastructure upgrade is carried out, including but not limited to email, blogs, and/or INDODAX's official social media.

2. Termination of crypto asset trading (Delisting)
If INDODAX decides to delist crypto assets, whether it is due to INDODAX's own internal decisions, decisions of related developers, or directions from the competent authorities, INDODAX will provide written notification to Member through INDODAX's blog and social media along with settlement steps. The termination of crypto asset trading is carried out under the provisions of the applicable laws and regulations.

COMPLAINT SERVICE

Member complaints here are related to the notification of data breaches and/or if there are problems regarding the ownership of Crypto Assets owned by the Member. In the event of such issues, the following mechanism must be carried out by the Member, among others:

1. Concerning member complaints, the Member has the right to notify INDODAX under the following conditions:

• • • If Member receives spam, all forms of illegal advertisements, and/or electronic mail on behalf of names other than INDODAX that request personal data and/or disturb the comfort of Member;
    • If there is a criminal practice of theft and fraud of Crypto Assets which results in the loss of Crypto Assets in the Member's Account;
    • If there are suspected data breach activities by other parties not described in points a and b above.

2. Member can file a complaint by filling out the complaint form provided by INDODAX. The complaint form can be downloaded directly at https://indodax.com, which we offer, or can be downloaded here;

3. With regard to the practice of misuse of Member data by other parties, which results in spam or skimming practices, the Member is requested to make a complaint with the following mechanism:

• • • As required in point 2, Member can make complaints by filling out the complaint form that we have provided and can send it to e-mail support@indodax.com, Call Center service, and/or the official Live Chat service on the INDODAX website;
    • We will immediately follow up the report by handling the complaint within 3 x 24 (three times twenty-four) hours;
    • If, within this period, the Member does not get service from our party, then the Member can send the complaint form back to the e-mail support@indodax.com and/or make contact through the INDODAX representative office;

4. Concerning the loss of Crypto Assets in the Member's Account as a result of the practice of electronic crime by other parties, the Member can make a complaint with the following mechanism:

• • • As required in point 2, Member can make complaints by filling out the complaint form provided.
    • The report will be handled initially where an account freeze will be carried out by the reported party (the suspected party) who accommodates or takes the Member's Crypto Assets;
    • The admin will forward your complaint report to the Legal Team to process further handling. Further handling is in the form of clarification with the reported party (the alleged party);
    • If this clarification stage is successful when the reported party responds, mediation will be held with the reporting party (in this case, the reporting Member);
    • If the mediation is unsuccessful, it will proceed through a report to the police and/or other Law Enforcement Officials, and the Member will prepare the data requested by INDODAX.
      
      

REPRESENTATIONS AND WARRANTIES

1. All services on the Website do not provide any guarantee or warranty, and INDODAX does not guarantee that the Website will always be accessible at all times.

2. Member declares and guarantees that they will use INDODAX services properly and responsibly and not take actions that are contrary to the laws, laws, and regulations that apply in the territory of the Republic of Indonesia, including but not limited to money laundering, gambling, purchasing illegal goods, terrorism activities, hacking activities and/or other criminal acts.

3. Member represents and warrants that they will not use INDODAX Services in the sale of goods and/or services related to:

• • • Narcotics, materials and/or chemicals for research;
    • Money and anything similar to money, including derivatives;
    • Goods and/or services that violate Intellectual Property Rights;
    • Ammunition, firearms, explosives, sharp weapons in accordance with applicable legal provisions;
    • Goods and/or services that show personal information from unlawful Third Parties;
    • Support for Ponzi schemes and Illegal Investment programs;
    • Goods and/or services related to the purchase of lottery, layaway;
    • Banking-related services located outside the territory of the Republic of Indonesia;
    • Card payment;
    • Credit settlement and/or;
    • Support for organizations banned or prohibited by the government.

4. Member represents and warrants not to use the service for acts that engage in gambling practices and/or other activities that charge entry fees and promise prizes, including but not limited to casino games, sports gambling, businesses that facilitate gambling, and lottery methods.

5. The Member represents and warrants that all data, information, and documents provided by the Member to INDODAX are actual, valid, honest, transparent, complete, and accurate data information and documents. The Member states that they are willing to be prosecuted criminally if INDODAX finds out or obtains information from any party that the data, information, and documents provided by the Member are not valid / not entirely true/false. The Member is willing to update the data/information (profile update) at any time requested by INDODAX, and then all documents that have been provided become the whole property of INDODAX.

6. INDODAX has provided sufficient information and explanations regarding INDODAX services that will be used by Member under the provisions in the SKU, and Member has understood and comprehended and is willing to bear all the consequences that may arise in connection with the use of INDODAX services, including the benefits, risks, and costs inherent in services and services.

7. The Member hereby agrees and authorizes INDODAX to use all data, description, and information obtained by INDODAX regarding the Member, including but not limited to the use of the Member's communication facilities for all other purposes to the extent possible and permitted by applicable laws, including those aimed at marketing INDODAX products or other parties, in collaboration with INDODAX. For the use of data that requires the approval of other parties, the Member hereby declares that it has obtained written approval from any third party for the use of such data, information, and information. Therefore, the Member guarantees and agrees that INDODAX will not provide compensation and/or liability in any form to the Member or any party for all risks, losses, claims, and/or responsibilities that may arise in the future in connection with the use of data, description, and information that has obtained such written approval by INDODAX.

8. Member represents and warrants that transactions carried out using INDODAX services are transactions that do not violate the applicable laws and regulations and the provisions regarding acceptance of transaction implementation as stipulated in the SKU. Suppose INDODAX finds indications of the implementation of transactions that are not under the requirements of the applicable laws and regulations and/or the provisions regarding the acceptance of transaction implementation as stipulated in the SKU. In that case, INDODAX has the full right to close the Member's Account by deactivating the INDODAX service to the Member. The Member hereby agrees that INDODAX will not provide compensation and or liability in any form to the Member or any party for any claims and/or demands arising in connection with the deactivation of the INDODAX service to the Member.

9. Member represents and warrants that the risk of using Third Party services, products, and promotions with Member (if any) is borne by Member, and Member states that INDODAX is not responsible for the services and performance of Third Party services.

10. The Member is entirely responsible and agrees that INDODAX will not provide compensation and or liability in any form to the Member or any party for any losses and or claims and or demands that arise or may be experienced by INDODAX as a result of the Member's negligence or failure to carry out transactions.

11. The Member hereby warrants to INDODAX that the Member and all of its employees and or other parties who cooperate with the Member will not reproduce and or make, give, rent, sell, move, transfer, and/or transfer INDODAX services either partially or entirely to other parties for any reason, including but not limited to misuse of indodax.com services to carry out transactions other than those specified in the SKU with any intention, including but not limited to crime/fraud/fraud. If the Member violates this provision, then the Member must be responsible for all losses, claims, and or lawsuits arising from the violation and hereby agrees that INDODAX will not provide compensation and or liability in any form to the Member or any party for all claims and or demands and or lawsuits arising from the violation.
12. As a form of commitment and our compliance with Law Number 27 of 2022 concerning Personal Data Protection, together with these General Terms and Conditions (SKU), INDODAX guarantees that:

• • • INDODAX continues to always be committed and guarantee the personal data of our Member and will take firm action if other parties have used our member information data;
    • INDODAX guarantees cross-border transfer of Crypto Assets;
    • INDODAX always applies protocols and mechanisms in the form of requests for permission and approval or notification to Member for all forms of data processing in the marketplace in making deposits, withdrawals and/or updating data.
      
      

LIMITATIONS OF LIABILITY

Member agrees to bear any risk, loss, or consequence suffered by Member caused by, among others:
1. Damage, delay, loss, or misdelivery of orders and communications electronically caused by the Member;

2. INDODAX Account Report or notification of the use of INDODAX services sent to the Member is received or read or misused by parties who are not authorized to INDODAX Account;

3. The Account Password and/or Password is known by another person/party through the fault of the Member,

• • • The Member understands and agrees that the Member will use the INDODAX Account and services for transactions that do not conflict with the provisions of laws and regulations and/or INDODAX's applicable internal policies and/or other regulations that apply nationally and internationally related to the implementation of these transactions either directly or indirectly. INDODAX will not provide compensation and/or liability in any form to the Member or any party for any claims and/or demands and/or losses arising in connection with the use of INDODAX services by Member for transactions categorized as suspicious transactions and/or transactions prohibited by the provisions of laws and regulations and/or INDODAX's internal policies that apply and/or other regulations that apply both nationally and internationally related to transaction activities carried out by Member directly or indirectly.
    • In conducting transactions using INDODAX services, the Member understands and agrees that certain sanctions imposed by the government, including the governments of other countries and/or other authorized agencies, are against several countries, entities, and individuals. Referring to this, INDODAX reserves the right not to carry out / process transactions that violate the sanction provisions, and the authorized agency may require disclosure of related information. INDODAX is not responsible if indodax.com or other parties fail or delay the implementation of transactions or disclosure of information due to direct or indirect violations of the sanction provisions.
      
      

REJECTION OF GUARANTEE

INDODAX always strives to maintain safe, convenient, and well-functioning Services, but we cannot guarantee continuous operation or that access to our Services is always perfect. It is possible that information and data on the INDODAX website may not be available in real time.
1. INDODAX does not guarantee that the results obtained from using the services will be accurate or reliable

2. Member agrees that Member uses the INDODAX Services at Member's own risk and that the INDODAX Services are provided to Member on an "AS IS" and "AS AVAILABLE" basis.

3. To the maximum extent permitted by applicable law, INDODAX (including the Holding Company, Board of Directors, and employees) shall not be liable, and the Member agrees not to hold INDODAX liable for any damage or loss (including but not limited to loss of money, reputation, profits or other intangible losses) directly or indirectly caused by the following:

• • • Member's inability to use INDODAX's services is at their own risk.
    • Loss of use, loss of profits, loss of revenue, loss of data, loss of goodwill, or failure to realize expected savings, for any case directly or indirectly.
    • Any indirect, incidental, special, or consequential damages arising out of or in connection with the use or inability to use INDODAX's Website or services, including, but not limited to, damages caused thereby, even if INDODAX has been advised of the possibility of such damages.
    • Any loss caused by the Member's negligence, including but not limited to negligent login through a third-party device and/or failure to maintain the confidentiality of the device used for login.
    • The condition and quality of the tradable products or Crypto Assets.
    • Infringement of Intellectual Property Rights.
    • Disputes between Member.
    • Defamation of another party.
    • Any misuse of Assets purchased by Member.
    • Loss due to unauthorized payment to any party other than INDODAX's Authorized Account, which uses INDODAX's name or negligence in writing account and/or different information and/or negligence of the bank.
    • Fitness for a particular purpose, durability, title, and non-infringement.
    • Viruses or other malware (bots, scripts, automation tools) obtained by accessing or connecting to INDODAX services.
    • Skimming or hacking processes cause the loss of Member to the INDODAX Services.
    • Interruptions, bugs, errors, or inaccuracies in the INDODAX Services.
    • Damage to your hardware from the use of any INDODAX Service.
    • Enforcement action was taken in relation to the Member's Account.
    • Any hacking performed by a third party on the Member's Account

4. The Member acknowledges and agrees that the Member's only right for service problems or dissatisfaction is to stop using the service

RESTRICTION

Without reducing the intent of the provisions regarding the restrictions contained in the SKU, Member are restricted from doing the following things:
1. Member are not allowed to take actions that can result in losses for INDODAX and/or that are contrary to the SKU and applicable laws and regulations.

2. Suppose Member violates one or more of the provisions in this provision. In that case, the Member will be fully responsible and hereby agrees that for such violation, INDODAX reserves the right to limit the features of the use of INDODAX service, and the Member acknowledges and agrees that INDODAX will not provide compensation and or liabilTity in any form to the Member or any party for any risks or consequences arising from the limitation of the use of such services service. The Member is further obliged to pay compensation to INDODAX in the amount of the loss that INDODAX may suffer for such violation. The Member hereby authorizes INDODAX to debit the Member's Account to pay such compensation. Suppose the funds in the Member's Account are unavailable or insufficient. In that case, the Member is obliged to return all such funds in cash to INDODAX no later than 7 (seven) working days from the date INDODAX submits the claim.

CONFIDENTIALITY

During the cooperation with INDODAX and at all times thereafter, then:
1. Any information and/or data provided by INDODAX to the Member and/or data obtained by the Member as the implementation of the SKU, whether given or submitted orally, in writing, graphically, or submitted through electronic media or information and or data in other forms during the conversation or other work is confidential (hereinafter referred to as "Confidential Information").

2. Member agrees that he/she shall at all times keep confidential the confidential information obtained as a result of the cooperation to any person or shall not use it for the benefit of the Member or the benefit of any other party without first obtaining written approval from the authorized officer of INDODAX or any other authorized party under the provisions of applicable law.

3. Suppose Member violates the provisions referred to in numbers 1 and 2 of this confidentiality provision. In that case, all losses, claims, and or lawsuits suffered by INDODAX are the sole responsibility of the Member. At the first request of INDODAX, the Member is obliged to settle it under the provisions of applicable laws and regulations and provide compensation that may arise from the violation to INDODAX. The Member hereby agrees that INDODAX will not provide compensation and/or liability in any form to the Member or any party for any claims and or lawsuits that may arise in the future in connection with such violation.

4. The obligation to keep confidential information, as referred to in numbers 1 and 2 of the provisions regarding confidentiality, shall not apply if:

• • • The confidential information becomes available to the general public.
    • The confidential information must be disclosed to comply with a court order or other authorized government institution.
    • Confidentiality of information is provided under applicable law.

5. Member further agrees to make every effort and take every necessary action to prevent third parties from gaining access to or causing disclosure of confidential information.

6. If the cooperation has ended, the Member agrees that the obligation to keep confidential documents and materials that constitute confidential information as stipulated in this provision shall remain in effect.

7. You can also read and examine our commitment to safeguarding our Member's Personal Data in the Privacy Policy on the following page:
https://help.indodax.com/hc/id/articles/19751527469721-Kebijakan-Privasi

 

INTELLECTUAL PROPERTY RIGHTS

1. Member acknowledges and agrees that INDODAX holds the ownership rights to the services, software, technology tools, content, Website, and other materials, including Intellectual Property Rights associated with INDODAX's facilities.

2. Member are only allowed to view, print, and/or download copies of materials from the Website for personal and non-commercial use. All commercial use must be approved by INDODAX. Any commercial activity without INDODAX's approval shall be construed as a violation of INDODAX's Intellectual Property Rights and shall result in the termination of the Member's INDODAX Account

 

DEFAULT

1. Member agrees that the following matters or events define Default:

• • • Default.
    • The Member neglects to carry out an obligation or violates a provision in the SKU.
    • Incorrect Statement.
    • If it turns out that a statement or guarantee given by the Member in the SKU - is incorrect or does not match the reality.

2. In the event of an occurrence of Default based on number 1 of this Default provision by the Member, INDODAX may choose whether to continue or close the Member's Account. If INDODAX wishes to close the Member's Account, the Member shall be notified of such Intention within a reasonable time, according to INDODAX.

3. In the event of an occurrence of Default by the Member as referred to, Indodax.com shall have the right to immediately deactivate the Member's INDODAX Account without prior notice to the Member, and the Member hereby agrees that INDODAX shall not provide compensation and or liability of any kind to the Member or any party for any claims and or lawsuits and or claims and or requests for compensation from any party that may arise in connection with the occurrence of such Default

 

TAX

Taxes on Crypto Assets Trading Activities are borne by the respective actors involved, in this case, the Member and INDODAX. We encourage Member to consult their tax advisors, and INDODAX does not bear any taxes for Member unless otherwise specified in these Terms and Conditions.
Based on the Minister of Finance Regulation (PMK) Number 68 of 2022, both the buyer/receiver of Crypto Assets trading is subject to Value Added Tax (PPN) with the following details:

• • • 0.11 percent of the per-transaction value of Crypto Assets is charged to Member

Meanwhile, Member as sellers/deliverers of Crypto Assets are subject to Income Tax (PPh) from Crypto Assets trading with the following details:

• • • 0.1 percent of the per-transaction value of Crypto Assets is charged to the Member

The amount of tax will be adjusted to the provisions of the applicable laws and regulations.

 

FORCE MAJEURE

1. Force Majeure is defined as events that occur beyond the ability and power of INDODAX to affect the implementation of transactions, including but not limited to:

• • • Earthquakes, hurricanes, floods, landslides, volcanic eruptions, and other natural disasters;
    • War, demonstrations, riots, terrorism, sabotage, embargoes and mass strikes;
    • Economic policies of the Government that directly affect;

2. As long as INDODAX has carried out all of its obligations under the applicable laws and regulations in connection with the occurrence of Force Majeure, INDODAX will not provide compensation and/or liability in any form to Member or any other party for all risks, liabilities, and claims that may arise in connection with delays or non-performance of obligations due to Force Majeure.

 

NOTIFICATION

1. Member agrees to communicate with INDODAX in electronic format and agrees that all terms, conditions, agreements, notices, disclosures, or any other form of communication provided by INDODAX to Member electronically shall be deemed to be in writing.

2.  Member agrees to receive e-mails from INDODAX. E-mails may contain information about the Member Account, transactions, systems, promotions, etc.

DISPUTE RESOLUTION

Any conflict, disagreement, or difference of opinion (hereinafter referred to as "Dispute") arising in connection with the implementation of the cooperation will be resolved in the following manner:
1. To the extent possible, deliberation will resolve every dispute to reach a consensus within 30 (thirty) working days.

2. Any Dispute that cannot be resolved by deliberation will be resolved through the Commodity Futures Trading Arbitration Board (BAKTI) or the South Jakarta District Court.

LEGAL DOMICILE

The SKU is made, interpreted, and enforced by the laws of the Republic of Indonesia. Indodax.com and its Member have agreed to choose a common and unchanged legal residence at the Registrar's Office of the South Jakarta District Court.

 

THE IMPLEMENTATION OF AML-CFT AND PROLIFERATION OF MASS DESTRUCTIONWEAPONS

The implementation of the Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) program regime in Indonesia is closely related to the critical role of all parties, one of which is for many new industries, especially the Crypto Assets Trading Industry. Given that this Industry is one of Indonesia's latest forms of Commodity Physical Traders, it also has the potential as a medium of money laundering and financing terrorism.

Therefore, it has become one part of PT Indodax Nasional Indonesia's commitment as one of the Crypto Assets Trading Activities actors in implementing the AML-CFT program based on the provisions of applicable laws and regulations and referring to international standards made by FATF to minimize all risks of becoming a medium of money laundering and financing terrorism.

To improve the effectiveness of the implementation of the AML-CFT program, PT Indodax Nasional Indonesia has made improvements in the implementation of AML-CFT policies and procedures based on 5 (five) Pillars of AML-CFT Program Implementation, as follows:

1. Active Supervision of INDODAX's Board of Directors and Commissioners related to the implementation of AML-CFT

INDODAX's Board of Directors and Board of Commissioners conduct active supervision based on routine reports related to the implementation of the AML-CFT Program submitted, including providing approval of the AML-CFT Program Policies and Procedures.

To implement the function and active role of monitoring, the Board of Directors and Board of Commissioners, together with the Legal Division - Transaction Monitoring Unit, have carried out the following initiatives.

• • Routinely conduct discussions related to the implementation of AML-CFT program provisions, both during Board of Directors meetings, Board of Commissioners Meetings, Risk Management Committee, and Risk Monitoring Committee;
  • Proposing changes, developments, and initiatives related to the AML-CFT Program system and policies to the Board of Directors and Board of Commissioners under applicable regulations to support the implementation of the program and best practices, which currently have created system-integrated transaction monitoring tools,
  • Proposing parameter or threshold updates as well as monitoring scenarios in the Anti Money Laundry (AML) system to the Board of Directors Compliance and Legal Division Transaction Monitoring Unit to ensure compliance with the mode of money laundering and terrorism financing;
  • Submitting the draft approval of the Suspicious Transaction Report (STR) to the Compliance Director before it is sent to the Financial Transaction Reporting and Analysis Center (PPATK), including submitting approval for the response of instruction letters from Law Enforcement Officials and the Financial Transaction Reporting and Analysis Center (PPATK) in the context of implementing the AML-CFT Program;

2. INDODAX's AML-CFT Policies and Procedures

INDODAX continuously adjusts its policies and procedures to comply with the latest laws and regulations. The development of policies and procedures will be carried out on an ongoing basis with the latest regulations from the Regulators, including the Commodity Futures Trading Supervisory Agency (BAPPEBTI), the Financial Transaction Reports and Analysis Center (PPATK) and/or best practices, such as:

• • Issuing several internal provisions supporting the implementation of the AML/CFT program and updating the regulatory adjustments contained in the Anti Money Laundry (AML) Standard Operating Procedure (SOP), which in the SOP has included the implementation of the AML/CFT program, such as:

a. Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is an activity in the form of checking the personal information provided by the customer in the registration/account creation process to be validated by INDODAX to get complete platform services. INDODAX will reject the customer's account creation application if there are data discrepancies.

b. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is a more in-depth CDD action applied to customers classified as high risk, including high-risk customers, Politically Exposed Persons (PEP), and customers with indications of possible money laundering and terrorism financing. In the EDD activities, customer profiles and transactions are monitored to ensure transactions are in accordance with the customer's profile, characteristics, and/or transaction patterns.

c. Reporting of Suspicious Financial Transaction Report ("LTKM")
Following up on the results of EDD, if an account is found with a profile mismatch / indicated to carry out suspicious transactions leading to AML-CFT, INDODAX will proactively report LTKM to PPATK through the goAML application.

d. Matching the similarity of the Service User's profile with the watchlist of suspected Financing of Terrorism on the Suspected Financing of Terrorism Information System Application (SIPENDAR).
Terrorism on the Suspected Financing of Terrorism Information System Application (SIPENDAR). INDODAX has a Suspected Financing of Terrorism Information System Application ("SIPENDAR") and has performed routine maintenance when PPATK sends watchlist data to the SIPENDAR Application.

• • Conduct reviews and provide recommendations on policies and procedures of other work units so that they are in line with the implementation of AML-CFT program policies;
  • Provide recommendations and input as a follow-up to group discussions or questions found by the INDODAX AML-CFT Officer, both regarding the implementation of AML-CFT program procedures and related to handling cases of money laundering and terrorism financing.

3. Internal Control

INDODAX's Legal Division-Transaction Monitoring Unit monitors IDR transactions and Crypto Assets for Member or Crypto Assets customers suspected of violating AML-CFT, whether discovered through internal company investigations or requests from Law Enforcement Officers and Regulators.

In monitoring Rupiah transactions and Crypto Assets against Member or customers of Crypto Assets, INDODAX has created/has systemically integrated transaction monitoring tools that are used to detect indications of transaction patterns that are considered suspicious, such as activity spikes in transaction frequency, spikes in amount; and so on with parameters compiled in such a way by the Company based on the results of observations made internally with several Risk Factor parameters, namely:

1. Total Daily Withdraw Fiat
2. Total Daily Withdraw Coin
3. Total Daily Frequency Withdraw Fiat
4. Total Daily Frequency Withdraw Coin
5. Total Daily Frequency Deposit Fiat
6. Total Daily Frequency Deposit Coin
7. Total Daily Deposit Fiat
8. Total Daily Deposit Coin

If a significant transaction pattern is found that experiences a spike in transaction frequency, a spike in amount, and so on, INDODAX will proactively report LTKM to PPATK through the Go-AML website. In addition, monitoring of transaction fairness of INDODAX Member is carried out by the Legal Division - Transaction Monitoring Unit with reference to the following methods:

1. Centralized transaction monitoring of the AML Work Unit through the Anti Money Laundering (AML) application automation system or Go-AML;

2. Implementing AML/CFT Program related to Correspondent Banking activities as follows:

• • • Updating the data of Correspondent Crypto Assets Customers;
    • Responding to requests for clarification on Crypto Assets Customers suspected of fund transfer activities and

3. Acting cooperatively with Regulators and Apparatus by profiling and providing transaction history of Crypto Assets Customers related to suspicious transaction fund flows suspected of being the proceeds of Money Laundering or Proliferation of Weapons of Mass Destruction.

4. Management Information System and Reporting

A management information system is developed to facilitate the Legal Division Transaction Monitoring Unit as the AML-CFT Unit to monitor, identify, analyze, and provide reports with risk-based transaction characteristics carried out by Crypto Assets Customers.

The points of development of the management information system supporting the AML-CFT program include:

• • • Identify/Risk Identification
      Identifying the suitability of the verified member account profile of PT Indodax Nasional Indonesia with the application system, such as the Face Recognition feature during the KYC process.
    • Control and Assessment
      As previously mentioned, INDODAX has created/has a system-integrated transaction monitoring tool that is used to detect indications of IDR or Rupiah and Crypto Assets transaction patterns that enter or exit the INDODAX System, such as activity spikes in transaction frequency, spikes in amount, and so on with parameters compiled in such a way by INDODAX based on the results of observations made internally with several Risk Factor parameters, namely:

1. Total Daily Withdraw Fiat

2. Total Daily Withdraw Coin

3. Total Daily Frequency Withdraw Fiat

4. Total Daily Frequency Withdraw Coin

5. Total Daily Frequency Deposit Fiat

6. Total Daily Frequency Deposit Coin

7. Total Daily Deposit Fiat

8. Total Daily Deposit Coin

Excluding the above parameters, the Legal-Unit Transaction Monitoring Division also conducts detailed monitoring and assessment of customer transactions, whether they are per customer profile information. EDD is carried out at this stage to obtain more in-depth verification results before submitting LTKM reporting to the Compliance Director.

• • • Risk Mitigation
      Suppose the Transaction Monitoring Unit finds a customer account that is indicated to have committed AML-CFT Actions based on internal monitoring and assessment results. In that case, the Transaction Monitoring Unit will immediately record the analysis results on the working paper for further approval of LTKM reporting to the Compliance Director. LTKM reporting will be immediately carried out to PPATK via goAML if approved.

5. Human Resources and Training

There is a need for a training program for all employees in the AML-CFT field to produce human resources with adequate expertise and knowledge in carrying out their duties. In this case, INDODAX, especially the HR Division, is obliged to pay attention to the following two points:

• • • Screening procedures at the time of recruitment of prospective employees;
      Based on User requests for new or replacement employees, HR will upload job advertisements to the Job Portal media. The HR Division will screen CVs / Application Letters based on the requested qualification requirements to be processed to the Technical Test / Psychological Test and Interview stages.
    • Introduction and monitoring of employee profiles;
      After the prospective employee follows a series of screening processes, the HR Division conducts a background check, starting with personal data, education, and the last job of the prospective employee.

Methods that can be carried out as a form of training can be done as follows:

• • • Training or socialization by webinar conducted between the HRGA division and the Legal Division regarding awareness of the general application of the AML-CFT Program to INDODAX employees;
    • Further training from the Regulator, either from BAPPEBTI or PPATK, is needed to train the Legal Division as the designated AML Unit to update information from what has previously been running.

OTHER

1. This SKU is subject to and enforced based on Law Number 8 of 2010 concerning the Countermeasure and Eradication of Money Laundering Crime, Regulation of the Head of PPATK Number PER-02/1.02/PPATK/02/2014, PER-02/1.02/PPATK/02/15, and Regulation of PPATK Number 1 of 2021. Following up on those matters, all transactions classified as suspicious financial transactions with a nominal value above IDR 500,000,000, - (five hundred million Rupiah) within 1 (one) working day require reporting these transactions to PPATK. All provisions in the Civil Code and other related laws and regulations shall apply for matters that have not been regulated in the SKU. Suppose INDODAX makes changes to the contents of this SKU. In that case, INDODAX will notify the Member of the changes under the applicable laws and regulations through notification media deemed suitable and capable by INDODAX, and then the Member will comply with the changes to the SKU. Modifications to each attachment of the SKU will be agreed upon and subsequently constitute an integral part of the SKU;

2. If Member takes actions outside the provisions of the SKU, then the Member will be fully responsible and hereby agrees that INDODAX will not provide compensation and or liability in any form to the Member or any party for all demands and or lawsuits and or claims filed by other parties in connection with the actions taken by the Member;

3. Member must comply with all the requirements stated in the SKU. Member's negligence in complying with or implementing the contents of the SKU on one or more occasions will not eliminate the Member's obligation to continue to satisfy all the requirements contained in the SKU;

4. Questions about the Terms and Conditions or other matters are made through support@Indodax.com.

5. Member understands and agrees that this SKU constitutes an agreement in electronic form and the Member's action of pressing the 'register' button when opening an Account or the 'login' button when accessing the Member's Account constitutes the Member's active agreement to bind themselves in an agreement with INDODAX so that the validity of these Terms of Use and Privacy Notice is valid and legally binding and continues to apply throughout the use of the Application and Services by the Member.

6. Member will not submit any claims or objections to the validity of the SKU or Privacy Notice made in electronic form.

7. Member cannot transfer their rights to other Parties under these SKU without prior written consent from INDODAX. However, INDODAX may transfer INDODAX's rights under this SKU at any time to other parties without the need to obtain prior approval from or provide prior notice to the Member.

8. If a Member does not comply with or violate this SKU's provisions, and INDODAX does not take direct action, it does not mean that INDODAX waives INDODAX's right to take the necessary action later.

9. This SKU remains in effect even after a temporary freeze, permanent freeze, deletion of the Application, or after the termination of this agreement between the Member and INDODAX.

10. If one of the provisions of these SKU is unenforceable, it will not affect the other provisions.

11. INDODAX makes these Terms of Use in Indonesian, English, and Chinese. The Indonesian language will interpret any discrepancies. INDODAX is not responsible for any form of misinterpretation, interpretation, definition, understanding, meaning, or opinion that the Member has believed

 

THESE GENERAL TERMS AND CONDITIONS AND RISKS OF TRADE OF MEMBER OF INDODAX.COM HAVE BEEN ADJUSTED TO THE PROVISIONS OF APPLICABLE LAWS AND REGULATIONS.