The User is required to read the following terms and conditions (“Flock’s T&C”) before using or accessing the Site/Application of PT Inklusi Finansial Indonesia (“Flock”). The terms and conditions of the use of site or application contained in this Flock’s site or application constitutes an agreement between the User and PT Inklusi Finansial Indonesia, along with all of its subsidiaries and/or affiliates, whether presently or in the future. Flock’s T&C may be revised from time to time without any prior notice. The User is advised to regularly visit Flock’s Site/Application to know any such revision.

This Flock’s T&C governs the User’s access to and use of Flock’s Site/Application, contents, products and services provided and/or facilitated by Flock, as well as the use of services, facilities and/or products available on Flock’s Site/Application.  

By continuing to access or use or registering with Flock’s Site/Application, the User acknowledges and agrees that the User has carefully read, understood, comprehended, observed, accepted and approved the entire Flock’s T&C which will constitute a binding agreement between the User and Us. We reserve the right to terminate or restrict the User’s access to Flock’s Site/Application at any time without prior notice.

1. The access and use of Flock’s Site/Application, including the services available on Flock’s Site/Application are subject to this Flock’s T&C. 
2. In order to be able to access and use Flock’s Site/Application, a User must have a registered account in Flock’s system.
3. User hereby grants approval to Flock to store, share, forward User information and/or data related to the use of the Flock’s Site/Application.
4. Flock acts only as the management and owner of Flock’s Site/Application.
5. Flock does not guarantee and is not responsible for all profits and losses of the Users resulting from the execution of copy strategy and Crypto Assets transaction on the products available and carried out on Flock’s Site/Application. 
6. By performing a Crypto Assets transaction copy strategy on Flock’s Site/Application as a provider of Crypto Assets trading facilities, the User is consciously willing to take full responsibility of all actions taken, and releases Flock, including its subsidiaries, affiliates, shareholders, board of directors, officials, employees, and Pro Traders, fully from all claims, losses, liabilities, payments or any costs arising suffered by Flock or filed against Flock whether directly or indirectly, including attorney fees and case fees, related to the execution or non-execution of the User’s transaction instructions.
7. Pro Trader’s recommendation is an illustration of the crypto copy strategy product executed through Flock’s Site/Application, the User is consciously willing to take full responsibility of all actions taken, including but not limited to the Pro Trader’s strategy selected for copy strategy, the period, the amount of funds, or the risk level of copy strategy. The User also releases Flock, including its subsidiaries, affiliates, shareholders, board of directors, officials, employees fully from all claims, losses, liabilities, payments or any costs arising and/or suffered by the User and/or suffered by Flock whether directly or indirectly, including but not limited to attorney fees and case fees, related to the execution or non-execution of the User’s transaction instructions.
8. Flock as a platform that provides copy strategy service in Flock’s Site/Application are responsible for the User’s smooth transaction process which includes the registration, buying and selling processes for these to be well executed and conveyed.
9. The User has assessed all Pro Traders’ strategy options offered on Flock’s Site/Application, and therefore, Flock is not responsible for any Pro Trader’s strategy selected for copy strategy.
10. Crypto Assets trading is a risky activity because prices may significantly change from time to time. Flock is not responsible for any changes or fluctuation of Crypto Assets exchange rate, risk of losses from purchasing, selling, holding, investing in, and trading any Crypto Assets. These risks are fully and purely assumed by the User.
11. Insofar as they are not contradictory to this Flock’s T&C, all terms and conditions applicable and set out on Flock’s Site/Application (including arrangement on service rate/fee/profit sharing) are fully effective, and the User is hereby subject to those terms and conditions.
12. We reserve the right to, from time to time, make a revision, addition and/or modification to all or a part of this Flock’s T&C. If You use Flock’s Site/Application consistently and continuously after such revision, addition and/or modification of all or part of Flock’s T&C, such action will be considered a form of Your approval to such revision, addition and/or modification. If You do not agree to such revision, addition and/or modification, You are asked to stop accessing and/or using Flock’s Site/Application.
13. The User may access and use Flock’s Site/Application after providing all User’s identity documents required by the applicable regulations. The User hereby declares and states to have read, completely understood, comprehended, and approved Flock’s T&C. By approving this Flock’s T&C, the User is subject to and bound by Flock’s T&C, the Privacy Policy, and any amendment or addition thereto, for performance purposes.
14. Flock reserves the right to reject an application for account creation if:
    • Identity supporting documents provided by the User are incomplete or false; and/or
    • The User committed an action which is contradictory to the required procedures in creating an account under Flock’s T&C.
15. Flock reserves the right to  take necessary actions, including but not limited to, cancelling transactions, withholding funds, restricting and terminating the User’s access to the use of Flock’s Site/Application for Crypto Assets transactions and copy strategy services available on Flock’s Site/Application at any time with or without prior notice, for reasons including as a result of system maintenance and repair process, the User’s alleged breach or unfair activity against the terms provided for in this Flock’s T&C, or another agreement between Flock and the User, or a discovery of other deviations regarding the use of Flock balance account or Crypto Assets transactions and copy strategy committed by the User.
16. The User agrees that the User’s mistake and/or negligence in using the features of Flock’s Site/Application is entirely the User’s responsibility and risk. Information provided through Flock’s Site/Application does not constitute any advice, invitation, recommendation, or directive from Flock to the User to buy, sell, or withhold from buying or selling any certain crypto products.
17. The User represents and warrants that the User will not use Flock’s Site/Application services for any action that constitutes a criminal practice, money laundering crime, terrorism, proliferation of massive destruction weapon, gambling and/or other activities that charges entrance fee and promises gifts, including but not limited to casino games, gambling on sports, businesses that facilitates gambling and lottery.
18. The User represents and warrants that the User will use the services of Flock’s Site/Application properly and responsibly without committing any illegal action that contradicts the laws and regulations applicable within the territory of the Republic of Indonesia.
19. The User hereby releases Flock and its subsidiaries, affiliates, shareholders, board of directors, officials, employees from all forms of responsibility for any damages that might occur and/or losses that might arise out of Crypto Assets transactions and copy strategy resulting, whether directly or indirectly, from all disruptions, erasure, mistakes, delay in operation or transmission, computer virus, communication network disruption, theft or damage, illegal obtainment, alteration or utilization of information outside the electronic system provided by Flock.
20. In addition to this Flock’s T&C, the User will be bound by other terms and conditions on Crypto Assets transaction and copy strategy activities stipulated for each Pro Trader’s strategy on Flock’s Site/Application.

1. The User hereby grants approval and power to Flock to provide information on the User’s data and information when required/needed by the following parties:

• • Business partners or other third parties including other applications or sites that have integrated their API or services, or business partners with whom Flock is cooperating to administer the promotions or special services available on Flock’s Site/Application or Sites/Applications outside Flock’s Site/Application, such as account creation, online Crypto Assets transaction, and other necessary personal data processing;
  • Third parties such as vendors, consultants, or other similar service providers in the context of Flock’s operational activities and partnership with business partners or other third parties, including to improve and maintain Flock’s services quality.
  • The relevant government agencies under the laws and regulations applicable in the Republic of Indonesia which require the information on User;
  • Flock’s Affiliated Company with regard to transaction access and/or request made by the User for each Crypto Assets transaction available on Flock’s Site/Application.

2. The User hereby consents to and is committed not to take any action that might render Flock unable to provide information as referred to in point 1 above. For said purposes, the User hereby releases Flock from all damages and legal claims that might be suffered by the User as a result of the User’s information being provided to the above-mentioned parties by Flock.
3. The consent and power granted by the User to Flock as referred to in point 1 above are irrevocable insofar as the User continues to use the features or services available on Flock’s Site/Application, which Flock may lawfully perform without the need of any additional approval letters and/or separate power of attorney from the User.
4. The terms regarding the collection, storing, processing, utilizing and sharing of the User’s personal data, such as name, e-mail address and mobile phone number that the User provided when the User open and register for a Flock account are available on the Privacy Policy, which forms an inseparable part of this Flock’s T&C.

VI. Termination of Access to Crypto Assets Transaction and Copy Strategy Activities

1. Flock reserves the right to terminate access to Crypto Assets transaction and/or copy strategy activities, in part and/or in whole, temporarily or permanently, upon prior notice to the User concerning such termination, without any obligation to obtain prior approval from the User, to the User and to other parties.
2. Flock may suspend and/or terminate access to Crypto Assets transaction and/or copy strategy activities if:
   • The User asks Flock customer service/call center to terminate access to Crypto Assets transaction service;
   • The User closes the registered account in Flock’s system;
   • Flock is complying with the provision of the applicable laws and regulations;
   • There is an indication that the User is making unusual transactions, conducting fraudulent activities and/or crime, committing money laundering and/or terrorism funding crimes; and/or
   • The User refuses to perform data update as requested by Flock.
3. For reactivation of access to Crypto Assets transaction and/or copy strategy activities, the User must submit an application to reactivate Crypto Assets transaction and/or copy strategy activities through the customer service/call center if the access to Crypto Assets transaction and/or copy strategy activities was suspended.
4. If access to Crypto Assets transaction and/or copy strategy activities was terminated, You may perform a re-registration process. For Your information, Flock has the right to reject the registration of a User in accordance with the provisions of section IV.

VII. Withdrawal

1. The User may withdraw the User’s funds from Flock balance into a personal bank account in the name of the User.
2. The User hereby agrees to comply with the withdrawal limit of the User’s fund in Flock balance applicable to the User, and Flock in this case will apply the principles of Anti-Money Laundering (AML) in accordance with the provisions of the applicable laws and regulations and is granted the power and right to refrain from processing fund withdrawal that exceeds the withdrawal daily limit which amount is as prescribed by Flock.

VIII. Indemnification

1. Flock is not responsible for all damages, losses, claims, or actions suffered by the User which might arise as a result of incomplete information from the User or as a result of non-execution of the User’s instruction. This includes cancellation of, changes to the instructions (for instructions which have not been executed) given to the Pro Trader through Flock’s Site/Application, unless such damages occur due to intentional mistakes and negligence of the Pro Trader and/or Flock as a service provider for Crypto Assets transactions and/or copy strategy activities.
2. The User is consciously willing to take full responsibility of all actions taken, and releases Flock and its subsidiaries, affiliates, shareholders, board of directors, officials, employees and licensors fully from all claims, losses, liabilities, payments or any costs arising suffered by the User whether directly or indirectly, related to the execution or non-execution of the User’s instructions, including attorney fees and case fees.

IX. Costs

The User is fully responsible for all costs, claims, damages, losses or other liabilities arising from and suffered by the User due to the User’s inability or mistake in using Crypto Assets transaction and/or copy strategy service or those arising as a result of a disrupted access to Crypto Assets transaction and/or copy strategy service.

X. Intellectual Property Rights

1. The User declares and approves Flock as the holder of proprietary rights to services, software, technologies and contents, sites, and other things included in the Intellectual Property Rights with regard to the facilities available on Flock’s Site/Application.
2. The User is allowed only to view, print and/or download a material copy from Flock’s Site/Application for personal and non-commercial use. Flock’s written permission must be obtained prior to any commercial use. Any commercial activities without Flock’s permission is considered an infringement of Flock’s Intellectual Property Rights and may result in the termination of the User’s Flock account and/or legal proceedings in accordance with the provisions of the applicable laws and regulations.

XI. Force Majeure

Flock is not liable for any delay or delayed fulfillment of obligation under Flock’s T&C, that is caused by a force majeure or other causes beyond Flock’s capability or power, insofar as a written notice on such matter is sent to the User within no more than 7×24 (seven times twenty-four) hours following the occurrence of said force majeure. Force majeure in these terms and conditions, among other things, includes but not limited to, events of fire, natural disaster (for example earthquake, flood, typhoon, lightning), mass strike, civil commotion, war, changes in laws and regulations, and economic, financial, and capital market conditions, Flock’s transaction system damage, restrictions applied by the capital market authority, commodity forward trading supervisor, and stock exchanges as well as disrupted clearing trading system and transaction settlement.

1. In the event the User passes away, the heir or the party legally authorized to represent the User, must submit a notice to Flock concerning the lawful heir appointed in the event Crypto Assets owned by the User under Flock is sold, by submitting the death certificate, legal heir certificate, deed of testament, and other documents which Flock considers necessary to find out the heir(s) who have the right to the Crypto Assets owned by the late User.
2. Upon handing over the Crypto Assets owned by the late User to the heir(s) or the testament executor in accordance with the provisions of the applicable laws and regulations as referred to in the legal heir certificate or the testament or other documents, Flock will close the account in the name of the User, and Flock will thereby be released from any and all actions, liabilities, and/or claims in any form whatsoever with regard to the handing over of the Crypto Assets owned by said User.

XIII. Marketing and Promotion

Flock may send direct marketing, advertisement, and promotional communications to the User through push-notification application, messages through Flock’s Site/Application, postal service, phone call, Short Messaging Services (SMS), social media, and e-mail if the User has agreed to receive promotional and marketing materials from Flock.

XIV. Miscellaneous

1. Miscellaneous and Amendment
   Matters which have not been provided for under this Flock’s T&C or matters which need to be altered, added, or replaced in this Flock’s T&C, will be provided for by Flock in accordance with Flock’s internal provisions and the provisions of the applicable laws and regulations.
2. Authority to Sign
   The User hereby represents and warrants that the User and/or the party appointed or authorized to sign the document or to provide approval, has the right and authority to enter into, sign, and approve account opening in Flock’s system, and therefore bound by this Flock’s T&C as well as the provisions of the applicable laws and regulations.
3. Principal
   The User may grant power to the party appointed by the User to exercise the rights arising from the account in Flock’s system, including to give instructions to Flock, under the terms prescribed by Flock.
4. Governing Law
   This Flock’s T&C and each legal relationships entered into between Flock and the User, unless otherwise agreed, are governed by and construed in accordance with the law of the State of the Republic of Indonesia.

1. Dispute Resolution
   All disputes and/or dissenting opinions which might arise in relation to the performance of this Flock’s T&C will be resolved through deliberation to reach a consensus. The User may notify the subject of the dispute and/or dissenting opinions to Flock at [email protected]

If the dispute and/or dissenting opinions cannot be resolved through deliberation within 30 (thirty) calendar days following the receipt of information on dispute and/or dissenting opinion by Flock at [email protected], the User agrees that the dispute will be exclusively resolved within the jurisdiction of the court of the Republic of Indonesia.