Terms and Conditions of PT Transwap Dunamis Indonesia
(Valid from 23 June 2025)

Customer Agreement (Singapore)

1. About This User Agreement

1.1 When you register and use any of our products and services (our “Services”), it creates a legally binding contract between you (“you”, “your” or “User”) and PT Transwap Dunamis Indonesia (“Transwap”, “we”, “us”, or “our”) that outlines your rights and obligations. All our products and services are subject to this User Agreement (also called the “Agreement”).

1.2 Please read this Agreement carefully. By using our Services, you confirm that you have read, understood, and agree to the terms of this Agreement in its most current form as published on our website. 

If you do not agree with any part of this Agreement, you won’t be able to be onboarded to use our Services. 

If you require clarification or further information, please visit our website at www.transwap.com ("Website") or contact us directly. You may download a PDF version of this Agreement by clicking the link provided at the top of the relevant page. You may also request a copy of this Agreement from us at any time. 

You may close your account at any time by contacting us. Account closure will result in termination of this Agreement, and you will no longer be permitted to use our products and services.

1.3Additional documents that apply to your use of our Services are referenced in this Agreement:

  • The conditions under which we handle any personal information you give us or that we gather about you are outlined in our Privacy Policy. You consent to this processing when you use our services, and you guarantee that the data you submit is accurate.
  • The information concerning "cookies" on our website is provided in our Cookie Policy.

1.4The most current version of this Agreement can be found at https://www.transwap.com/terms-of-service-id.

2.Who We are and How to Contact Us

2.1We are incorporated under the laws of the Republic of Indonesia with company registration number 9120605703405.

2.2Our registered office is at Jalan Merdeka No. 1 Cimone, Karawaci, Banten 15114.

2.3PT Transwap Dunamis Indonesia is authorised (reference number 21/248/Sr/3) in Indonesia as a Fund Transfer Operator and regulated by Bank Indonesia under Bank Indonesia Regulation No. 23/6/PBI/2021 on Payment Service Providers.

2.4You can contact us by email via our help centre at https://www.transwap.com/help-centre, or by logging into your account.

3.Definitions

3.1In this Agreement, unless otherwise expressed in a different context:

  • Account means an account you have opened with us to execute fund transfer transactions and for the purpose of using any of our Services.
  • Agreement refers to this document that pertains to the product and services provided by Transwap.
  • App or Application means our mobile application software, which you can use to access our Services, including any data and associated media with the software.
  • Authorised Person/User means a natural person who has been authorised by a company director to access and use the Services on behalf of the company or organisation. 
  • Business Day means a day (except Saturdays, Sundays, and public holidays) on which financial institutions are open for business in the Republic of Indonesia.
  • Company or business means an entity that is not a natural person.
  • User means any legal person or company who has registered for an account and has been accepted by us.
  • Designated Account means a bank account provided by you to facilitate any future withdrawal requests.
  • FATF stands for Financial Action Task Force.
  • BI stands for Bank Indonesia.
  • PBI stands for Peraturan Bank Indonesia which translates to the Bank Indonesia Regulation.
  • Fees means any costs, rates, or charges that are imposed by us relating to the products and Services that we offer.
  • Transaction Instruction means an instruction by a sender to send money to a receiver.
  • Receiving Currency means the currency that your recipient will receive from a Transaction Instruction.
  • Recipient means the entity receiving the money from a Transaction Instruction.
  • Services means carrying out transactions in accordance with purchase orders and the use of any technology, features, content, applications, and services that we provide, as well as any associated websites, apps, and services.
  • Sender means the entity initiating a Transaction Instruction.
  • Sending Currency means the currency with which you will fund a Transaction Instruction.
  • Source Account means the account from which money is transferred to fund a transaction Instruction.
  • User Interface means software that Transwap provides to the User and that the User utilises, such as websites, to communicate with Transwap.
  • Website refers to www.transwap.com

4.Who Can Use Our Services?

4.1To use our Services, you and/or your business must be established or registered in a jurisdiction or territory that we support.

4.2You are responsible for ensuring that your registration with us, your entry into this Agreement, your use of the Services, and the performance of any obligations under this Agreement do not violate any applicable laws or regulations.

4.3If you represent a Company, you are confirming that you have the authority to act on behalf of the Company to use our Services and that the Company accepts all the terms and conditions set out in this Agreement.

4.4You must be legally eligible to register for the purpose of using our Services. By doing so, you represent and warrant that you have the full right, authority, and capacity to enter into this Agreement ,  comply with and perform all your obligations under this Agreement.

4.5You must ensure that you will not violate any laws or regulations when registering with us, entering into or performing any part of this Agreement, or when using our Services.

4.6You may grant permission to a third party (an "Authorised User") to access, use, and manage your account or our Services on behalf of your business. By doing so, you consent and acknowledge that: 

Any actions taken by an Authorised User in connection with your account—including accessing balances, initiating deposits or withdrawals, or issuing instructions—will be treated by us as if they were taken by you and will be legally binding on you, even if such actions exceed the authority you granted to the Authorised User. We will treat Authorised Users in accordance with this Agreement and may share relevant information regarding your profile and account with them. 

It is your sole responsibility to ensure that your list of Authorised Users is accurate and up to date. While Authorised Users and Signatories may be verified at the time of account opening, we do not undertake to verify their authority on an ongoing basis. 

We are not responsible for how any Authorised User uses the information disclosed to them or for any acts or omissions by them. 

The addition of an Authorised User does not relieve you of your obligations under this Agreement, including but not limited to promptly notifying us of any suspicious activity, unauthorised transactions, or compromise of your account.

4.7Regarding the use of your account and the Services, Transwap assumes no liability for any claims or disagreements that may occur between you and your Authorised Users.

You agree to keep the list of Authorised Users and their responsibilities updated at all times and to update Transwap immediately with any modifications you make.

5.User Care and Grievances

5.1If you believe we have made a mistake or if our Service has not met your expectations, you are encouraged to contact us.

To lodge a complaint, please reach out to our customer service team or by emailing us at support@transwap.com.

Upon receipt of your complaint, we will investigate the matter promptly and, where appropriate, take corrective action. We are committed to resolving issues fairly and efficiently and will take necessary steps to prevent recurrence. Every complaint will be treated seriously, and you will be informed of the outcome of our investigation.

6.Your Account with Transwap

6.1By following the given steps throughout the registration procedure, your Transwap Account (“Account”) will be created through user interfaces such as our website.

6.2Once your Account has been successfully created, we will provide you with access to the tools and interfaces necessary to create the Transaction Instruction, communicate with us, and utilise other available services  our licensed jurisdiction permits.

6.3By creating an Account and using it, you shall be deemed to have accepted and be bound to this Agreement.

6.4You agree to provide us with any information we may request from time to time to create, maintain, and operate your Account. You are solely responsible for ensuring that all information you provide to us—including, but not limited to, your address and contact details—is accurate, complete, and kept up to date at all times.

6.5You may convert funds held in your Account from one supported currency to another, subject to availability. Currency conversion may be used as part of our Services, including when transferring funds out of your Account. A conversion fee may apply to each transaction. You will be informed of the applicable fees prior to initiating the conversion, and your confirmation of the transaction will be deemed as acceptance of those fees.

6.6You are required to disclose the purpose(s) of your Account during the KYC onboarding  whether it be used to send, receive, convert, or transfer funds to yourself and/or on behalf of any third party.

6.7Funds in your Account may be temporarily withheld from you if:

  • Part or all of the funds in your Account are under an ongoing investigation either by us or by the relevant authorities;
  • Part or all of the funds in your Account are pending a transaction reversal; or
  • We are prohibited by law from allowing the withdrawal of your funds.

7.Inactive or Dormant Accounts

7.1If no activity occurs within 12 months, an Account will be considered inactive. You can continue using your Account, however, we may request updated documents if and when necessary.

8. Your Responsibilities as a User

8.1You play a critical role in helping us maintain a secure environment for the use of our Services. Please read this section carefully, as it outlines important measures that will help protect you and your information while using our Services.

8.2Registering Your Account

  1. You must register for an Account with us atapp.transwap.live/register before you can access or use our Services.
  2. You may be restricted from accessing or using your Account or certain features of our Services until you complete our identification and security validation processes and provide all required information under our internal policies and applicable regulations.
  3. You must provide the following details by entering them into the appropriate fields on our application form:
    1. Company documents (deed of incorporation and Ministry of Law and Human Rights (“MOHLR”), latest articles of association and its MOHLR, business registration number (Nomor Induk Berusaha (NIB)), business license/permit/certification (if any), and tax registration card (NPWP)).
    2. Management information of the corporate entity (latest deed on management structure composition, copy of ID of director and commissioner, copy of tax registration card (NPWP) of director and commissioner; if the director and commissioner are of non-Indonesian nationalities, please provide passport and stay permit (KITAS)).
    3. For the individual (full name, ID number, registered address, phone number, signature, email address).
    4. Shareholder and Beneficial Ownership information.
    5. Authorised User (full name, citizenship, ID number, address, phone number, email address).
    6. Your mobile contact number—which will be used for authenticating and verifying the person using the account. Known as two-factor—one-time password (2FA – OTP) verification.
  4. We reserve the right to request additional information, documents, or data relating to you, your transaction(s), the sender, and/or the recipient of any transaction proceeds. We also reserve the right, at our sole discretion, to determine whether the information and/or documentation you have provided is sufficient to allow you to access or continue using any part of our Services.
  5. You are required to complete our identity verification process, which enables us to confirm your identity. This process may involve the use of a third-party verification system, which we will provide at our cost.
  6. You must ensure that all information you provide during registration and throughout your use of our Services is accurate, complete, and kept up to date at all times by promptly notifying us of any changes to your information to maintain its accuracy.
  7. You must not impersonate any other person, use an alias, or conceal your identity. We will use the information you provide, along with data obtained through your use of the website and our Services, to facilitate your participation in the Services and for other purposes in accordance with our Privacy Policy.
  8. From time to time, you may be required to provide additional information to allow us to continue providing our Services to you.
  9. You can sign up for an Account using one unique primary email address. If we detect multiple active registrations for a single email address used as the primary registration, we reserve the right, at our sole discretion, to merge or terminate such registrations and to suspend or refuse continued access to our Services without prior notice.
  10. You agree to the clauses stated on all account opening forms and account update forms (for both individuals and corporates wherever applicable).

8.3Keeping Your Account Safe

  • All instructions received from your registered email address or mobile contact number shall be deemed valid and binding on you. Accordingly, it is your responsibility to ensure the security of your account credentials and communication channels at all times.
  • You must never disclose your login credentials or user reference number to any third party. We will never request your password or user reference number, as these are not part of our user verification process. You accept full liability for any intentional or unintentional disclosure of your credentials and assume all associated risks, including the possibility of unauthorised access or use by third parties.
  • A strong password to secure your Account is highly recommended. If you have forgotten your password, you can reset it by requesting for a link to be sent to your registered email address with us at https://identity.transwap.live/Account/ForgotPassword?returnUrl=https%3A%2F%2Fapp.transwap.live.
  • You must ensure that the email address and mobile contact number provided during registration is accurate, belongs to you, and is secured and accessible only by you. Your registered email address may be used to reset your login password and to communicate important information regarding the security of your Account.
  • You must notify us immediately if your mobile contact number or email address changes, or if you suspect that either has been compromised. Prompt notification is essential to help us protect the security of your account and prevent unauthorised access.
  • You must inform us immediately if you become aware of any unauthorised access to your Account, unauthorised transactions or instructions, or if you suspect that your Account or security credentials have been compromised. In such cases, you must immediately change your password to one that you have never used before. You agree to promptly cooperate with us and/or law enforcement authorities in any reasonable investigations or actions taken to recover lost funds or address any actual or suspected security breaches.
  • When accessing your Account, you must ensure that your device is secured and maintained with the latest security updates. You are responsible for ensuring that your login session is safe and secure and that you keep your username and password always secure.

8.4Managing Your Account

  • You must agree to not use the Account for any illegitimate or unlawful reasons and that it is for your sole and exclusive use. You agree that it is your responsibility to seek independent expert advice on matters pertaining to your use of the account, including legal and tax matters. You agree that it is your responsibility to ensure that your usage of the Account conforms with all applicable laws, rules, and regulations, whether national or specific to the Republic of Indonesia.
  • You are responsible for ensuring that your Account is in good order. You must check your Account regularly and inform us immediately if you discover any irregularities.
  • You will receive an email after the completion of every Transaction Instruction. Your transactions can also be viewed after logging into your Transwap Account. You must report any disputes related to a transaction within 24 hours from the time the transaction occurs. Failure to notify us within this period will be deemed as your acceptance that all transactions and entries in your transaction history are accurate, true, and final.

8.5Ordering a Transaction Instruction

  1. For every Transaction Instruction you initiate, you must provide the following information accurately and in full:
    1. The Sending Currency and the amount to be transferred;
    2. The Receiving Currency and the amount to be received;
    3. The full name of the Receiver;
    4. The Bank Account Details of the Receiver (including account number, bank name, branch or any other applicable identifiers);
    5. Any other information that may be applicable or required by law, regulation, or Transwap’s internal policies
  2. You are solely responsible for ensuring the accuracy, completeness, and validity of all information submitted to us in connection with any Transaction Instruction. We will process transactions strictly based on the details you provide, and we are not obligated to verify or correct any such information. You acknowledge that any errors or omissions may result in delays, rejections, or misdirection of funds. In such cases, you may be liable for any associated costs. We reserve the right to charge a fee for any amendment, rejection, cancellation, or retrieval of a transaction that has already been processed, regardless of whether the retrieval is ultimately successful or unsuccessful.
  3. The exchange rate and transaction fees will be displayed on the ordering screen before you go ahead and confirm the booking of any transaction. Once you have confirmed that you agree to the displayed exchange rate and transaction fee, the Transaction Instruction cannot be modified. If you need to change any details, you must cancel and start a new Transaction Instruction. Please note that you may or may not get the same exchange rate when you initiate a new Transaction Instruction.
  4. Transaction fees displayed do not include any fees your bank or your recipient’s bank may charge for your Transaction Instruction. Depending on the situation, the fees may be deducted from your funds or from the amount sent to your Recipient.
  5. You may fund your Transaction Instruction via a bank transfer from your bank account. The Source Account must be in your name. We do not accept any form of funding from a third party. We also do not accept other methods such as cash or check.
  6. We must receive sufficient funds for your transaction before your Transaction Instruction is considered valid. We are not responsible for the time it takes for your bank or any other service provider to process funding instructions.
  7. You may cancel your Transaction Instruction before we receive your funds. You should contact us at support@transwap.com for any assistance.
  8. We may cancel your Transaction Instruction if we do not receive your funds within 24 hours.

8.6Receiving Money in Your Bank Account

  • You may receive funds into your designated bank account from us. You are solely responsible for ensuring the accuracy and completeness of the bank account details you provide to the sender. We shall not be liable for any delays, misdirected payments, or losses arising from incorrect or incomplete information supplied by you.
  • You will be able to view the received amount in your transaction history. It is your responsibility to regularly review your transaction history for any discrepancies or irregularities. You must notify us immediately upon identifying any such issues.

8.7Withdrawing Money from Your Account

  • You will not be able to withdraw from your Account in cash.
  • Withdrawals from your Account are for refund purposes only. You will be charged a fee for each withdrawal request.
  • All requested bank account information is necessary for us to process your refund. Refund can only be sent to the Source Account.
  • Responsibility for Bank Account Information—You are solely responsible for ensuring the accuracy of the bank account information you provide. We are not liable for any funds sent to an incorrect recipient as a result of errors in the information submitted by you. You may request a transaction reversal; however, we do not guarantee that such a request will be successfully processed. A handling fee may apply for any such request, regardless of whether the reversal is completed successfully.
  • We are not responsible for any delays caused by your receiving bank or payment service provider in crediting the funds to your account. Once we have processed and transmitted the funds following your instruction, the timing of receipt is outside our control.

8.8Paying off Fees and Charges

  1. You are solely responsible for the following:
    1. All fees and charges imposed by us, as agreed upon by you at the time of placing the Transaction Instruction;
    2. All fees and charges levied by your bank in connection with funding your Transaction Instruction;
    3. All fees and charges applied by the receiving bank in connection with your Transaction Instruction;
    4. All fees and charges associated with any amendment, rejection, cancellation, or retrieval of your Transaction Instruction, regardless of the outcome; and
    5. If you fail to pay us any applicable fees or charges, we reserve the right to suspend or refuse to provide Services to you.

8.9Communications Between Us

  • Our primary method of communication with you is via email. You must ensure that the email address registered with us remains valid and accessible at all times. Communications from us may include important information and may contain links directing you to additional content on our website. You are responsible for checking your email regularly and staying informed of any communications we send.

8.10Adhering to Relevant Laws

  • You must not use your Account or any of the Services we provide to conduct, facilitate, or participate in any form of illegal activity. This includes, but is not limited to, fraudulent transactions, money laundering, terrorism financing, proliferation financing, or any activity that violates applicable laws, regulations, or regulatory guidelines. We reserve the right to report any suspicious activity to the relevant authorities and to take any appropriate actions, including suspension or termination of your Account(s).
  • You must comply with all applicable laws, regulations, and regulatory requirements in connection with your use of our Services. This includes, without limitation, full compliance with all prevailing Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) legislation and guidelines. You are responsible for ensuring that your activities do not breach any such legal or regulatory obligations.
  • Following prevailing Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) legislation, we are prohibited from conducting business with certain individuals, entities, or jurisdictions. We have implemented security screening procedures and other due diligence measures per local regulatory requirements. If any concerns arise regarding your identity or the nature of your transactions, we may request additional documentation or information. This may result in delays, suspension, or cancellation of your transaction(s) or Account access.
  • You must not share access to your Account with any third party. For individual users, you must remain the beneficial owner(s) of your Account(s) at all times. Any unauthorised access, use, or sharing of your account may result in immediate suspension or termination of the account, and we shall not be held liable for any loss or damage arising from such unauthorised use.

9.Our Responsibilities to You

9.1Safeguarding Your Money

  • Transwap is authorised by Bank Indonesia and operates in collaboration with trusted and regulated partners. We comply with applicable safeguarding regulations to ensure that your funds are adequately protected. In the unlikely event that Transwap becomes insolvent or ceases operations, your safeguarded funds will be returned to you following the relevant legal and regulatory requirements.

9.2Provision of Services

  • We strive to provide Users with 24/7 access to our Website. However, access may be interrupted from time to time due to scheduled maintenance, in which case we will use reasonable efforts to notify you at least 24 hours in advance. In certain cases, access to your account may be temporarily suspended for unscheduled or emergency maintenance, whether routine or exceptional, based on our assessment of the situation. Where practicable, we will provide advance notice of such suspensions via email, in-app notifications, or both.
  • We reserve the right, at any time and without prior notice, to discontinue or limit access to the Services for residents of high-risk and non-cooperative jurisdictions as recommended by the laws of the Republic of Indonesia and FATF.
  • Notwithstanding the above, we do not guarantee that our Website or Services will always be available, uninterrupted, or error-free. Access may be affected by factors beyond our control, including technical failures or maintenance activities. We shall not be held liable for any downtime, interruptions, or disruptions to our Website or Services, whether scheduled or unscheduled.

9.3Processing Your Transaction Instruction

  • We aim to process and complete all Transaction Instruction within 24 hours. You may contact us to enquire about the status of any transaction. However, please note that this timeframe is indicative only and not guaranteed. We shall not be held liable for any delays in processing
  • If a transaction instruction is ordered after 2 pm or any time on a non-business day, it will be considered as ordered on the next business day.
  • You will be notified of the estimated completion time for your Transaction Instruction upon our receipt of your funds. If the scheduled completion falls on a non-business day in the Recipient’s country, the transaction will be processed on the next available business day.
  • To fulfill our regulatory obligations, we may conduct verification checks on your transactions. Verification checks may increase the processing time of your Transaction Instruction. We are not responsible and cannot be held liable for any delays as a result of conducting such checks.
  • We are obliged to provide an explanation of any rejection and/or pending Transaction Instruction to you. If we have already received funds for a Transaction Instruction that is subsequently rejected, we will refund the full amount received to the Source Account used to fund the Transaction Instruction.
  • If we receive your funds after 2:00 PM or on a non-business day, we will refund the full amount received to your Source Account used to fund the Transaction Instruction. Your Transaction Instruction will not be cancelled or rejected. You may reinitiate the transfer by sending the funds to us on the next business day before 2:00 PM or during our operating hours.

9.4Exchange Rate

  • The applicable exchange rate will be disclosed to you before you confirm any Transaction Instruction involving a currency conversion.
  • The exchange rate will be presented during the Transaction Instruction process if the transaction involves currency exchange.
  • The exchange rate applied to your transaction instruction will be based on the rate available at the date and time the instruction is confirmed.
  • You are solely responsible for reviewing and accepting the exchange rate before confirming a Transaction Instruction. We strongly advise you to exercise caution and ensure that you are satisfied with the rate presented.

9.5Our Fees and Charges

  • We charge a fixed transaction fee (collectively referred to as “fees and charges”) for each Transaction Instruction, all of which are fully visible to you before you accept and confirm every Transaction Instruction.
  • These fees and charges differ for each currency pair.
  • Fees and charges imposed by us do not include any additional fees or charges that may be levied by your bank, your recipient’s bank, or any payment service provider involved in processing the Transaction Instruction. Depending on the circumstances, such fees and charges may be deducted either from your funds before the transfer is made or from the amount received by your Recipient.
  • If you provide invalid Recipient details, the receiving financial institution may reject the processing of your Transaction Instruction. In such cases, we may apply a handling fee, which will be deducted from the sent amount before the remaining balance is returned to you.
  • We may charge a fee for any amendment or cancellation of a Transaction Instruction resulting from the same reasons. Additionally, we may charge a fee for any retrieval requests, regardless of whether the retrieval is successful.

9.6Important Notifications to You

  1. We will send you a notification through email or any communication tools to inform you of:
    1. Changes in the status of a Transaction Instruction;
    2. Updates relating to special requests such as amendments, cancellations, or retrievals;
    3. Changes to this Agreement;
    4. Changes to Services offered by us;
    5. Changes to the way we offer our Services to you;
    6. Information which may impact the way you use our Services; or
    7. Any other information as required by legislation.
  2. We aim to provide you with a reasonable notice period for any material changes so that you can make any necessary arrangements.
  3. If we do not receive any notification indicating that our email was not delivered, the email will be deemed to have been received by you on the same day it was sent to your registered email address or through any other communication channel we use.

9.7Dispute Resolution

  • We are committed to resolving any disputes with fairness, impartiality, and reason. While your concerns and feedback will be carefully considered, our final decision will be binding. Should you wish to challenge it, you may seek review through the local country’s established mechanisms and relevant bodies for an independent review of the case.

9.8Record Keeping and Account Statements

  • We reserve the right to retain any records or other data in an electronic format pertaining to you, the Services, or any Transactions. To the greatest extent allowed by law, any such digital recordings will be considered as proof of the receipt and legitimacy of the aforementioned Transaction Instruction.
  • We have provide copies of your transaction history by email every time you create a Transaction Instruction. The transaction history will show (i) the transaction currency and amount that was processed, (ii) the foreign exchange rate that was applied for any currency conversions, (iii) the fees charged, and (iv) the date when the transaction was approved.
  • By accessing your Account through our Website, you will be able to view detailed information for each completed transaction. We will provide comprehensive records, including any fees paid in connection with those transactions.

10.Promotion Code and Promotion Campaigns

10.1Any promotion codes provided by us cannot be used together with other promotions unless otherwise stated.

10.2You must have a successfully registered account with us to use a promotion code.

10.3Any form of promotion is not exchangeable for cash or other benefits.

10.4We reserve the right to change or terminate any promotion at any time without giving you prior notice or any form of compensation.

10.5We reserve the right to disqualify you from the promotion if we deem that you have engaged in conduct that we consider inappropriate or unacceptable.

11.Changes to This Agreement

11.1We reserve the right to amend all or part of this Agreement. If any changes are made, we will notify you at least 30 (thirty) working days before the changes take effect, using the email address you have registered with us.

11.2If you object to any changes to this Agreement, you must submit a termination request to us at support@transwap.com within 30 (thirty) working days from the notice of the changes. If you do not notify us within this period, or if you continue to use our Services after the notice of the changes, it shall be deemed that you have accepted the changes.

12.When Can We Suspend Your Account?

12.1We reserve the right to suspend any part or all of your access to our Services if:

  • We cannot verify your identity.
  • You failed to provide the information requested by us to facilitate your Transaction Instruction.
  • We receive instructions to do so from the relevant authorities.
  • We believe the information you have provided is incorrect, unauthorised, or fraudulent.
  • We believe that access to your Account has been compromised.
  • To conduct a regulatory check, we may stop the execution of your transactions, or we might decline to execute them altogether. Unless there is a clear and present fraud or wilful carelessness on our part, we will not be responsible for any losses resulting from such suspension or refusal.
  • We may not disclose the reason for your suspension, especially if your transaction is under legal and/or regulatory investigation(s) or suspect of improper use

12.2When your Account is suspended, you will not be able to submit any Transaction Instruction. The funds in your Account will remain your property; however, you will not be able to access or use them until the suspension is lifted.

12.3We do not guarantee any specific timeline for lifting a suspension, and therefore we shall not be liable for any losses incurred by you or any third party as a result of the suspension.

13.Termination

13.113.1. We may immediately suspend or terminate your registration and this Agreement at any time, without prior notice or explanation, if:

  • We determine that you are ineligible to use our Services or that you are using the Services for purposes that are unauthorised or prohibited under our terms and applicable laws.”
  • We discover that your Account is not operating in a proper or regular manner stipulated in this Agreement
  • We discovered that you have engaged in behaviour that we view as suspicious.
  • We discover that you have duplicate Accounts opened for the same person.
  • We have reasonable grounds to believe that you are violating any applicable laws or regulations.
  • You have breached any of the terms within this Agreement.
  • We are required to do so to fulfill our regulatory obligations, either in the Republic of Indonesia or elsewhere in the world.
  • It is deemed unlawful for us to continue to provide our Services to you.
  • You have given us untrue, inaccurate, incomplete, or misleading information.
  • You become insolvent or bankrupt or subject to judicial proceedings.
  • You become subject to investigation for offences relating to money laundering, tax evasion, or terrorism financing, and their predicate offences.
  • You are persistently unresponsive or unreachable through the phone number or email address you have provided to us; or
  • You or your bank initiated a chargeback or rejection of an attempted transfer.

13.2We may suspend or refuse to execute a Transaction Instruction if any of the reasons stated above in Clause 13.1 apply to the Recipient of the Transaction Instruction.

13.3You may terminate this Agreement by contacting us at support@transwap.com.

13.4In all cases, we reserve the right to determine the effective date of termination at our sole discretion.

13.5Termination of this Agreement shall not affect any transactions or obligations that arose prior to the effective date of termination. Following termination, we will retain records of your transactions following applicable regulatory requirements and our data retention policies.

14.Our Intellectual Property Rights

14.1Our Services are protected by copyright, trade secrets, and other intellectual property laws. We and/or our licensors own the title, copyright, and other worldwide intellectual property rights in all services relating to Transwap. Using Transwap and our Services does not grant you any rights to our trademarks or Service marks.

14.2For the purpose of these Terms and Conditions, intellectual property rights shall mean all patent rights, copyright rights, moral rights, rights of publicity, trademark, trade dress, and service mark rights, goodwill, trade secret rights, and other intellectual property rights as may now exist or hereafter come into existence, and all applications and registrations, renewals, and extensions thereof, under the laws of the Republic of Indonesia and any country, territory, or other jurisdiction.

14.3You agree not to alter, copy, distribute, extract, make available, modify, obscure, reproduce, tamper with, or otherwise use any content from our Website without our prior written consent. Any unauthorised use of such content may constitute an infringement of our intellectual property rights, and we reserve all rights to enforce and protect those rights to the fullest extent permitted by law.

15.Data Protection and Confidentiality

15.1All information you provide to us about yourself, referred to as "Personal Information" or "Personal Data," is handled in accordance with applicable legal and regulatory requirements governing confidentiality and data protection. We are committed to maintaining the confidentiality of your personal information. However, in certain circumstances—such as when required by applicable law, regulation, or a valid court order—we may be legally obligated to disclose such information.

15.2By entering into this Agreement, you expressly consent to our collection, use, processing, and disclosure of your information (including, without limitation, Personal Information) in accordance with our Privacy Policy, which is available at https://www.transwap.com/privacy-notice. Your acceptance of this Agreement constitutes your explicit agreement to the terms of our Privacy Policy.

16.Information Security

16.1We do not guarantee that our Website or app will be secure or free from bugs or viruses.

16.2You are responsible for configuring your devices, systems, and network to ensure secure and safe access to our Website or app.

16.3You must not misuse our Services by introducing viruses, trojans, worms, logic bombs, or any other material that is malicious or technologically harmful. You are strictly prohibited from attempting to gain unauthorised access to our Website, the server on which it is hosted, or any server, computer, or database connected to our Website. You must not conduct or participate in any form of denial-of-service attack or distributed denial-of-service attack against our Website.

A breach of this provision may constitute a criminal offence under Clause 30 of Law No. 11 of 2008 on Electronic Information and Transactions (ITE Law) and its amendments. We reserve the right to report any such breach to the relevant governmental, public, or law enforcement authorities and will cooperate fully by disclosing your identity as required. In the event of such a breach, your right to use our Services will be terminated immediately.

16.4Links from Our Website

  • We may provide links to websites and resources operated by third parties. These links are provided for informational purposes only. We do not control, endorse, or assume responsibility for the content, accuracy, or practices of any third-party websites. You are advised to exercise due diligence and caution when accessing or using such external sites.
  • Accessing links from our website does not imply any endorsement by us of the linked third-party websites, their content, or the resources they provide. We do not warrant or endorse any advice, opinions, statements, or other information that may be displayed on or through such third-party sites. We accept no responsibility for the accuracy, completeness, or legality of content provided by these external sources, and we shall not be liable for any loss or damage that may arise from your access to or use of them.

17.Disclaimer for Usage of Our Services

17.1 In providing the Services to you, neither we nor any of our affiliates, parent or holding companies, subsidiaries, employees, officers, directors, agents, service providers, or subcontractors make any express warranties or representations except as expressly set out in this Agreement. To the fullest extent permitted by applicable law, all implied and statutory warranties and representations—including, without limitation, any warranties of merchantability, fitness for a particular purpose, or non-infringement—are hereby expressly disclaimed.

17.2To the fullest extent permitted by applicable law, in no event shall we, or any of our affiliates, parent or holding companies, subsidiaries, employees, officers, directors, agents, service providers, or subcontractors be liable to you or any third party for any indirect, incidental, special, consequential, punitive, or exemplary damages. This includes, without limitation, damages for loss of data, loss of income, loss of profits, failure to realise expected savings or revenues, or any other economic or pecuniary loss, whether arising in tort (including negligence), contract, strict liability, or any other legal or equitable theory.

17.3We shall not be liable for any goods or services bought or sold by you in connection with, or settled through, your use of the Services. We also accept no liability for any event or circumstance beyond our reasonable control, including those that are unusual, unforeseeable, or required by statutory obligation or legal order.

Unless we are under a statutory duty to the contrary, we do not accept liability for:

  • Any failure or inability on your part to communicate with our systems;
  • Loss of data or delays in transmission caused by third-party service providers, including internet service providers;
  • Computer viruses, spyware, or malware originating from third parties;
  • Errors resulting from incomplete or inaccurate information provided by you; or
  • The unauthorised use, access, or interception of information during your access to the Services.

17.4We may from time to time provide you with information on historical and current market trends, transaction processing methodologies and patterns, updates on currency pairs, or any other information we believe may be of use to you. This can be in the form of verbal communications, articles on our Website, or email communications sent by us. Such information and publications are not intended to be and do not constitute any professional advice or any other advice or recommendation of any sort. We also do not guarantee that such information and publications are accurate, up-to-date, or applicable to the circumstances of any particular case. You must do your own due diligence and exercise caution when using our Services. We will not be liable to you if you choose to act based on information provided by us.
We do not exclude liability for any matter where it would be unlawful to do so, including liability for death or personal injury caused by our negligence, for fraud, or for breach of your legal rights where it would be unlawful to exclude such rights.

17.5You consent to us using any contact information you have given us, such as your email address, phone number (including mobile number), and postal address, to get in touch with you about any issues relating to this Agreement, service, or operational concerns.

17.6Unless and until you notify us of a new email address in writing, we will continue to correspond with you using the email address you provided at the commencement of our relationship. You are responsible for informing us in writing of any changes to your email or mailing address as soon as reasonably practicable.

17.7Notifications sent via postal mail will be considered received by you on the fifth (5th) day after the date of posting, and if sent via the website, it will be considered received instantly by email.

17.8We may, at our sole discretion, accept instructions received via email if we reasonably believe them to be authentic. However, we are under no obligation to do so and may require additional verification or refuse to act on such instructions without providing a reason.

17.9You agree to notify us—either in writing, via customer support, or by email—within 14 business days of any change to your name, address, or other contact information. This is necessary to ensure that our records remain current, accurate, and up-to-date. We shall not be held liable for any losses or damages you may incur as a result of providing false, outdated, or incomplete information.

17.10Each provision of this Agreement is separate and severable from the others. If any term or condition is found to be invalid, unlawful, or unenforceable under the laws of any jurisdiction, such invalidity, unlawfulness, or unenforceability shall not affect the validity, lawfulness, or enforceability of the remaining provisions of this Agreement, which shall continue in full force and effect. Furthermore, the affected provision shall not impact the enforceability of this Agreement under the laws of any other jurisdiction.

17.11Nothing in this Agreement limits or affects your statutory rights, including but not limited to your right to discontinue use of the Services at any time, your right to seek remedies for any misrepresentation of the Services, and any other rights granted to you under applicable consumer protection laws.

18.Other Important Terms

18.1Non-Waiver of Rights

  • Any failure or delay by us in exercising or enforcing any right under this Agreement shall not be deemed a waiver of that right, nor shall it prejudice or affect our ability to exercise that right at a later time. We reserve the right to enforce our rights strictly and at our sole discretion.
  • Moreover, no waiver by Transwap or any of its rights or powers under this Agreement shall be deemed to have been made unless expressed in writing and signed by its duly authorized representative.

18.2Entire Agreement

  • This Agreement, together with any documents expressly referenced herein, constitutes the entire Agreement between you and us and supersedes all prior discussions, correspondence, arrangements, or understandings, whether oral or written, relating to the subject matter of this Agreement.
  • This Agreement may be provided to you in Bahasa Indonesia or English. If any inconsistency arises between the Bahasa Indonesia and English of the Agreement, the English version of the Agreement shall prevail.

18.3Severability

  • If any provision of this Agreement is found to be void, invalid, or unenforceable under any applicable law, such invalidity shall not affect the validity, legality, or enforceability of the remaining provisions, which shall continue in full force and effect.

18.4Assignment

  • You may not assign, transfer, or otherwise dispose of any of your rights or obligations under this Agreement without our prior written consent.
  • We may assign or transfer any of our rights or obligations under this Agreement to a third party without your prior consent or notice, provided that such assignment does not adversely affect your rights under this Agreement.

18.5Notices to Us

  • Any notice of legal claim or other process pursuant to this Agreement shall be delivered via post to Transwap's registered address at PT Transwap Dunamis Indonesia, Jalan Merdeka No. 1 Cimone, Karawaci, Banten 15114.

18.6Our Service Providers

  • We may engage agents and third-party service providers to assist in the delivery of our Services to you. All such Services, whether provided directly by us or through our agents or service providers, are engaged at our sole discretion and shall remain subject to our oversight, supervision, and control.

19.Governing Law and Jurisdiction

19.1This Agreement, and any dispute or claim arising out of or in connection with it—whether contractual or non-contractual, including its subject matter or formation—shall be governed by and construed in accordance with the laws of the Republic of Indonesia.

19.2Transwap and you shall endeavour to resolve any dispute, controversy, or claim arising out of or in connection with the formation, performance, termination, or breach of this Agreement through good faith negotiations as a first step prior to pursuing any formal legal proceedings.

19.3The Parties agree that the Indonesian National Board of Arbitration (BANI) at Jakarta shall have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with the Agreement or its subject matter or formation (including non-contractual disputes or claims).

IN WITNESS WHEREOF, the authorised representatives of the parties hereto have executed these Terms and Conditions of PT Transwap Dunamis Indonesia as of the date first written above.