Dispute Resolution & Complaint Handling

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This Dispute Resolution and Complaint Handling framework describes how PT UNIT GLOBAL SYSTEM receives, acknowledges, investigates, and resolves customer and merchant complaints. It implements OJK Regulation POJK 18/POJK.07/2018 on Consumer Complaint Handling in the Financial Services Sector (POJK 18/2018) and is consistent with the Bank Indonesia consumer-protection framework for payment service providers.

1. Scope

This framework applies to every complaint relating to UnitPay services, including complaints about: transactions processed through UnitPay-integrated checkouts, merchant on-platform conduct that affects the customer experience, refunds and chargebacks, account suspension, KYC and AML decisions, fees, settlements, and data processing.

It applies to customers paying through UnitPay-integrated checkouts (end users) and to merchants holding accounts with UnitPay. Complaints from regulators and law enforcement are handled through dedicated regulator channels and are outside the scope of this consumer-facing framework.

Complaints that relate purely to the merchant's underlying goods or services (not to UnitPay's role in processing the transaction) are best addressed by the merchant directly. Where the customer is unable to resolve the matter with the merchant, UnitPay's complaint channels remain available so the customer is not left without recourse.

2. Complaint channels (per POJK 18/2018 Article 5)

Multiple channels are provided so that complainants can choose the format most convenient to them:

  • Email: complaints@unitpay.net — preferred for written, evidenced cases.
  • Phone: +6285121084571 during operating hours (Mon-Fri 09:00-18:00 WIB).
  • WhatsApp: through the click-to-chat link displayed in the site footer; same operating hours as voice.
  • Postal mail: PT UNIT GLOBAL SYSTEM, registered office at Menara Cakrawala Lt. 12 Unit 05A, Jl. M.H. Thamrin, Kelurahan Kebon Sirih, Kecamatan Menteng, Kota Administrasi Jakarta Pusat, Provinsi DKI Jakarta 10340, Republik Indonesia.
  • Walk-in: at our registered office during operating hours, with reasonable advance notice so a complaint handler is available.

For matters touching personal data subject rights specifically, the appropriate channel is dpo@unitpay.net; the framework here applies in parallel.

Complaints may be filed in Bahasa Indonesia or English. The substantive response is provided in the language of the complaint where reasonably practicable; for cross-border cases involving non-Indonesian counterparties, the response may be provided in English with an Indonesian summary.

3. Resolution timeline (per POJK 18/2018 Articles 18 and 25)

UnitPay observes the timelines set out in POJK 18/2018:

  • Acknowledgement: every complaint is acknowledged within five working days from receipt, with a ticket number and the assigned case handler.
  • First substantive response: provided within twenty working days for standard complaints.
  • Extended response: complex cases may be extended up to forty working days, with written notice to the complainant before expiry of the original window stating the reason for extension.

The clock starts on receipt of a complete complaint with sufficient information to investigate. Where additional information is required to proceed, we request the information promptly and the response clock is paused only for the minimum period reasonably required to obtain it.

Working day is interpreted in line with the Indonesian financial-sector calendar: Saturdays, Sundays, and Indonesian public holidays are excluded. Bank Indonesia and OJK closures (rare but possible for system maintenance) do not toll the clock except where specifically directed by the regulator.

Resolution timelines apply to the substantive response. Implementation of any agreed remedy (refund, account adjustment, process correction) follows the timing specified in the response, which depends on the rail or system involved.

4. Acknowledgement and tracking

Every complaint is logged in our complaint register with: receipt timestamp, complainant identity (subject to consent), channel of receipt, summary, ticket number, assigned handler, milestone dates, supporting documents, and final resolution. The register is the authoritative source for complaint metrics reported to OJK on the schedule established by POJK 18/2018 Article 38.

Complainants may request status updates at any time by quoting the ticket number to complaints@unitpay.net. We aim to provide an interim status update within five working days of any such request.

Where a complaint is resolved in favour of the complainant, the substantive response sets out the remedy provided (refund, fee waiver, account adjustment, written apology, or process correction as applicable). Where a complaint is not upheld, the response explains the reasoning so that the complainant can decide whether to escalate.

5. Internal escalation

Complaints follow an internal escalation ladder. Each tier reviews the case independently, taking into account evidence, policy, and applicable law:

  • Tier 1: customer support, for transactional and procedural matters resolvable from documented information.
  • Tier 2: AML Compliance Officer, for matters touching AML, sanctions, suspicious-activity decisions, or risk-tier outcomes.
  • Tier 3: legal team, for matters of contractual interpretation, regulatory complaint, or contested data subject rights.

The final internal response is signed by the AML Compliance Officer or the Head of Legal, as appropriate to the subject matter. The signed response sets out the next available escalation step (LAPS SJK or OJK 157) so that the complainant has a clear pathway forward.

Tier 2 and Tier 3 reviewers are independent of the original handler so that escalations receive a genuinely fresh look. Where the original handler is also the appropriate Tier 2 or Tier 3 reviewer, the case is allocated to a substitute reviewer.

6. External escalation: LAPS SJK

If a complainant remains dissatisfied with our final internal response, the complainant may escalate to Lembaga Alternatif Penyelesaian Sengketa Sektor Jasa Keuangan (LAPS SJK), the OJK-recognised alternative dispute resolution body for the financial services sector. LAPS SJK provides mediation, adjudication, and arbitration services for unresolved consumer complaints.

Contact LAPS SJK via https://lapssjk.id. The complainant should reference our final response and any prior ticket number when filing the LAPS SJK case to expedite review. UnitPay cooperates fully with LAPS SJK proceedings and complies with LAPS SJK awards in line with the procedural framework.

7. External escalation: OJK consumer hotline 157

In addition to or in place of LAPS SJK, the complainant may contact the OJK consumer hotline at 157. The hotline operates as an OJK consumer-protection channel; complaint forms and additional contact options are available through the OJK contact page at https://ojk.go.id/en/contact.aspx.

Where the matter concerns Bank Indonesia regulatory aspects of payment services, complainants may also approach Bank Indonesia consumer channels in line with applicable BI procedures.

UnitPay cooperates promptly with OJK and BI follow-ups arising from a complaint. Where a regulator requires UnitPay to take specific corrective action, the action is implemented within the timeline directed by the regulator and recorded in the case file.

8. Statistics reporting (per POJK 18/2018 Article 38)

UnitPay reports complaint statistics to OJK on a quarterly cadence as required by POJK 18/2018 Article 38, including:

  • Total complaints received during the period.
  • Breakdown by complaint category (transactional, fees, suspension, KYC and AML, data processing, other).
  • Resolution time distribution against the 5-working-day acknowledgement and 20/40-working-day response timelines.
  • Outcomes (resolved in favour of complainant, partially upheld, not upheld, withdrawn).
  • Trend metrics quarter-on-quarter and year-on-year.

Aggregated statistics may be published in our annual transparency review. Sensitive complainant identifying information is excluded from any public-facing summary.

9. Anti-retaliation and confidentiality

UnitPay does not penalise customers or merchants for raising good-faith complaints. Suspending services, increasing fees, or otherwise altering the relationship in response to a complaint is prohibited and would itself constitute a separately reportable matter.

We treat complaint content confidentially within UnitPay to the extent permitted by law, consistent with our duties to investigate and to comply with regulator inquiries. Access to complaint records inside UnitPay is restricted to the assigned handler, the relevant escalation tier, and the staff who maintain the register; broader access is logged.

Information disclosed to LAPS SJK or OJK in the course of external escalation is the minimum required by the body conducting the review. Where the body's process permits, sensitive personal data is redacted.

10. Personal data and retention

Complaint-related personal data is processed on the lawful basis of legal obligation (POJK 18/2018 record-keeping requirement) and contractual necessity, in line with our UU PDP Personal Data Notice. Complaint records are retained for at least seven years to support regulator audit and longer where specific legal-process requirements apply.

Where a complaint involves data subject rights, the response is coordinated with the Data Protection Officer. Complainants may exercise data subject rights at any time through dpo@unitpay.net; the rights and the qualifications imposed by regulator-mandated retention are described in the UU PDP Notice.

For training purposes and quality assurance, anonymised complaint summaries may be used internally; identifying information is removed before any such use. External publication of complaint material always requires the complainant's prior consent or strict anonymisation that prevents re-identification.

Effective date: 06 May 2026