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Contract reading

What Pluang legally published, but does not want you to read

Every clause below is published by Pluang itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: PT Bumi Santosa Cemerlang

sole discretionhidden feedeemed acceptancewithdrawalscounterpartydispute barrierfee ceilingkyc freezeprofit voidingunilateral amendment

Pluang is one app over five Indonesian companies, each with its own contract and its own rule book. Two of those rule books let a trade you have already made be cancelled or closed out, including a trade that is winning. On US stocks you get one day to dispute a transaction report. The fee figures on the marketing pages are promotions, and the contracts set ceilings about three times higher.

Contract risk

Money at risk
6.5/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
5
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
20
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
17
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
4

How the 20 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical5
Warning14
Notice1

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

3 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

What the documents say

20 clauses worth knowing about, worst first, each quoted from Pluang's own files

01

If another trader's loss is too big for the insurance fund, the exchange closes other people's open positions to cover it. It picks the accounts with the highest leverage and the largest potential profit first, so being right is what puts you on the list. The crypto rules call this Automatic Deleverage.

Why this matters

You can be taken out of a profitable trade at a price you did not choose, because of somebody else's losing trade. The same clause says you agree not to protest it to the exchange or the clearing house.

Exhibit 1CriticalHarder than usual

Dalam hal menunjuk pihak/Nasabah yang menjadi lawan transaksi dalam proses ADL, Bursa mengacu pada kriteria Nasabah dengan leverage paling tinggi dan potensi keuntungan paling besar. Nasabah yang terkena ADL setuju untuk tunduk pada aturan ini dan tidak dapat memprotes Bursa maupun Lembaga Kliring Penjaminan dan Penyelesaian dengan terlebih dahulu menyetujui syarat dan ketentuan yang berlaku.
Clause XVIII in Peraturan dan Ketentuan Perdagangan Aset Crypto dan Crypto Futures
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026Your winning crypto futures position can be closed because it is winning (clause XVIII)Visit this page on the broker's siteDownload the full size image file
  • Worse together with Exhibit 2One product closes you out for being wrong, the other for being right, and neither needs your agreement.
02

Once your margin level reaches 30%, PT PG Berjangka can close some or all of your US stock positions without asking you. In a fast market the stop loss price you set is ignored, and everything is closed at the forced liquidation price instead. Margin is the money you must keep in the account to hold a leveraged position open.

Why this matters

You can be closed out at a far worse price than the one you chose as your own limit. Nobody has to warn you first: the same rules say PT PG Berjangka has no duty to tell you a margin call has happened.

Exhibit 2CriticalHarder than usual30%

Apabila Margin Level mencapai level 30% atau di bawahnya, maka pialang PALN dapat melikuidasi sebagian atau semua posisi nasabah tanpa memerlukan persetujuan nasabah (Force Liquidation).
Clause Force Liquidation in Peraturan dan Ketentuan Transaksi Penyaluran Amanat Luar Negeri Produk Saham Tunggal Asing (PALN)
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026The claim, on Leverage feature page, FAQ answer to the question Apa itu Margin Call?This capture shows the page the quotation was taken from. The words themselves are not marked in it, so please read the quotation above as the evidence.Visit this page on the broker's siteDownload the full size image file
Our own capture of pluang.com, taken on Sep 16, 2026What the contract says, clause Force LiquidationVisit this page on the broker's siteDownload the full size image file

What it costsOn $1,000 of your own money at 2x leverage you hold $2,000 of stock. Your positions can be closed once your equity falls to 30% of the margin required, and any stop loss you set above that price does not apply.

Set against a regulated standard: ESMA (EU), FCA (UK)

Firms licensed under the ESMA and FCA rules for retail leveraged trading must close a retail client's positions once account equity falls to 50% of required margin, and must notify the client. These rules set the closing point at 30% and put the duty to watch the account on you.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

03

Pluang can revoke, cancel, refuse, suspend or change a transaction you have already made, and it can do that without telling you first. It can then adjust your transaction records, balance, assets or portfolio without your consent. Judging whether your behaviour was suspicious is, in the contract's own words, entirely Pluang's authority.

Why this matters

A profit you have already banked can be removed, and the contract says Pluang owes you nothing for the gain you lose. If the balance cannot be adjusted, you have three working days to send the money back.

Exhibit 3CriticalHarder than usual3 working days

Pluang berhak untuk melakukan penyesuaian terhadap catatan transaksi, saldo, aset atau portofolio Anda tanpa persetujuan dari Anda;
Clause Pembatalan Transaksi in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026Pluang can cancel a completed trade and rewrite your balance (clause Pembatalan Transaksi)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must treat clients fairly when cancelling a trade and must give reasons a client can challenge. This contract makes the test internal to Pluang and excludes any payment for lost profit.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 5The same suspicion that cancels the trade can freeze the account it sat in, and Pluang decides both.
04

PT PG Berjangka emails you a daily transaction report, and the rules give you one day, stated as 24 hours, to object to anything in it. Miss that window and the rules set out no other route to dispute what the report says.

Why this matters

A pricing error, a wrong quantity or a liquidation you did not expect has to be spotted and challenged within one day. If you were travelling, ill, or simply did not open the email, the report stands.

Exhibit 4CriticalHarder than usual1 days

Nasabah diberikan waktu 1x24 (satu kali dua puluh empat) jam untuk melakukan sanggahan apabila nasabah menganggap laporan transaksi tersebut tidak sesuai.
Clause MEKANISME TRANSAKSI ELEKTRONIK in Peraturan dan Ketentuan Transaksi Penyaluran Amanat Luar Negeri Produk Saham Tunggal Asing (PALN)
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026One day to challenge a US stock transaction report (clause MEKANISME TRANSAKSI ELEKTRONIK)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must run a published complaints procedure and must give a retail client a reasonable period to raise a complaint, normally measured in months. These rules measure it in hours.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 11A short objection window matters more when the broker's own records are the evidence you agreed not to question.
05

Pluang can freeze your account temporarily or permanently on a long list of grounds, one of which is simply that it suspects something has happened which, in its view, could harm it, you or somebody else. If you send it clear evidence that the freeze was wrong, the contract still says Pluang alone decides whether to lift it.

Why this matters

Your money can be locked in the app while Pluang reviews it, and the contract sets no deadline for that review. Proving you did nothing wrong does not entitle you to your account back.

Exhibit 5CriticalHarder than usual

Jika Akun Anda dibekukan dan Anda memiliki bukti yang jelas bahwa Akun Anda seharusnya tidak dibekukan, Anda dapat membuat Laporan kepada Kami untuk menyampaikan bukti-bukti tersebut. Setelah melakukan pemeriksaan lebih lanjut terhadap Laporan Anda, Kami akan, atas kebijakan Kami sepenuhnya, menentukan untuk mengakhiri atau melanjutkan pembekuan terhadap Akun Anda.
Clause Pembekuan Akun in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026Frozen on suspicion, unfrozen only if Pluang decides to (clause Pembekuan Akun)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must give a retail client access to an independent complaints body when they refuse access to funds. Here the internal decision is the end of the road inside the contract, although Indonesian clients can still escalate to OJK.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

06

The Pluang fee page quotes 0,15% to take a crypto price and 0,10% to make one. The only figure that binds anyone is in the crypto rules, and it is a ceiling of 50bps, which is 0,5%. The same rules say every fee lives on a web page and can change whenever the company decides.

Why this matters

Pluang can raise your trading cost to more than three times the advertised rate without amending a contract or asking you. You find out by looking at the fee page again.

Exhibit 6WarningHarder than usual0.5%

Biaya transaksi maksimal yang diterapkan oleh BSC sebagai PAKD yaitu 50bps dari total jumlah transaksi.
Clause IX.6 in Peraturan dan Ketentuan Perdagangan Aset Crypto dan Crypto Futures
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026The crypto fee you are quoted is a promotion, not a promise (clause IX.6)Visit this page on the broker's siteDownload the full size image file

What it costsA Rp10.000.000 crypto purchase costs Rp15.000 at the advertised taker rate of 0,15%. At the 0,5% the rules permit, the same purchase costs Rp50.000.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must disclose the actual costs and charges to a retail client before that client trades. This contract discloses a maximum and points to a page that can move underneath you.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Same clause as Exhibit 7Both product rule books state a maximum where the marketing states a price.

Pluang's 0% daily leverage fee runs for 30 days and stops at $30

The Pluang leverage page headline promises 4x buying power with a 0% daily leverage fee. The same page puts the real rate at 0,0208% a day for regular users and caps the free period at 30 days and $30. The PALN rules that govern the product allow margin interest of up to 12% a year.

Headline and footnote1 clause flagged

The leverage page headline offers 4x buying power with 0% daily leverage fee, marked with an asterisk. Further down the same page, the real rate is 0,0208% a day for regular users, and the 0% deal runs for 30 days and caps at $30. The PALN rules allow margin interest of up to 12% a year.

Why this matters

Holding a leveraged US stock position overnight costs you money every day, including weekends. Pluang says so on the same page it says the fee is zero.

Exhibit 8WarningHarder than usual12%

Bunga: Maximum 12% p.a. Untuk transaksi menggunakan margin
Clause Biaya Transaksi Saham in Peraturan dan Ketentuan Transaksi Penyaluran Amanat Luar Negeri Produk Saham Tunggal Asing (PALN)
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Our own capture of pluang.com, taken on Sep 16, 2026The claim, on Leverage feature page, main headline under the title Maksimalkan keuntungan dengan Leverage!Visit this page on the broker's siteDownload the full size image file
Our own capture of pluang.com, taken on Sep 16, 2026What the contract says, clause Biaya Transaksi SahamVisit this page on the broker's siteDownload the full size image file

What it costsA $5,000 leveraged position held for a year at 0,0208% a day costs about $380 in daily fees. At the 12% a year the rules permit it would cost $600.

Every Pluang fee page quotes a price, and every contract quotes a ceiling

Pluang advertises a 0,15% crypto taker fee and a 0,30% US stock commission. The contracts behind them say 50bps, which is 0,5%, and 1% plus 11% VAT. In both cases the binding number is a maximum roughly three times the advertised rate, and the crypto rules add that fees can change at any time in line with company policy.

Cost disclosure1 clause flagged

Pluang's leverage page puts the US stock transaction fee at 0,30% for regular users. The PALN rules that actually govern those trades set the commission at up to 1% of notional plus 11% VAT, and options carry a minimum of $5 per trade. Regulatory charges sit on top and can change at any time.

Why this matters

The rate you were shown is not the rate you agreed to, and the 11% tax on top of it appears on no marketing page. On an app that lets you trade from $1, a $5 minimum options fee can cost more than the trade.

Exhibit 7WarningHarder than usual1%

Komisi Transaksi: maximum 1% dari notional dan dibulatkan kepada satuan sen terdekat + 11% PPN
Clause Biaya Transaksi Saham in Peraturan dan Ketentuan Transaksi Penyaluran Amanat Luar Negeri Produk Saham Tunggal Asing (PALN)
Downloaded from the broker's site on Open the reference
Our own capture of pluang.com, taken on Sep 16, 2026The claim, on Leverage feature page, comparison table of 2x and 4x leverage costsVisit this page on the broker's siteDownload the full size image file
Our own capture of pluang.com, taken on Sep 16, 2026What the contract says, clause Biaya Transaksi SahamVisit this page on the broker's siteDownload the full size image file

What it costsA $1,000 US stock trade costs $3 at the advertised 0,30%. At the 1% the rules permit it costs $10, and the 11% VAT takes it to $11,10.

Seven exchange days for mutual fund money, and staked crypto does not move at all

PT Sarana Santosa Sejati has up to seven exchange days to send mutual fund sale proceeds to your bank, and a sale placed after 13.00 Jakarta time is priced the next exchange day. Staked crypto is locked and cannot be sold, transferred or withdrawn until the staking period and unbonding both finish. The yield that persuaded you to lock it can change at any time without notice.

Getting money out2 clauses flagged

When you sell mutual fund units, PT Sarana Santosa Sejati has up to 7 exchange days to send the money to your bank. Sell after 13.00 Jakarta time and you are priced at the next exchange day's value, which adds another day before the clock even starts.

Why this matters

Money you asked for on a Friday afternoon can take most of two weeks to arrive once weekends and Indonesian public holidays are counted. The contract gives you no faster option and no compensation for the wait.

Exhibit 10WarningHarder than usual7 working days

Hasil penjualan hanya akan dikirimkan ke rekening Pengguna pada Bank yang tercatat pada Kami maksimal 7 (tujuh) Hari Bursa.
Clause VI in Syarat dan Ketentuan Pembuatan Rekening dan Transaksi Reksa Dana, PT Sarana Santosa Sejati
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK)

Funds authorised by the FCA must pay redemption money within four business days of the valuation point. This contract allows seven exchange days.

Pluang is not licensed by this regulator, so this is a comparison of practice, not a finding of any breach.

While your crypto is staked it cannot be sold, transferred, pledged or withdrawn in any form until the staking period ends and unbonding completes. The advertised yield is indicative only and can change at any time without prior notice. PT Bumi Santosa Cemerlang also takes a service fee out of your rewards before you see them, at a rate the rules never state.

Why this matters

You cannot sell while the price is falling, because the asset is locked and unstaking is not instant. The yield that persuaded you to lock it can be cut the next day, and the fee that reduces it is never quoted.

Exhibit 14WarningHarder than usual

Selama Periode Staking, Aset Kripto yang telah dialokasikan untuk keperluan Staking akan berada dalam status terkunci. Oleh karena itu, tidak dapat diperjualbelikan, di transfer, dialihkan kepemilikannya, dijanjikan, atau ditarik dalam bentuk apapun hingga berakhirnya Periode Staking dan/atau di selesaikannya seluruh proses unbonding, sebagaimana disyaratkan oleh protokol blockchain yang berlaku.
Clause X.1 in Peraturan dan Ketentuan Perdagangan Aset Crypto dan Crypto Futures
Downloaded from the broker's site on Open the reference

Pluang decides when you trade, when you stop and when you get your account back

PT PG Berjangka can close your US stock positions at a 30% margin level without asking, and your stop loss price stops applying when it does. PT Bumi Santosa Cemerlang can freeze your account on suspicion and decides alone whether to lift the freeze, even after you produce clear evidence. Twelve separate rule books govern your account, each of them changeable at any time, and each one overriding the app terms where they differ.

Broker discretion4 clauses flagged

The crypto rules say you can pick leverage from 1x to 25x. Two clauses later, the margin tables in the same document are built around 50x, requiring 2% of notional to open and 0,5% to hold. Leverage multiplies both your gain and your loss against the money you actually put in.

Why this matters

The single number that decides how fast you can be wiped out appears twice in one contract with two different answers. At 50x, a 2% move against you takes your whole stake.

Exhibit 9WarningRarely seen25

Nasabah dapat memilih tingkat leverage mulai dari 1x hingga 25x.
Clause IX.5 in Peraturan dan Ketentuan Perdagangan Aset Crypto dan Crypto Futures
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), ESMA (EU)

The FCA bans the sale of crypto derivatives to retail clients altogether, and the ESMA rules cap retail leverage on cryptocurrency contracts at 2:1. This contract offers at least 25x.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Our readingRetail contracts usually state one leverage ceiling. Here the stated cap and the cap the margin formulas are built for differ by a factor of two, inside the same rule book.

  • Worse together with Exhibit 1High leverage is also the first criterion the exchange uses to pick whose winning position gets closed.

The mutual fund terms say plainly that they can change at any time without prior notice. The app terms add that if you keep using Pluang after a change, that counts as your agreement to it. Checking for changes is put on you, regularly and periodically.

Why this matters

A clause you read today can be replaced tomorrow without an email, and opening the app is treated as accepting it. To stay informed you would have to re-read twelve separate rule books on your own schedule.

Exhibit 12WarningHarder than usual

SK SSS dapat berubah sewaktu-waktu tanpa pemberitahuan terlebih dahulu.
Clause Perhatian in Syarat dan Ketentuan Pembuatan Rekening dan Transaksi Reksa Dana, PT Sarana Santosa Sejati
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must give a retail client advance notice of a change to the terms, normally with a period to object or leave. These documents require neither.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 13Silent amendment is heavier when twelve documents can each be amended silently.

Accepting the app terms also binds you to every product rule book and disclaimer Pluang links, and the app terms name 12 of them. Where a product rule book disagrees with the app terms, the product rule book wins.

Why this matters

The clauses that decide your liquidation price, your fee ceiling and your objection deadline are not in the document you agreed to. They are in separate rule books you have to find, open and re-read yourself.

Exhibit 13WarningHarder than usual12

Meskipun merupakan satu kesatuan, Ketentuan Layanan dari masing-masing Layanan akan berlaku dalam hal terdapat perbedaan dengan SK Pluang ini.
Clause Ketentuan Umum in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference

You give Pluang consent and authority that cannot be withdrawn to move, transfer or reassign some or all of the money and assets in your account to its affiliates. The listed purposes include tax, transaction fees, administration fees and other service fees. The same clause promises Pluang will keep those assets safe and still recorded as yours.

Why this matters

Money you deposited with one licensed company can be moved to another company in the group without asking you again. You cannot take that permission back while you keep using the app.

Exhibit 15WarningHarder than usual

Dengan menyetujui SK Pluang ini, Anda dengan ini memberikan persetujuan dan kuasa yang tidak dapat ditarik kembali kepada Pluang untuk memindahkan, mentransfer, menyalurkan, atau mengalihkan sebagian atau seluruh dana dan/atau aset yang terdapat dalam Akun Anda kepada afiliasi Kami untuk tujuan pemenuhan transaksi, termasuk namun tidak terbatas pada pemotongan pajak, biaya transaksi, biaya administrasi, dan/atau biaya layanan lainnya, yang dilakukan oleh Anda melalui Aplikasi Pluang atau sesuai jumlah biaya dan pajak yang diberitahukan di dalam Aplikasi Pluang.
Clause Akses, Pembatasan Akses, dan Penghentian Akses in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must hold retail client money in segregated accounts and must not use it for their own purposes. Here the safeguard is a promise inside the same clause that grants the power.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

One day to object, and the records you would argue with belong to Pluang

The PALN rules give you 24 hours to challenge a US stock transaction report, after which the rules offer no other route. The mutual fund terms have you agree in advance not to contest the validity, truth or authenticity of PT Sarana Santosa Sejati's own records of your instructions. Indonesian clients can still escalate to OJK and the LAPS SJK dispute body, which sits outside these clauses.

Complaint deadlines1 clause flagged

Everything PT Sarana Santosa Sejati stores about your instructions counts as valid evidence, and you agree in advance not to contest its validity, its truth or its authenticity. That covers written documents, recordings, tapes, computer print outs and copies.

Why this matters

If you say you never placed an order and the broker's log says you did, you have signed away the argument. The only record of what happened belongs to the party you are arguing with.

Exhibit 11WarningHarder than usual

Catatan atau rekaman atas perintah dari Pengguna kepada Kami dan komunikasi lain antara Kami dengan Pengguna melalui layanan Transaksi Reksa Dana yang tersimpan pada pusat data Kami dan atau tersimpan dalam bentuk penyimpanan informasi dan data lainnya di situs/aplikasi yang disediakan oleh SSS maupun Gerai, baik berupa dokumen tertulis, catatan, tape/cartridge, print out komputer atau salinan, merupakan alat bukti yang sah yang tidak akan dibantah keabsahannya, kebenaran, atau keasliannya.
Clause VI in Syarat dan Ketentuan Pembuatan Rekening dan Transaksi Reksa Dana, PT Sarana Santosa Sejati
Read from the broker's site on Open the reference

Pluang collects your contacts' phone numbers, and the English policy omits where data goes

The Pluang app terms define your personal data to include religion, health data and the phone numbers of people in your contact list who are not users. All five privacy policies carry a section IX where the Indonesian paragraph discloses transfers of your data outside Indonesia and the English paragraph beneath it discusses something else entirely. Withdrawing your consent to any of it closes your account.

What Pluang keeps3 clauses flagged

The app terms define your personal data to include your religion, your health data, your biometric data, and the phone numbers of people in your mobile contact list who are not Pluang users. That definition sits in the trading terms, not in the privacy policy.

Why this matters

Friends and family who never signed anything can have their numbers collected because they are in your phone. You cannot consent on their behalf, and the contract does not ask you to try.

Exhibit 16WarningRarely seen

Data Pribadi meliputi, nama, alamat, tanggal lahir, pekerjaan, nomor telepon, agama, status perkawinan, alamat email, rekening bank dan rincian kartu kredit, jenis kelamin, identifikasi (termasuk paspor atau dokumen identitas nasional) dan/atau tanda pengenal lainnya yang dikeluarkan pemerintah, informasi kendaraan, foto, kewarganegaraan, nomor telepon Anda dan non-Anda di daftar kontak telepon seluler Anda, data kesehatan, informasi terkait keuangan, dan informasi biometrik.
Clause Definisi in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference

Our readingBroker contracts routinely define personal data as identity, contact and financial details. Extending the definition to the phone numbers of non customers taken from the customer's own contact list, alongside religion and health data, is not ordinary in a trading agreement.

All five Pluang privacy policies are written in two columns, Indonesian then English. The Indonesian paragraph in section IX says your personal data may be transferred, stored or processed outside Indonesia. The English paragraph directly beneath it is not a translation of that at all: it talks about anonymising data for artificial intelligence development.

Why this matters

If you read the English column, you are never told your data leaves the country. The heading carries the same fault, and the error repeats in all five privacy policies.

Exhibit 17WarningRarely seen

Mengingat infrastruktur teknologi Kami mungkin melibatkan fasilitas di luar Indonesia (seperti peladen/server pihak ketiga), Data Pribadi Anda dapat ditransfer, disimpan, atau diproses di luar wilayah Republik Indonesia.
Clause IX in Kebijakan Privasi / Privacy Policy
Downloaded from the broker's site on Open the reference
Set against a regulated standard: ESMA (EU), FCA (UK)

Firms under the ESMA and FCA regimes must give data subjects clear information about transfers of personal data outside the home jurisdiction. One of the two language versions here carries no such information.

Pluang is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Our readingBilingual policies normally mismatch through clumsy translation. Here an entire substantive paragraph is replaced by unrelated text from the next section, so one language version discloses a cross border transfer and the other does not.

The app terms say that if you later withdraw your consent to Pluang sharing your information, you agree that your transactions cannot continue and your account will be closed. The privacy policy repeats the point in capitals, warning that using your deletion or restriction rights can suspend or end your access.

Why this matters

The data right the law gives you is priced at your account. Exercising it is the trigger for closure, not a request Pluang has to weigh against keeping you as a client.

Exhibit 18WarningHarder than usual

apabila di kemudian hari Anda menarik kembali persetujuan terhadap pemberian informasi kepada Kami, maka Anda menyatakan setuju bahwa transaksi Anda di Aplikasi Pluang tidak dapat dilanjutkan dan Akun Anda akan ditutup.
Clause Data Pribadi in Syarat dan Ketentuan Penggunaan Aplikasi Pluang
Downloaded from the broker's site on Open the reference

Five licensed Indonesian companies, and US stocks that are not shares

PT Bumi Santosa Cemerlang runs the Pluang app and is your counterparty for crypto only. Four other licensed companies stand behind mutual funds, gold, Indonesian shares and US stocks, and Pluang names all five in the footer of every page. What you hold when you buy a US stock is a derivative with the share as its underlying asset, recorded on the Jakarta Futures Exchange and cleared by Kliring Berjangka Indonesia.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Who you deal with2 clauses flagged

Buying Apple on Pluang does not give you an Apple share. PT PG Berjangka is licensed as a financial derivatives broker, and what you hold is a derivative contract with the share as its underlying asset, recorded on the Jakarta Futures Exchange under codes such as AAPL_PALN and cleared by Kliring Berjangka Indonesia.

Why this matters

Your position carries margin, margin interest and forced liquidation, which share ownership does not. Options are settled in cash, so no stock changes hands at any point.

Exhibit 19WarningStandard wording

Saham AS, ETF, dan Options difasilitasi oleh PT PG Berjangka sebagai Perantara Pedagang Derivatif Keuangan yang berizin dan diawasi oleh Otoritas Jasa Keuangan (OJK) untuk produk derivatif keuangan dengan aset dasar berupa Efek. Transaksi dicatat pada Jakarta Futures Exchange (JFX) dan Kliring Berjangka Indonesia (KBI).
Clause Footer in Syarat dan Ketentuan Pembuatan Rekening dan Transaksi Reksa Dana, PT Sarana Santosa Sejati
Read from the broker's site on Open the reference
  • Only applies after Exhibit 2The forced liquidation rules only exist because the product is a margined derivative rather than a share you own outright.

PT Bumi Santosa Cemerlang runs the Pluang app and is your counterparty for crypto only. US stocks go through PT PG Berjangka, mutual funds and Indonesian share marketing through PT Sarana Santosa Sejati, gold through PT Pluang Emas Sejahtera, and Indonesian shares through PT Pluang Maju Sekuritas.

Why this matters

Which company owes you money depends on which tab you were in. Pluang names all five in the footer of every page, which is more than most brokers disclose.

Exhibit 20NoticeStandard wording5

Pluang adalah aplikasi finansial yang dikelola dan dikembangkan oleh PT Bumi Santosa Cemerlang, dengan misi membuka akses lebih luas terhadap beragam kelas aset melalui produk investasi mikro secara mudah, aman, dan terjangkau bagi masyarakat Indonesia.
Clause Footer in Syarat dan Ketentuan Pembuatan Rekening dan Transaksi Reksa Dana, PT Sarana Santosa Sejati
Read from the broker's site on Open the reference

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The FAQ tells you a margin call leaves you free to sell your own position, and stops before the clause where PT PG Berjangka sells it for you at 30%.

Said in public, in Indonesian

Margin call adalah situasi di mana ekuitas kamu berada di 70% margin yang dipakai, atau di bawahnya. Situasi ini akan terjadi apabila harga aset yang kamu beli telah turun ke level di mana ekuitas kamu berada di 70% atau di bawahnya. Setelah kamu terkena margin call, kamu tidak dapat membuka posisi baru, namun, kamu kamu masih dapat menjual posisimu.

Word for word in English: A margin call is a situation where your equity is at 70% of the margin used, or below it. This situation will happen if the price of the asset you bought has fallen to a level where your equity is at 70% or below. After you get a margin call, you cannot open new positions, but you can still sell your position.

Leverage feature page, FAQ answer to the question Apa itu Margin Call?

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of pluang.com

In the contract · clause Force Liquidation

Apabila Margin Level mencapai level 30% atau di bawahnya, maka pialang PALN dapat melikuidasi sebagian atau semua posisi nasabah tanpa memerlukan persetujuan nasabah (Force Liquidation).

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of pluang.com

02

The fee page quotes 0,15% to take a price while the binding rule book sets a ceiling of 0,5%, more than three times higher.

Said in public, in Indonesian

Taker

Word for word in English: Taker

Crypto fees page, Biaya Transaksi table, where the taker fee is listed as 0,15%

In the contract · clause IX.6

Biaya transaksi maksimal yang diterapkan oleh BSC sebagai PAKD yaitu 50bps dari total jumlah transaksi.

03

The page quotes 0,30% with no tax, and the PALN rules allow 1% plus 11% VAT on top.

Said in public, in Indonesian

Biaya transaksi (0,30% untuk pengguna reguler, 0,20% untuk Pluang Plus)

Word for word in English: Transaction fee (0.30% for regular users, 0.20% for Pluang Plus)

Leverage feature page, comparison table of 2x and 4x leverage costs

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of pluang.com

In the contract · clause Biaya Transaksi Saham

Komisi Transaksi: maximum 1% dari notional dan dibulatkan kepada satuan sen terdekat + 11% PPN

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04

The 0% daily leverage fee is a 30 day promotion capped at $30, while the rules permit margin interest of up to 12% a year.

Said in public, in Indonesian

Dapatkan hingga 4x daya beli di 650+ Saham AS dan ETF dengan 0% biaya harian leverage.*

Word for word in English: Get up to 4x buying power on 650+ US Stocks and ETFs with a 0% daily leverage fee.*

Leverage feature page, main headline under the title Maksimalkan keuntungan dengan Leverage!

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of pluang.com

In the contract · clause Biaya Transaksi Saham

Bunga: Maximum 12% p.a. Untuk transaksi menggunakan margin

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of pluang.com

The documents this reading is based on

17 files, all published by Pluang. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording Pluang publishes.

How this reading was done

Every clause above was read out of a document Pluang publishes itself

This reading was published on .

Documents
3 of 17downloaded from the broker's site, and 3 read in full
Pages opened
26pages walked to find those documents, footer links included
Marketing pages
11public pages set against what the contract says

Who the contract is with

PT Bumi Santosa Cemerlang

PT Bumi Santosa Cemerlang owns and runs the Pluang app, and it is your counterparty for crypto and crypto futures. It is not your counterparty for anything else you buy in that app. US stocks, ETFs and options go through PT PG Berjangka, mutual funds through PT Sarana Santosa Sejati, gold through PT Pluang Emas Sejahtera, and Indonesian shares through PT Pluang Maju Sekuritas. Each of the five holds its own licence and publishes its own privacy policy, so a complaint about gold is not a complaint against the company whose name is on the app.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

Pluang publishes more than most brokers do. The crypto fee page gives maker, taker and exchange fees as real figures, with a worked example in rupiah underneath them. The crypto rules print the whole margin ladder with its formulas and a filled-in liquidation table. Every page footer names which licensed company runs each product, which exchange records it and which clearing house guarantees it. Indonesian clients get Indonesian law, Indonesian courts, and escalation to OJK and the LAPS SJK dispute body, so nobody has to complain abroad. When a crypto asset is delisted, PT Bumi Santosa Cemerlang has a hard 30 day deadline to settle your holding.

We read the mutual fund terms, the analyst rating disclaimer and the Pockets disclaimer end to end. The app terms, the US stock rules and the five privacy policies were cut short, so we read roughly the first two thirds of each. We read the crypto and crypto futures rules on Pluang's own page, clause by clause rather than end to end, and every quotation credited to that document comes from that page. Six further rule books that the app terms make binding on you were not read at all: gold trading, Indonesian shares, gold instalments, the centralised wallet, USD Yield and recurring buy. No earlier version of any of these documents is available, so this is a first reading with nothing to compare against.

How to check any of this yourself

Every quote above links to the Pluang file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document Pluang publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge Pluang on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Sep 16, 2026.

If you represent Pluang and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on Pluang. Whether its licence is real and current is a separate check on the broker profile.

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