-
INTRODUCTION
1.1.Welcome to the terradataindonesia.id Website (the “Service”) operated by PT Terra Data Indonesia and its affiliates (individually and collectively also referred to as the “Company” or “we”). The Company takes its responsibilities under the applicable personal data laws and regulations (“Personal Data Laws”) seriously and is committed to respecting the privacy rights and concerns of all partners as Users of the Service (collectively referred to as “you”, “your”, “User” or “yours”).
We recognize the importance of the personal data that you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (the “Privacy Policy” or the “Policy”) is designed to help you understand how we collect, use, disclose and/or process the personal data that you have entrusted to us and/or that we possess about you, both now and in the future, and to help you make informed decisions before providing your personal data to us.1.2.“Personal Data” means any information that can be used to identify you or from which you can be identified. This includes but is not limited to username and email address.1.3.By using the Service or accessing the Service, you acknowledge and agree that you accept the practices, terms, and/or policies outlined in this Privacy Policy, and you hereby permit us to collect, use, disclose and/or process your personal data as described herein.1.4.We specifically collect, use, disclose, or process your Personal Data in accordance with this Privacy Policy with your consent, or in accordance with applicable laws, such as where:- we are required to comply with legal requirements;
- we are required to enter into or perform a contract with you; and/or
- for our legitimate interests or the legitimate interests of others, including but not limited to the purposes set out in this Privacy Policy.
1.5.If we change our Privacy Policy, we will post the changes or the amended Privacy Policy on our Service. We reserve the right to change this Privacy Policy at any time. -
COLLECTION OF PERSONAL DATA
We collect (and may combine) Personal Data about you in the ways listed below:
2.1.You provide your Personal Data to us
We collect your Personal Data when you provide it to us. For example, when you:- Verify your identity through various means (such as entering your name, telephone number and email address).
2.2.When our Service is used
Personal Data may be collected through the normal operation of our Service and/or the use of our Service. Some examples are:- Your location information;
- Actual or estimated location data such as IP address, Wi-Fi location and geo-location;
- Data in the form of the time of each User activity in connection with the use of the Service;
- Usage data or User preferences, including User interactions in using the Service, saved choices, and selected settings. Such data is obtained using cookies, pixel tags, and similar technologies that create and maintain unique identifiers;
- Device data, including the type of device used to access the Service, including hardware model, operating system and version, software, IMEI number, file name and version, language preferences, unique device identifier, advertising identifier, serial number, device movement information, and/or mobile network information; and/or
- Log data, including records on servers receiving data such as device IP address, date and time of access, or pages viewed, and other system activities, browser type, and/or third-party services used by the User.
2.3.Data obtained from other sources, including but not limited to:- Data in the form of geo-location (GPS) from our business partners who also assist us in developing and providing the Service to Users, including payment service provider partners, Service infrastructure providers and other partners.
- Data in the form of email, telephone number, name from our business partners where Users create or access your account, such as social media services, or Services that use our application programming interface (API) or that we use;
- Data in the form of email from marketing service providers.
-
PERSONAL DATA TO BE COLLECTED BY US
3.1.Personal data that may be collected by us includes but is not limited to:
- Name;
- Telephone number;
- Email address;
- Any other information about the User when the User uses the Service, as well as information relating to how the User uses our Service.
3.2.You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We have the right, at our discretion, to require further documentation to verify the information you provide. -
USE OF PERSONAL DATA
The Company may use the Personal Data obtained and collected from Users as mentioned in the previous section for the following matters:
4.1.Process all forms of requests and activities carried out by Users through the Service.4.2.Provision of features to provide, realize, maintain and improve our products and services, including:- carrying out internal activities necessary to provide the Service, such as troubleshooting software, bugs, operational issues, conducting data analysis, testing, and research, and to monitor and analyze usage trends and activities.
4.3.Assist Users when communicating with the Company's Customer Service, including:- checking and resolving User issues;
- directing User inquiries to the appropriate customer service personnel to resolve issues;
- monitoring and improving the Company's customer service responses;
- contacting Users via email and other communication methods, including but not limited to, to assist and/or resolve transaction processes and problem resolution processes, as well as to deliver news or other notifications in connection with the protection of User Personal Data by the Company, including failures in the protection of User Personal Data;
- using information obtained from Users for product research, analysis, development and testing purposes to improve the security of the Service, as well as develop new features and products.
4.4.In certain circumstances, the Company may need to use or disclose User Personal Data for law enforcement purposes or to fulfill applicable legal and regulatory requirements and obligations, including in the event of a dispute or legal proceedings between the User and the Company, or suspected criminal acts such as fraud or data theft.4.5.Fulfillment of applicable legal and regulatory requirements and obligations in connection with taxation interests in Indonesia.4.6.Facilitate merger transactions, sale of company assets, consolidation or restructuring, financing or acquisition involving the Company. -
DISCLOSURE TO THIRD PARTIES
5.1.Your Personal Data may be transmitted, assessed or disclosed to third parties for the Purposes (as defined below) and additional Purposes. Furthermore, we may use other companies, service providers or individuals to perform functions on behalf of the Company, and at the same time may provide access to or disclose your Personal Data to third parties.5.2.Third parties include, but are not limited to:
- Our partners, including but not limited to parties with whom we cooperate for certain events, programs and activities, such as in credit scoring processing activities, risk analysis and provision of related services;
- Advertising companies;
- Company affiliates;
- Event management companies and event sponsors;
- Marketing research companies;
- Service providers, including information technology service providers for infrastructure, software and development work;
- Professional advisors and external auditors, including legal advisors, financial advisors and consultants;
- Other entities within the Company; and
- Competent authorities, law enforcement or government authorities to comply with applicable laws and regulations.
-
COOKIES
6.1.Cookies are small files that will automatically take place on the User's device which function to store User preferences and configurations while visiting the Service.6.2.Such Cookies are not intended to be used when accessing other data owned by the User on the User's computer device, other than those that the User has agreed to provide.6.3.Although the User's computer device will automatically accept cookies, the User may choose to modify this through the User's browser settings by choosing to reject cookies (this option may hinder the optimal availability of the Company's services when the User accesses the Service).6.4.The Company may use features provided by third parties in order to improve the Company's services and content, including assessment, customization, and delivery of advertisements to each User based on interests or visit history. If the User does not want advertisements to be displayed based on such customization, the User may adjust this through the browser.
-
USER CHOICE AND TRANSPARENCY
7.1.Users may change information in the form of personal data by submitting a request to the Company through the group Whatsapp service and/or email address [email protected] listed on the Website.7.2.To the extent not contrary to applicable laws and regulations, Users may contact the Company to withdraw consent to the acquisition, collection, storage, management and use of User data. In such event, the User understands the consequence that the User will not be able to use the Service or other Company services.
-
DATA CONFIDENTIALITY
The User agrees and guarantees that all information and data provided and/or presented by the Company in the Service will not be used, distributed, or sold to other Parties. The User guarantees that any data and information provided may only be used for transaction monitoring purposes and may only be processed for informational purposes used internally by the User. In the event that the User wishes to disclose information and data in the Service to a third party, the User is required to obtain written approval from the Company. The User understands, acknowledges, and is responsible for the legal consequences that may arise from violations of this data confidentiality, including but not limited to compensation, civil claims, and criminal claims.
8.1.The User must keep confidential all confidential information relating to the Company, services, products, business affairs, marketing and promotional plans or other operations and related companies disclosed to the User by or on behalf of the Company (whether orally or in writing, disclosed before, on or after the date of this Privacy Policy and User Terms & Conditions) or that is directly or indirectly obtained by the User from the Company, or its affiliated companies. The User must ensure that the User only uses such confidential information to perform the Service, and will not disclose such information to any third party or use it for any other purpose without the Company's written consent. The Company will only disclose such information to third parties on a need-to-know basis and after obtaining permission from the owner of the data and information to fulfill its obligations under this Agreement.8.2.The confidentiality obligations do not apply to the extent that the User can demonstrate that such information:- was already in the User's possession at the time of receipt;
- is, or becomes in the future, known to the public through no fault or negligence of the User;
- is received from a third party that has the right to disclose it; or
- is required to be disclosed by law.
-
SECURITY, STORAGE AND RETENTION OF USER PERSONAL DATA
9.1.The Company protects all User Personal Data stored in its systems, as well as protects such data from unauthorized access, use, modification, retrieval and/or disclosure by using a number of security measures and procedures.9.2.User Personal Data may also be stored or processed outside the country by parties working for the Company in other countries, or by third-party service providers, vendors, suppliers, partners, or affiliates of the Company. In such case, the Company will ensure that such Personal Data remains protected in accordance with the Company's commitments in this Privacy Policy.9.3.Although the Company has used its best efforts to secure and protect User Personal Data, it should be noted that data transmission over the internet is never completely secure. Accordingly, the Company cannot guarantee 100% the security of data provided or transmitted to the Company by the User and the provision of information by the User is at the User's own risk.9.4.The Company will delete and/or anonymize User Personal Data under the Company's control if (i) the User Personal Data is no longer required to fulfill the purposes of its collection; and (ii) retention is no longer required for compliance with applicable laws and regulations, upon the User's prior written request.9.5.You may have various rights in relation to your Personal Data under Applicable Law. If you wish to exercise your rights, you may submit a data subject rights request to us by contacting us at the contact details available in this Privacy Policy. In particular, for your account deletion request, you may do so through customer service via the group and/or Whatsapp between the Company and the User, as well as by email to [email protected].9.6.Please note that there is still a possibility that some User Personal Data may be stored by other parties, including authorized state institutions. In the event that we share User Personal Data with authorized state institutions and/or other institutions that may be designated by the authorized government or have cooperation with the Company, the User agrees and acknowledges that the storage of User Personal Data by such institutions will follow the respective data retention policies of such institutions.
-
PERSONAL DATA PROTECTION
10.1.The User agrees and permits the Company to use and process the User's personal data for the Purposes and in the manner identified below.10.2.For the purposes of this Privacy Policy, “Personal Data” means information about the User, from which the User can be identified, including but not limited to name, ID card number, Taxpayer Identification Number (NPWP), address, telephone number, email address, User information that the User has provided to the Company in registration forms or other similar forms and/or information about the User that has been or may be collected, stored, used and processed by the Company from time to time and includes sensitive personal data such as data relating to health, religion or other similar beliefs.10.3.The provision of User Personal Data is voluntary. However, if the User does not provide personal data to the Company completely and causes the Company to be unable to process the User's personal data for the purposes described below, this may result in the Company being unable to accept the User to use the Company's Service.10.4.The Company may use and process Personal Data for the Company's business and activities which include, but are not limited to, the following (“Purposes”):
- To provide the User with any services in accordance with these User Terms & Conditions;
- To process the User's participation in promotional events, activities, focus groups, research studies, contests, promotions, polls, surveys or productions and to communicate with the User regarding the User's attendance therein;
- Process, manage or verify the User's registration application for the Service in accordance with these User Terms & Conditions;
- To develop, improve and provide what is required in accordance with these User Terms & Conditions to meet the User's needs;
- To respond to questions, comments and feedback from Users;
- To communicate with Users for any of the purposes listed herein;
- For internal administrative purposes, such as audits, data analysis, database records;
- For the purposes of detecting, preventing and prosecuting criminal acts;
- To comply with official requests from any authorized state official;
- To send alerts, newsletters, updates, mailers, promotional materials, privileges, holiday greetings from the Company, its partners, advertisers and/or sponsors;
- To notify and invite Users to events or activities organized by the Company, its partners, advertisers, and/or sponsors;
- To share User Personal Data among the Company's group of companies consisting of affiliates, associated companies and/or entities jointly controlled by the parent company of the group (“Group”) and with the Company's third-party providers and Group Users, developers, advertisers, partners, event companies or sponsors who may communicate with Users in any manner.
10.5.Except for the purpose of fulfilling official requests from authorized state officials, if the User does not consent to the Company processing the User's personal data for any particular purpose, please notify the Company using the contact details provided in the Service.10.6.If any Personal Data provided by the User to the Company changes, for example, if the User changes the User's email address, telephone number, payment details or if the User wishes to cancel the User's account, the User may update the profile by submitting the User's request through the contact details provided in the Service.10.7.The Company will use its best efforts to make changes in accordance with the User's request within 14 (fourteen) working days from receipt of such notification.10.8.If there are differences in certain provisions relating to personal data protection in the Company's User Terms & Conditions with the Company's Privacy Policy, the Parties agree that the provisions in the Company's Privacy Policy shall apply, limited to the conflicting provisions, while all non-conflicting provisions shall remain in effect.By submitting the User's personal information to the Company, the User agrees to the use of such information as regulated in the submission form and User Terms & Conditions and this Privacy Policy.
-
ACCESS TO USER PERSONAL DATA
11.1.The Company takes reasonable steps to ensure that User Personal Data is processed accurately and completely. However, it is important for Users to promptly notify the Company of any changes to User Personal Data or if there are errors in User Personal Data under the Company's control.
-
COMPLAINTS REGARDING USER DATA PROTECTION
12.1.If the User has concerns about the Company's handling or treatment of User Personal Data or if the User believes that their privacy has been violated, the User may contact the Company through the Company's customer service or the Company's contact details listed in this Privacy Policy by explaining the User's identity and the nature of the User's complaint.12.2.The Company will investigate the User's complaint and endeavor to provide a response to the complaint within a reasonable period after receiving the complaint submitted by the User.
-
CONTACT US
If the User has any questions, comments, complaints, or claims regarding this Privacy Policy or the User wishes to obtain access to and/or correct their Personal Data, please contact customer service through the group and/or Whatsapp between the Company and the User, as well as by email to [email protected].
-
INFORMATION RETENTION
Your Personal Data will only be retained for as long as necessary to fulfill the purposes for which it was collected and/or for as long as such retention is required or permitted under Applicable Law. We will delete or anonymize your Personal Data promptly once its retention is deemed no longer appropriate in accordance with the provisions set out herein.Please note that some of your Personal Data may still be retained by other parties, including by government agencies in certain ways. In the event that we share your Personal Data with authorized government agencies and/or other institutions that may be designated by government authorities or cooperate with us, you agree and acknowledge that the retention of your Personal Data by such relevant institutions will follow their respective policies on data retention.To the extent permitted by Applicable Law, you agree to indemnify, defend and hold us harmless from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal fees and expenses on a full indemnity basis) arising directly or indirectly from any activity carried out outside our Service.We will retain information in accordance with the applicable laws and regulations in Indonesia.
-
INFORMATION ABOUT CHILDREN
The Service is not intended for children under the age of 17. We do not knowingly collect or maintain any personal data or non-personal information from anyone under the age of 17 and no part of our Service is intended for children under the age of 17. As a parent or legal guardian, please do not permit children under your care to submit personal data to the Company. In the event that personal data of children under the age of 17 under your care is disclosed to the Company, you hereby consent to the processing of such child's personal data and accept and agree to be bound by this Privacy Policy on behalf of such child. We will close any account used exclusively by such children and will remove and/or delete any personal data that we believe was submitted without the consent of a parent or legal guardian by a child under the age of 17.
-
UPDATES TO THE PRIVACY POLICY
The Company may at any time make changes or updates to this Privacy Policy as part of compliance with laws and regulations and the Company's internal policies. The Company will notify Users of any changes and/or updates to this Privacy Policy through mechanisms at the Company's discretion.