Privacy Police
PRIVACY POLICY
The SMEs Pack Privacy Policy is an explanation regarding SMEs Pack Users' personal data and information, including:
Definition
Applicable Laws and Regulations;
Data Acquisition and Protection;
Use, Storage, Utilization and Processing of Data;
Data Deletion;
SMEs Pack Limitation of Liability;
Changes to the Privacy Policy;
Intellectual property rights
Cookies; And
Kontak SMEs Pack.
References to SMEs Pack in this Privacy Policy may mean PT. Cipta Satukarya Indonesia Maju (“ SMEs Pack ”), SMEs Pack affiliates, group companies, and SMEs Pack subsidiaries, including SMEs Pack Representatives, namely financial, insurance, legal, accounting or other SMEs Pack advisors who provide services professionals to SMEs Pack, and third parties who collaborate with SMEs Pack, including but not limited to partners, vendors, farmers and end users.
SMEs Pack reserves the right from time to time to update this Privacy Policy to remain relevant and current with changing technology, applicable laws, evolving SMEs Pack business practices and the needs of SMEs Pack users. If any changes are made to this Privacy Policy, SMEs Pack will provide a "Last Updated Date". SMEs Pack encourages SMEs Pack Users to periodically review this Privacy Policy to stay informed about how SMEs Pack manages your personal data and information. By using the SMEs Pack platform Services, Users are deemed to have given explicit consent to the Privacy Policy and by continuing to use the Services after the Privacy Policy, Users are deemed to have agreed to the updated Privacy Policy.
DEFINITION
" Users " are parties who access the SMEs Pack platform services, including but not limited to clients, partners or other parties who simply visit the SMEs Pack platform.
“ SMEs Pack Platform ” is the official SMEs Pack website and applications that can be accessed via the User's computer and/or mobile device
“ Services ” means (i) the SMEs Pack Platform; (ii) Any content, features, services and functionality made available on or through the Platform by or on behalf of SMEs Pack.
“ SMEs Pack System ” means the system developed and operated by SMEs Pack, including but not limited to the SMEs Pack Platform.
“ SMEs Pack Representatives ” are directors, commissioners, employees, or third parties (including but not limited to external auditors or legal consultants) legally appointed by SMEs Pack to represent their interests.
“ Personal Information ” is data related to Users that can be identified and/or can be identified individually or combined with other information either directly or indirectly through electronic and/or non-electronic systems, including but not limited to when Users access platform services eFisheries.
“ Third Party Offers ” are various types of offers with marketing purposes carried out by parties collaborating with SMEs Pack.
“ Supervisory Agency ” is a government agency that supervises the SMEs Pack business sector, in this case including but not limited to the Ministry of Communication and Information.
“ Relevant Sector Regulator ” is the regulator that regulates the SMEs Pack business sector.
" Force Majeure " includes, among others, (i) strikes, company lockouts, and other industrial actions; (ii) civil commotion, riot, invasion, terrorist attack or threat, war (whether declared or not) or threat of war preparations; (iii) fire, explosion, storm, flood, earthquake, epidemic or other natural disaster; (iv) unavailability or disruption of telecommunications, information technology and/or electricity networks; (v) there is a system failure caused by a third party that occurs outside of SMEs Pack's authority; (vi) non-functioning of the banking system and/or network, (vii) actions, decisions, laws, regulations or restrictions issued by the government. In the event of a Force Majeure Event, SMEs Pack notifies the User no later than 14 (fourteen) Calendar Days after the occurrence of the Force Majeure Event and tries to the best of its commercial ability to fulfill SMEs Pack's obligations under this Privacy Policy.
" Calendar Day " is all days in 1 (one) month including holidays.
APPLICABLE LAWS AND REGULATIONS
SMEs Pack complies with all applicable laws and regulations of the government of the Republic of Indonesia, including those governing electronic information and transactions, the operation of electronic systems, and the protection of Users' personal data; including all implementing regulations and amendments to these regulations which regulate and protect the use of Users' important data and information.
ACQUISITION AND PROTECTION OF DATA
1. SMEs Pack has the right to request User data and information, including but not limited to:
a. Information regarding SMEs Pack accounts
(i) name
(ii) profile, including Date of Birth, Gender
(iii) address and/or location of residence
(iv) username
(v) password
(vi) email
(vii) telephone number
(viii) transaction, financial and/or banking information
b. User behavior on SMEs Pack and/or while using the Service Information on product, feature and service options. By providing the information in letters a and b above, Users waive their rights to claims, losses, demands and lawsuits that may occur regarding the acquisition, storage, use, utilization and/or disclosure of information, including personal information, in the SMEs Pack System.
2. Users hereby give explicit consent to the acquisition, storage, use, utilization, and/or disclosure of personal data and information that Users submit (input) into the SMEs Pack System, including Users' personal data, product photos, chats and conversations in the SMEs Pack system and the User hereby declares that giving consent to such personal data and information is done without coercion, in a competent condition, and with a conscious state, where the User gives such consent when creating an SMEs Pack account ("User Consent").
3. With the User's Consent, the User hereby declares that all data and information is the property of SMEs Pack. For the avoidance of doubt, the User's personal data, whether entered into the SMEs Pack System or not entered into the SMEs Pack System, belongs to the User as part of their complete personal rights.
4. The User hereby declares that the personal data that the User submits (inputs) into the SMEs Pack System (including documents uploaded and/or provided to SMEs Pack) is original, authentic, correct, accurate, complete, not misleading, up to date, and constitutes personal rights The User and/or he/she is authorized to submit the User's personal data to submit it to the SMEs Pack System.
5. SMEs Pack protects all information provided by Users when Users use all SMEs Pack services, including maintaining the confidentiality, integrity and availability of the personal data it manages.
6. SMEs Pack has the right from time to time to request authentication and updating of the User's personal data, so that the User's data and information is accurate, complete and up to date, including temporarily stopping the Service and/or permanently stopping the Service, in the event that the User has not authenticated and updated the User's personal data .
7. Users have the right from time to time to update the User's personal data.
8. Users hereby understand that the use of certain features in SMEs Pack requires further personal data authentication processes and is subject to the terms and conditions of certain features in SMEs Pack. The User hereby confirms that the User Consent is an explicit agreement to the acquisition, storage, use, utilization and/or disclosure of personal data that the User submits (inputs) into the SMEs Pack System and certain features in the SMEs Pack, and states that the use of such personal data is carried out without coercion, in a capable condition, and consciously.
USE, STORAGE, UTILIZATION AND PROCESSING OF DATA
1. SMEs Pack has the right to use User data and personal information to improve quality and services at SMEs Pack in accordance with applicable laws and regulations and based on User Agreement.
2. SMEs Pack has the right to use general and service usage information that has been collected to verify User data
3. SMEs Pack has the right to use transaction information to monitor and determine User transaction patterns, as well as for administrative purposes and investigative purposes or other purposes as required by statutory regulations
4. SMEs Pack has the right to use and store bank name information which includes name and account number, name and/or credit card number to ensure payment/receipt by SMEs Pack Users
5. SMEs Pack has the right to use the User's personal information in its entirety for know-your-customer ("KYC") purposes, internal data processing to ensure the service functions technically.
6. User information collected may be used to comply with applicable laws and regulations, investigate and resolve disputes, and other illegal activities, including if there are disputes with third parties
7. SMEs Pack has the right to use, utilize and disclose User personal data and information based on the User Consent, which the User has provided at the time of obtaining personal data, unless the following conditions occur, among others:
a. required and/or requested by authorized institutions based on applicable legal provisions, subpoenas, official orders from the Court, and/or official orders from the relevant agency or apparatus, including but not limited to disputes, investigations, inquiries, legal processes and resolution processes disputes between SMEs Pack and Users, between Users, and Users and other parties as well as other illegal activities;
b. required and/or requested by authorized banking, financial institutions, and/or third parties based on official requests and applicable legal provisions;
c. to process all forms of User activity including but not limited to processing transactions, payment verification, product delivery and so on
d. SMEs Pack may collaborate with companies and other third parties who facilitate or provide assistance in developing certain applications and services for and/or on behalf of SMEs Pack, including:
(i) provide User assistance;
(ii) provide geographic location information;
(iii) carry out services related to the Application (including but not limited to maintenance services and database management);
(iv) assist SMEs Pack in analyzing how the Application and Services are used and how they are developed; or
(v) to assist SMEs Pack's professional advisors and external auditors, including legal advisors, financial advisors and consultants. These third parties only have access to User Personal Information to perform these tasks for and/or on behalf of SMEs Pack and are contractually bound not to disclose or use such Personal Information for any other purpose;
e. In disclosing information, SMEs Pack may disclose some of the User's personal information so that the information becomes information that cannot identify the User as a whole (aggregate data/anonymous data) which is intended for third parties to be used for Application development, database management, analysis or service improvement, promotion and advertising;
f. SMEs Pack can also combine User Personal Information with other information in such a way that the information is no longer associated with the User, then disclose the combined information to third parties, for the purposes as in point e;
g. SMEs Pack can also combine User Personal Information with other information in such a way that the information is no longer associated with the User, then disclose the combined information to third parties, for the purposes as in point e;
h. SMEs Pack may disclose User information to SMEs Pack's subsidiaries, affiliates, partners and vendors to help provide services or manage data;
i. in an emergency that threatens a person's life, health or safety;
j. if necessary for a clear purpose in the interests of the User and the User's Consent cannot be obtained in a timely manner; or
k. as may be required or permitted by law.
8. SMEs Pack has the right to use, store, utilize and disclose personal data based on the User Consent that the User has provided at the time of obtaining personal data to:
a. provide Third Party Services and/or Offerings, for example:
(i) for purposes related to payment, billing, activation, provision, maintenance, support, troubleshooting, dispute resolution, deactivation, replacement, upgrade or renewal of the Services;
(ii) to better understand, analyze and predict User preferences and interests, and combine such information with other information to customize User experience;
(iii) to ensure the Services are technically functioning as intended and to help identify and resolve problems;
(iv) to facilitate User access and use of the Services and/or Third Party Offerings;
(v) to send subscription offers, messages and postings within the Service on behalf of Channel administrators or Official Accounts;
(vi) to combine such information with information obtained from other sources (including Third Party Offerings) in connection with providing the Services;
(vii) to comply with or enforce any Notices applicable to the Services;
(viii) to manage or respond to User inquiries;
b. develop new Services and improve existing Services and provide Users with information about third party content or related products, services and software including to communicate with Users about the various means they use, for example to provide or send to Users
(i) upgrades or updates, or notices of upgrades or updates, of the Services or third party content or related products, services and software;
(ii) notifications of upcoming promotions, contests, offers and events;
(iii) personal information, surveys, marketing materials, advertising or customized content;
c. collect, use and disclose for promotional and advertising activities which includes but is not limited to advertising identifiers, including those provided by other software platforms, or similar identifiers, to facilitate SMEs Pack in conducting analytics or providing promotional content or other information that may be relevant to Users ;
d. managing and developing SMEs Pack business and operations, for example:
(i) to detect, monitor, investigate, mitigate or prevent fraud and technical or security issues or to protect the property of SMEs Pack;
(ii) to enable business continuity and disaster recovery operations;
(iii) to obtain legal services, to seek legal advice and/or to enforce the legal rights of SMEs Pack or the legal rights of other members of SMEs Pack;
(iv) for statistical purposes;
e. meet legal and regulatory requirements and to respond to emergency situations, for example:
(i) to respond to a court order, subpoena or lawful request or other law enforcement or legal process;
(ii) to provide emergency assistance in situations that may threaten the life or physical safety of you or others;
f. SMEs Pack's internal interests for business, product, quality and service development including SMEs Pack's promotional activities, studies, research and collaboration with other third parties;
g. interests of SMEs Pack, SMEs Pack affiliates, group companies and SMEs Pack subsidiaries, for business development, products, quality and services including promotional activities, studies, research and SMEs Pack collaboration with other third parties
h. SMEs Pack's interests to fulfill transaction objectives on behalf of SMEs Pack, including in the event of the sale of all or part of SMEs Pack's assets including any purchase, sale, lease, merger or amalgamation or acquisition, disposal or financing of SMEs Pack, SMEs Pack affiliates, group companies and SMEs Pack subsidiaries
i. Other purposes communicated from time to time by SMEs Pack to the User, as well as permitted or required by applicable laws and regulations.
9. SMEs Pack has the right to store Users' personal data and information to fulfill the purposes of the Service, the purposes of this Privacy Policy, the purposes of applicable laws and regulations, including processing, transferring, and/or storing Users' data and information, both within the territory of the Republic Indonesia and outside the territory of the Republic of Indonesia, taking into account regulations, including laws and privacy policies in the country where Users' data and information is processed, transferred and/or stored.
10. SMEs Pack, SMEs Pack affiliates, group companies and SMEs Pack subsidiaries, including SMEs Pack Representatives, and third parties who collaborate with SMEs Pack, in providing the Services have the right to utilize and process Users' personal data and information to fulfill the purposes of the Services, the purposes of this Privacy Policy, the objectives of the applicable statutory and legal regulations. The use and processing of this data is covered by the agreement and contains a confidentiality clause that is binding on the parties. In this case, including SMEs Pack Representatives
11. SMEs Pack has the right to utilize and process User data and information to fulfill Transaction purposes on behalf of SMEs Pack, including the sale of all or part of SMEs Pack's assets including any purchase, sale, rental, merger or amalgamation or acquisition, disposal or financing of SMEs Pack, affiliates SMEs Pack, group companies and SMEs Pack subsidiaries.
12. SMEs Pack, in the use and processing of data, including data transmission, in accordance with the purposes of this Privacy Policy will implement reasonable security, in accordance with applicable laws and regulations, including providing encryption for the use and processing of such data.
DATA DELETION
1. Users can withdraw the User Consent provided regarding the use of the User's personal data and information, including ceasing use, accessing the Service, and/or closing the account by taking into account the provisions of applicable laws and regulations (including retention provisions required by applicable laws ). The User hereby states that the User understands the consequences of withdrawing the User Consent, including but not limited to no longer being able to enjoy the Service.
2. Users can request data deletion to SMEs Pack via [x] by attaching:
a. copy of court order;
b. valid proof of self (KTP/SIM/PASSPORT) according to his/her personal identity on the SMEs Pack account page; and/or
c. reason for the deletion request
3. SMEs Pack agrees to delete data submitted by the User if they have fulfilled the conditions in point 2 above and have fulfilled their rights and obligations at SMEs Pack, within a reasonable time.
4. SMEs Pack at the User's request can collect User data and information to make it anonymous.
LIMITATION OF LIABILITY SMEs Pack
1. Users are responsible for the security and mitigation of violations of their own SMEs Pack accounts, such as implementing appropriate security, limiting access, creating strong passwords, protecting passwords, maintaining one time passwords ("OTP").
2. SMEs Pack is not responsible for the exchange and provision of User personal data and information carried out by the User, including between Users. Included in these provisions are any and all User errors that result in User data leakage.
3. SMEs Pack is responsible for the SMEs Pack System, including the protection and security of confidential personal data, including notifying Users in the event of a failure to protect personal data via at least e-mail to Users registered with the SMEs Pack System and reporting to law enforcement officials or agencies Related Sector Supervisors and Regulators. In the event of a data leak, the party responsible for informing the User regarding failures in data protection is the party or institution where the data is processed based on this Privacy Policy.
4. SMEs Pack is not responsible for the authenticity, authenticity, correctness, accuracy, completeness of personal data entered by Users into the SMEs Pack System.
5. By providing User Consent, Users waive their rights to claims, losses, demands and lawsuits that may occur regarding the acquisition, storage, use, utilization and/or disclosure of data, including personal data, in the SMEs Pack System.
6. In the event that the User is a minor, SMEs Pack is not responsible for inputting the child User's personal data and recommends that the child's parent/guardian monitor the child's internet usage, so that the child User's personal data is provided and/or supervised by the parent/guardian as authorized party.
7. SMEs Pack is not responsible for data leaks that occur due to and/or occur during Force Majeure.
INTELLECTUAL PROPERTY RIGHTS
1. All works contained in the Service or Platform and its supporting systems including but not limited to: (a) layout, design and appearance of the Service or Platform contained or displayed on SMEs Pack media; (b) logos, photos, images, names, brands, words, letters, numbers, text and color arrangements contained in the Services or Platform; and (c) the combination of elements as intended in letters (a) and (b), fully constitutes SMEs Pack's Intellectual Property Rights and no other party also has rights to the SMEs Pack Services or Platform.
2. Users are not permitted from time to time to:
a. copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, publicly display, reproduce, transmit, transfer, broadcast, describe or disassemble any part of or otherwise exploit the Platform (including supporting systems and facilities therein) licensed to Users, except as permitted in this Privacy Policy;
b. license, sublicense, sell, resell, transfer, transfer, distribute or commercially exploit or otherwise make available the software and/or software to third parties in any way;
c. publish, distribute or reproduce in any way copyrighted material, trademarks or other information from SMEs Pack without obtaining prior consent from SMEs Pack's proprietary rights or the rights owner who licenses his rights to SMEs Pack;
d. remove any copyright, trademark or other proprietary notices contained in the SMEs Pack service;
e. reverse engineer the SMEs Pack application or access and/or supporting systems to (i) build a product or service counter, (ii) build a product or service using a similar idea, feature, function or graphic, or (iii) copy an idea, feature, function or chart;
f. launching automated programs or scripts, including, but not limited to, web crawlers, web robots, web indexers, bots, viruses, worms, or other similar applications and any program that may make multiple server requests per second, create a heavy load, or hinder the operation and/or performance of the Platform;
g. use any robot, spider, site search/retrieval application, or other manual or automatic process or process to retrieve, index, "data mine", or in any way reproduce or circumvent the navigational structure or presentation of the SMEs Pack application and its contents.
COOKIES
1. Cookies are small data storage places on a computer or other device such as a smartphone or tablet, when a User browses and/or visits the SMEs Pack Site.
2. The User's computer or other device will automatically receive Cookies when the User browses and/or visits the SMEs Pack Site and when the User uses SMEs Pack services ("Use of Cookies"). However, Users can determine the choice to modify or choose to refuse the Use of Cookies through the User's web browser settings preferences.
3. SMEs Pack uses Google Analytics ("Feature"), where data obtained from the use of the Feature includes, User IP address, User device type, etc. ("Data"). This data is used by SMEs Pack for the development of the SMEs Pack Site and Content as well as advertising. Users can choose not to be accessed by the Feature by downloading the Google Analytics Opt-Out Add-on on the User's web browser.
4. SMEs Pack may provide User data and information originating from the Use of Cookies to third parties, such as location data, advertising identifiers, or email addresses used for advertising segmentation, including but not limited to marketing and advertising needs, where the data and information are not personally identifiable.
5. Users can control the use of cookies through the user's web browser settings preferences, namely by modifying or choosing to refuse the use of cookies. However, by making these settings, service performance when accessing the SMEs Pack Site may be affected, such as certain functions and pages on the SMEs Pack Site not being able to work optimally for service to Users.
