PRIVACY POLICY

 

PT Royal Pesona Indonesia ("HINT", "we", "us", "our") respects your privacy. Our privacy policy (“Privacy Policy”) summarizes what personal information we collect when you use any website operated by or on behalf of HINT (each, a “Website”), and how we use and disclose this information. This Privacy Policy also describes other important topics relating to your privacy. Please read this privacy policy to understand and agree on as it will help you understand what we do with the information that we collect. HINT reserves the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy in our Website(s) and will indicate at the top of this page the date this Privacy Policy was last amended. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.

 

TABLE OF CONTENTS

 

  1. WHAT INFORMATION DO WE COLLECT?

  2. HOW DO WE USE YOUR INFORMATION?

  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

  5. HOW LONG DO WE KEEP YOUR INFORMATION?

  6. HOW DO WE KEEP YOUR INFORMATION SAFE?

  7. DO WE COLLECT INFORMATION FROM MINORS?

  8. WHAT ARE YOUR PRIVACY RIGHTS?

  9. CONTROLS FOR DO-NOT-TRACK FEATURES

  10. DO WE MAKE UPDATES TO THIS NOTICE?

  11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

  12. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

  13. LANGUAGE

 

  1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

Personal Information Provided by You. Personal information is information about an identifiable individual, such as your name, address, telephone number, email address, or payment information (“Personal Information”). collect Personal Information when you voluntarily provide it through a Website, or when you provide it to us through other means. For example, we may collect Personal Information when you:

 

  • Provide us with information on our Website;

  • Create an account;

  • Use a Website to make a purchase; or

  • Otherwise provide us with Personal Information.

 

The Personal Information that we collect include:

 

  • When you create an account, your first and last name; contact information, such as your address, telephone number, or e-mail address; your age; and your selected home location for your account;

  • If you choose to make a purchase, your payment information; and

  • Any other Personal Information that you voluntarily choose to submit to us or to a Website.

 

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Information automatically collected – Log Data

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our website.

 

We automatically collect certain information when you visit, use or navigate the website, we collect information that your browser sends to us that is called Log Data. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

 

When you visit our Website, we may collect information that is automatically sent to us by your web browser or your internet service provider. This information may include your domain name and your numerical IP address. We may also collect other general information (such as the type of browser you use, which pages you view, and the files you request). We use this information to better understand how visitors use our Website(s) and to improve our Website(s)to better meet your needs. We use this information in the aggregate and do not link it to your Personal Information. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.

 

To enhance your experience on our Website(s), we may use a feature on your Internet browser called a "cookie" and/or other similar devices. Cookies are small files that your web browser places on your computer's hard drive. They are used for a variety of reasons, such as tracking click streams, and for load balancing. Information tracked through these mechanisms may include, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; and (iii) the pages of a Website each user visits, (iv) Facebook pixel, (v) Google conversion tag. By using cookies, we can deliver faster service, consistent, updated results, and a better experience on our Website(s). Your browser gives you the option to reject cookies. However, setting your browser to reject cookies generally hinders the browser's performance and will adversely affect your experience while using our Website(s). We use Bank transfer & Midtrans for payment, analytics, and other business services. Midtrans collects identifying information about the devices that connect to its services. Midtrans uses this information to operate and improve the services it provides to us, including for fraud detection.

 

  1. HOW DOES HINT USE AND DISCLOSE PERSONAL INFORMATION?

 

In Short: We process your information and supporting data for purposes based on legitimate business interests in order to use our Websites.

 

The Personal Information we collect may be used or disclosed by HINT for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. For example, we may use or disclose your Personal Information to:

 

  • Operate a Website in accordance with its terms and conditions,

  • Facilitate a purchase you choose to make using a Website, including facilitating payment for your purchase;

  • Notify you when an order you have made using a Website is ready for pick-up or delivery;

  • Respond to your questions or inquiries;

  • Conduct market research and surveys;

  • Conduct promotional activities, including contests, in association with a Website;

  • Improve our products, services, and our Website(s);

  • Supply you with requested information;

  • Send you informational or promotional communications that you have agreed to receive;

  • Carry out other purposes that are disclosed to you and to which you consent; and/or

  • Carry out any other purpose permitted or required by law.

We reserve the right to transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed.

 

We may also use, or disclose your Personal Information to third parties if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter, for example, if we are subject to a subpoena, court order, or the information is requested by the police or another law enforcement entity; or (iv) to protect our rights, safety or property. We may transfer your Personal Information to third-party service providers that assist us with carrying out these purposes. For example, we use third party service providers to facilitate payments, and we may use a data processing contractor to operate computer systems on our behalf. We provide protection of personal information, which is required under PIPEDA.

 

When Personal Information is transferred to such a third-party service provider, that party will be contractually bound to use such Personal Information only to carry out the services we have requested, and to provide protection for the Personal Information.

 

  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

In Short: We only share information with your consent, to comply with laws, to provide you with Websites, to protect your rights, or to fulfill business obligations.

 

We may process or share your data that we hold based on the following legal basis:

 

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

More specifically, we may need to process your data or share your personal information in the following situations:

 

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • Business Partners. We may share your information with our business partners to offer you certain products, Websites or promotions.

  • Other Users. When you share personal information (for example, by posting comments, contributions or other content to our website) or otherwise interact with public areas of the website, such personal information may be viewed by all users and may be publicly made available outside the website in perpetuity. If you interact with other users of our website and register for our website through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly,

other users will be able to view descriptions of your activity, communicate with you within our website, and view your profile.

  • Offer Wall. Our website may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our website and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our website. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy policy and terms of Website relating to the use of those websites and we recommend you to carefully read the privacy policy of those websites carefully before proceeding to utilize such website.

 

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information.

 

We may use cookies to access or store information and to improve our Website. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Website.

 

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for a minimum period of 5 years to fulfill the purposes outlined in this privacy policy and as required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, or a minimum retention period of 5 years as required by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

You may ask us to delete the personal information provided to us if you deem that the personal information that we collect is irrelevant for the use of our website.

 

  1. HOW HINT PROTECT PERSONAL INFORMATION?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

The security of your Personal Information is important to us. We take measures to help protect your Personal Information by maintaining physical, organizational, and technological safeguards intended to help protect against unauthorized use, disclosure, or access. Personal Information may only be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes indicated above. Personal Information we collect is maintained in Jakarta, Indonesia. We retain Personal Information that we collect for as long as reasonably necessary to fulfill the purposes for which it was collected or to meet any legal requirements. We have retention standards that meet these requirements.

Although we have taken measures to help protect our Website(s), computer systems, and any Personal Information that we have collected from unauthorized use, access, disclosure, misuse, alteration, or destruction, no security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us. All third parties that obtain Personal Information from us (e.g. service providers that perform functions on our behalf) are required to protect your confidentiality and Personal Information in a manner consistent with this policy, and/or as required by law.

 

Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in Indonesia, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the Personal Information.

 

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. We will however notify you immediately if any personal information under our control is compromised due to any breach involving personal information which may have been compromised and take other procedure under applicable laws and regulations.

 

  1. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

 

Our Websites do not address anyone under the age of 18. We do not knowingly solicit data from or market to children under the age of 18 years. By accepting this privacy policy, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the website. If we learn that personal information from users less than 18 years of age has been collected, we will delete the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 18, please contact us so that we will be able to do necessary actions.

 

  1. ACCESS, ERASURE, AND RECTIFICATION

 

In Short: You may review, change, terminate your account and ask us to delete your personal information at any time.

 

You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to HINT and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact form. We will use reasonable efforts to comply with your request; however, in some cases, we may not be able to allow you to access certain Personal Information in certain circumstances, for example, if it contains Personal Information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.

 

Cookies and similar technologies:Most Web browsers are set to accept cookies by default. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive cookies, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or Websites. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.

Opting out of email marketing:You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you Website-related emails that are necessary for the administration and use of your account, to respond to Website requests, or for other non-marketing purposes. To otherwise opt-out, you may access your account settings and update your preferences.

 

  1. THIRD PARTY WEBSITES

 

In Short: Our Website(s) may contain links to other third party websites.

 

These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from this Website to other websites, or references to products, services, or publications other than those of HINT, do not imply the endorsement or approval of such websites, products, services, or publications by HINT.

 

  1. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

Subject to applicable law, PT Royal Pesona Indonesia reserves the right, in its sole and absolute discretion, to modify all or any portion of this Agreement at any time without incurring any liability or obligation whatsoever to you or any other person or entity. If we do this, we will post the changes to this Agreement at least thirty (30) days before the amendment comes into effect, and will indicate at the top of this page the date this Agreement was last revised. You may refuse the amendment and rescind, or cancel your participation without cost, penalty, or cancellation indemnity, by sending us to notice that effect no later than thirty (30) days after the amendment comes into force, using the information in the notice.

 

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE OR ANY USER COMPLAINT?

 

If you have any questions regarding this Privacy Policy, any Personal Information you have submitted to us, or if you would like to:

 

  • access Personal Information that you have already provided to us so that you can correct or update it, or request that it be deleted;

  • request the deletion of Personal Information regarding your minor child; and/or

  • report any violation of this Privacy Policy;

 

Please advise us by contacting our Privacy Officer by contacting us through the contact page.

 

  1. LANGUAGE

 

This privacy policy has been prepared in both English and Indonesian languages. If there is any inconsistency or conflict between the English and the Indonesian languages version of the privacy policy, the English language version shall prevail.

 

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