1.         Foreword

1.1.       BAckground

Privacy Policy is created as an instruction and support from top management in PT. Truest Tech Indonesia to protect customer’s information regarding the company’s business needs and to conform with the law, legislation, regulation, and relevant contract obligation.

This policy is meant as a guide in the process of protecting the customer’s information in PT. Truest Tech Indonesia services, in which information that belongs to the customer that has been processed, stored, and exchanged by the company’s employee and technological infrastructure of information that the company has.

This Privacy Policy has been approved by the top management in PT. Truest Tech Indonesia that will then be disclosed and communicated to all employees and customers.

This policy is valid for all services provided by PT. Truest Tech Indonesia to every member and user that is listed in the Terms and Conditions (T&C) (will then be stated as “we”, “belongs to us”, or “PT. Truest Tech Indonesia”) and this applies when using our website, services, or functionality, product, or any other services offered by PT. Truest Tech Indonesia.

This Privacy Policy regulates on how we collect, use, transfer, store, protect, and disclose your PII (Personally Identifiable Information) data and/or PII of your customer or the latter user that you gave us in accordance with your usage of PT. Truest Tech Indonesia’s platform, or other terms that relates to the data location.

1.2.       Objectives

As a regulation regarding the Republic of Indonesia’s Law No.27 Year 2022 about protection of Personal Data

We collect, store, use, and disclose PII for these objectives:

·         Processing your registration as a user, giving a User ID in PT. Truest Tech Indonesia’s platform and keep and manage your registration;

·         Giving Customer Service and respond to your question, feedback, claim, or problems;

·         Providing services to you and/or your latter user;

·         Processing your purchases and/or subscriptions;

·         Establishing a more personal communication with you based on your transaction history, and researching or analyzing it statistically to upgrade our product offer and services;

·         To conform with the regulation, law process or relevant government’s regulation, or  in relation to a claim or potential claim against us or the parent company, shareholder, subsidiary, and our affiliation;

·         To do a risk control, conform to the law and filter the sanctions;

·         To filter and check activities that violates the rules, deceptive, fraudulent, or harmful.

·         We store the information that you give regarding yourself to provide the necessary information or services. This information, excluding any Personal Information, usually stored in a specified period of time, except if you ask for it to be removed.

Related to your permission (or if it is permitted by the relevant law in your jurisdiction), we can use the name, phone number, home address, email address, and your fax number (that may contain PII) to give announcement, survey, product alert, related communication and marketing materials and other promotions to you that relates with the product and services that we offer in PT. Truest Tech Indonesia’s platform and services.

1.3.       Scopes

This Privacy Policy explains our practice to collect and disclose information that we have gather when the data subject process services through PT. Truest Tech Indonesia’s products.

This Privacy Policy covers handling of every information or a set of information that is used by or on behalf of PT. Truest Tech Indonesia to identified individual, that perhaps, in a certain context, includes information such as first and last name of an individual that can be identified, phone number, debit or credit card number, account number, (collectively called “Personal Information”) that we collect through services. This Privacy Policy also covers our handling of any Personal Information that is shared by our business partner to us or that we shared with our business partner. You can navigate most of our website without giving out any personal information regarding yourself to us. However, we are able to trace technical information (see “Information Collected through Cookie Menu” below) that you gave us while browsing website to increase navigation, content, and design of our website.

Services that can be used by our customer (which is registered customer from PT. Truest Tech Indonesia) for product used by the latter user of the customer. Every information collected and handled by PT. Truest Tech Indonesia in that condition is processed on behalf of our customer that controls the collection and usage of such information.  We will not conduct any direct contact with the latter user of our customer. In this case, the latter user must direct the whole privacy questions, such as request to access, revise, change, or remove PII, to customer of PT. Truest Tech Indonesia that provides their product or services. We will not be responsible for privacy or security practice of our customer.

This Privacy Policy is not valid for privacy practice of third parties that we don’t have or can’t control, but is not limited to, third parties website, services, application, online resources where this site can link to, frame or reference (collectively “Third Party Services”) that you can access through services. We will not be responsible for content or privacy practice from that Third Party Services. We encourage you to observe thoroughly every privacy policy from Third Party Services that you access.

1.4.       collecting pii data

Information that is given to us is data from member or acquirer at the time that they have already cooperate with us

·         Customer Service: When you contact customer support, sales, or any other department from PT. Truest Tech Indonesia, we will record every communication for security purposes and Customer Service’s needs and collect additional information to help verified your identity.

Aside from that, every information that you convey through email to us, our team will also accept confirmation when you open the email. This is our way to collect and use information to enhance our Customer Service.

·         Information Collected through Cookie Menu: We use cookie information to analyze trend, manage website, track the user’s movement, and collect demographical information for aggregate usage. PT. Truest Tech Indonesia also use Google Analytics, an analysis service provided by Google, Inc. (“Google”). Google Analytics use cookie to collect unidentifiable information, that can be sent and stored by Google in the Indonesian server. Google provides a few additional privacy choices that is explained in www.google.com/policies/privacy/partners/ regarding Google Analytics cookie. Most of the browser has an option to disable cookie to avoid your browser to accept any new cookie or activate cookie use selectively.

User that doesn’t accept cookie from our website may be unable to access a certain area in the website.

·         IP and Other Information Collected Automatically: We can accept and record information from your website browser automatically when you use our services, including your IP Address. IP Address is a number given to you by your internet service provider so you can access the Internet. We receive IP address during the normal operation of our sites. We can automatically collect and record information regarding your usage of our service feature, about our service functionality, and other information that relates to your interaction with the service. We use those information that we have collected and recorded automatically to analyze trend, manage, supervise, and enhance the sites and service performance, to track the sites and service usage by the user, and to collect an extensive demographical information for aggregate usage. We will not be using the IP address to identify you personally or disclose it to others. This information is used to fight against spam/malware and to facilitate data collection about your interaction with the service (for example, which link have you clicked).

Usually, services can automatically collect usage information, such as the amount and frequency of the site visitor. We can use this data in aggregate form, that is, as a statistic measure, but not in a way that will identify you personally. This kind of aggregate data allow us and third party that has been given authority by us to be aware about how often does an individual use a part of our service so we could analyze and improve it.

1.5.       DISTRIBUTION OF PII DATA

·         With merchant that you pay through PT. Truest Tech Indonesia’s services and service provider to finish your transaction and any incident that happens, this could prevent fraudulent act. Be aware that these related parties have their own privacy policy to regulate usage and disclose your personal information. We advise that you do a thorough check of their privacy policy.

·         With vendor that works together with us in operating PT. Truest Tech Indonesia’s business. We oblige every vendor that works together with us to protect your information.

·         Aside from that, as stated in this Privacy Policy, PT. Truest Tech Indonesia will not hand out, sell, or rent any individual personal information to anyone without your consent or except by the ruling of court.

·         Information that is sent to us will only be available and used by employees and our system that is responsible to provide Customer Service or to the service provider that has a contract for the purpose of providing our communication service to you.

·         Head of the legal entity that is competent, regulating institution, health, government institution, or any other third parties, where we are certain that a disclosure is needed (i) as an issue to law or valid regulation, (ii) to operate, decide, or defend our rights, or (iii) to protect your vital interest or other parties.

 

1.6.       TRANSFER OF PII DATA

As a part of your provision, we may need to move your PII from your jurisdiction to another jurisdiction abroad. Data receiver in this jurisdiction may conform to a data privacy law that is less protective or is not equal to the law in your jurisdiction.

Transfer or processing of your PII abroad may be needed to process and manage account (including providing customer service to you, contacting you regarding promotion, product and service, do a risk control, avoid fraudulent act, and law compliance procedure, and do a service of payment process).

1.7.       SECURITY SYSTEM

We will try to protect PII that you have given to us. We will also apply several security techniques, but not limited to the use of SSL encryption, that is the industrial standard for transmitting PII in the registration and payment information and applicating steps of identity management, credential, and access to transmitting PII in order to avoid security breach and unauthorized PII access. We have restricted access to your PII and other data only to people who needs access for their jobs.

However, there is no data transmission through internet or any other wireless connection can be guaranteed 100% secure. Therefore, even if we already try to protect you PII, we can’t guarantee the security of every PII that is sent to us, so you are doing it with your own risk. We can’t guarantee the safety of your connection that is used to access PT. Truest Tech Indonesia’s services.

We keep your PII within a certain period based on the needs for necessary purposes. Aside from that, storing User’s Private Data is done in accordance with the law and regulation.

1.8.       MAIN RESPONSIBILITIES REGARDING PII DATA

You have a right to ask access to your PII data that we store (or on behalf of our name) and ask for correction or removal of those PII. Moreover, by request, we can also give information about whether we have your PII data. You can contact us through info@truesttech.id to request access, correction, or removal of your PII data. We will be responding to your request within a reasonable period. You may also have additional rights based on the law that is valid and relates to you PII data. For example, you have the right to reject or restrict your PII data processing, and to ask for portability.

In the case that we act as a processor, we will not conduct any direct contact with the individual whose PII we processed. Someone that search for access, or tries to revise, change, or remove their inaccurate data must be instructed to hand the query to their PII controller.

You may receive e-newsletter from us. If you want to stop receiving this information, you can renew your email preference by using the “Unsubscribe” link in the email that we sent you or on your profile account.

We will never intentionally collect the PII data of underage child (someone under 18 years old). If an underage child gave us their PII data, parents or guardian can contact us on behalf of their child to stop collecting, using, and/or disclosing PII any further and remove any possible PII data that we have regarding the underage child.

If you have any question regarding this Privacy Policy or want to use one of this or other rights that you may have based on the law related to you PII data, you can send a written request to this contact: Email: info@truesttech.id

1.9.       CHANGES IN PRIVACY POLICY

PT. Truest Tech Indonesia can change this policy from time to time. If we made any major changes in our approach to use your personal information, we will inform you by posting an announcement on our website. You have given your approval that a posted announcement is adequate to notify you regarding these changes. You have approves that as long as you use our product and services, you will agree to every policy and amendment from the terms and conditions.

This policy comply to the law that is valid in the Republic of Indonesia that relates with protection of information, and if needed, by the rightful authority for any regulation objectives, such as law compliance of any kind.

To avoid any violation with the law, we will release all necessary information needed by the authority and valid in accordance with the court ruling from the competent jurisdiction.

1.10.   CONTACT OF PT. Truest Tech Indonesia

If you want to request access to your PII that we have, or you want to contact us for other reason related to policy or our privacy practice, please contact our Data Protection Officer by sending your email through info@truesttech.id.

Please note that we will charge a reasonable price to process any data access request.

 

2.         POLICY REVIEW

This policy is managed by the Standard Management and Compliance Function. Every input regarding changes into this policy must be submitted to the Standard Management and Compliance Function and its change must have approval from the authorized personnel as stated in the provision that applies in PT. Truest Tech Indonesia.

This policy shall be reviewed periodically by the Standard Management and Compliance Function at least once every 3 (three) years to ensure the validity with the company’s condition.