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PRIVACY POLICY

As of 1 May 2019


The following Privacy Policy describes how we, LOKAL (CV Hyperlokal Indonesia and affiliates, “we”, “us” or “our”) collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Policy applies to all users of our applications, websites (www.hyperlokal.id), services, or products (“Applications”), unless covered by separate privacy policy.

Please read this Privacy Policy thoroughly to ensure that you understand our data processing practices. Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meaning ascribed to them in the Terms of Use.

This Privacy Policy includes the following matters:

PERSONAL INFORMATION WHICH WE COLLECT

We collect information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains (“Personal Information”). Personal Information includes, but not limited to, name, address, date of birth, occupation, phone number, fax number, e-mail address, gender, identification (including KTP, SIM, or Passport) or other government issued identifier, photo, and nationality. Additionally, to the extent other information, including a personal profile, unique identifier, and/or biometric information is associated or combined with Personal Information, then that information is also Personal Information. The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register or use the Application, when you contact our customer services, or you otherwise provide Personal Information to us). We may collect information in various forms and purposes (including purposes permitted under applicable law).

Information obtained from you or from your mobile device directly

Information collected whenever you use the Application or visit our website

Information collected from third parties

We may also collect your Personal Information from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with). In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be).

Information about third parties you provide to us

You may provide us with Personal Information relating to other third-party individuals (including Personal Information relating to your spouse, family members, friends, or other individuals). you will, of course, need their consent to do so – see “Acknowledgement and Consent”, below, for further information.

THE USE OF PERSONAL INFORMATION WHICH WE COLLECT

We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by applicable law (“Purposes”):

  1. Where you are a user, we may use your Personal Information:
  2. to identify you and to register you as a user and to administer, verify, deactivate, or manage your account as such;
  3. to facilitate or enable any verification as we may in our discretion consider necessary before we register you as a user, including Know Your Customer (KYC) process;
  4. to enable service providers to provide you with such of the services as you have requested;
  5. to process and facilitate orders and payment transactions made by you;
  6. to communicate with you and to send you information in connection with the use of the Application;
  7. to notify you of any updates to the Application or changes to the services available;
  8. to process and respond to enquiries and feedback received from you;
  9. to maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a user;
  10. to monitor and analyse user activities, behaviour, and demographic data including trends and usage of the various services available on the Application;
  11. to process and manage your reward points;
  12. to offer or provide services from our affiliates or partners; and
  13. to send you direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions.

SHARING OF PERSONAL INFORMATION WHICH WE COLLECT

  1. We may disclose to or share with affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by applicable law:
  2. where you are a user, for the purpose of enabling a job provider, to perform a recruitment;
  3. where you are a job provider, for the purpose of enabling a user to apply a job from you;
  4. where required or authorised by applicable law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing and reporting requirements), for the purpose so specified in that Applicable Law;
  5. where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the services, for the purposes of that legal proceeding;
  6. in relation to any verification as we or a service provider may in our discretion consider necessary before we register you as a user, including Know Your Customer (KYC) process;
  7. in an emergency concerning your health and/or safety (whether you are a user or a service provider) for the purposes of dealing with that emergency;
  8. in connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
  9. to third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us or you, perform functions on our behalf, or whom we enter into commercial collaboration with) for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, or other conducting activities including marketing, research, analysis and product development; and
  10. where we share Personal Information with affiliates, we will do so for the purpose of them helping us to provide the Application, to operate our business (including, where you have subscribed to our mailing list, for direct marketing purposes), or for the purpose of them conducting data processing on our behalf. For example, a LOKAL Affiliate in another country may process and/or store your Personal Information on behalf of the LOKAL group company in your country. All of our affiliates are committed to processing the Personal Information that they receive from us in line with this Privacy Policy and applicable law.

RETENTION OF PERSONAL INFORMATION

  1. Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or authorised by Applicable Law. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.

ACCESS AND CORRECTION OF PERSONAL INFORMATION

  1. Subject to the applicable law, you may request us for access to and/or the correction of your Personal Information in our possession and control, by contacting us at the details provided below.

WHERE WE STORE YOUR PERSONAL INFORMATION

  1. The Personal Information that we collect from you may be stored at, transferred to, or processed by third party service providers. We will use all reasonable endeavors to ensure that all such third-party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

SECURITY OF YOUR PERSONAL INFORMATION

Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control. You are responsible for keeping your account details confidential and you must not share your account details, including your password and One Time Password (OTP), with anyone and you must always maintain and fully responsible on the security of the device that you use.

CHANGES TO THIS PRIVACY POLICY

We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice published on the Application and/or website, or otherwise to your e-mail address set out in your account. You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and that your continued use of the Application or website, communications with us, or access to and use of the services following any amendments to this Privacy Policy will constitute your acceptance to this Privacy Policy and all of its amendments.

ACKNOWLEDGMENT AND CONSENT

By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you accept all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.

MARKETING AND PROMOTIONAL MATERIAL

We and our partners may send you direct marketing, advertisement, and promotional communications via push-notification app, message in Application, post, telephone call, short message service (SMS), instant messaging and e-mail (“Marketing Materials”) if you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us. You may opt out from receiving such marketing communications at any time by clicking on any “unsubscribe” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you opt out, we may still send you non-promotional messages, such as ride receipts or information about your account.

ANONYMOUS DATA

We may create, use, license or disclose Personal Information, provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) that has been combined with similar data such that the original data forms a part of a larger data set.

THIRD PARTY PLATFORMS

  1. The Application, website, and Marketing Materials may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.
  2. Advertisements contained on our Application, website, or Marketing Materials operate as links to the advertiser’s website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

HOW TO CONTACT US

If you have any questions regarding this Privacy Policy or, please contact legal@hyperlokal.id

© CV Hyperlokal Indonesia.All Rights Reserved.