KEBIJAKAN PRIBADI

2.1. General

The following sections cover the specifics of each of the following groups from which Personal Data is collected: Website's visitors ("Visitors") and/or users ("Users") and/or business partners (e.g., affiliates, advertisers, publishers, advertising agencies and/or platforms, etc.) of our Services (collectively "Partners"). For the purposes of this Policy, Personal Data shall mean and may comprise: IP address, first and last name, postal and/or email address, telephone number, interest in products and services, leads information, as well as information as to the type of relationship that exists between us and Visitors, Users and/or Partners that shall have the meaning ascribed to such terms in the applicable data protection regulation and/or the law.

2.2. Collection and Use

By visiting the Website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit the Website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on the Website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of the Website may not be possible. We may collect, record and analyze information of Visitors to the Website. We may record your IP address and use cookies (see: Cookies Policy below). We may add information collected by way of page view activity. Furthermore, we may collect and process any Personal Data that you volunteer to provide, and/or make available to, us in our Website's forms, such as when you subscribe or sign up for our Services and/or for receiving information. We gather data about visits to the Website, including numbers of Visitors and visits, Geo-location data, length of time spent on the Website, pages clicked on or where Visitors have come. For the purposes of this Policy, Visitor shall mean any person who visits the Website and reviews any of its content; User shall mean any Visitor of the Website who receives Service(s) and/or actively provides data (e.g. via forms, registration process or other methods).

2.3. Purpose of Processing Personal Data

We may process Personal Data to operate, improve, understand and personalize our Website and/or Services. For example, we use the following Personal Data to use your data augmented with data from our operations to improve the accuracy of our Services; Communicate with you about the Services; Contact you about Service announcements, updates or offers; Provide support and assistance for the Services; Meet or comply with contractual or legal obligations towards our Partners; Collaborate, cooperate and otherwise work with our Partners, vendors and service providers; Sharing Personal Information with our Partners, vendors and service providers who may perform services on our behalf (e.g., via API and/or other electronic and digital means); Enforce our Terms of Use and/or our Policies; Additionally, we may communicate with you through the means you've provided us to do so.

We shall not process Personal Data unless there is a legal basis for such processing.

The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:

2.4. Sharing Personal Data

We may also share such information with service vendors, Partners and/or contractors in order to provide a requested service or transaction or in order to analyze the Visitor's and/or User's behavior on the Website and/or Partners' websites.

For Visitor and/or User with accounts located in the European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following in accordance with the GDPR (as defined below) and/or the applicable Data Protection Laws and Regulations (as defined below).

Personal Data about you may be transferred to a third country (i.e., jurisdictions outside the European Economic Area ("EEA")) or to international organizations. In such circumstances, we shall take appropriate reasonable efforts to safeguard aimed to ensure the protection of Personal Data about you and provide that enforceable data subjects' rights and effective legal remedies for data subjects are available.

These safeguards and protection will be available if any of the following are met:

You may request us to be provided with details concerning the safeguards employed by us to protect the Personal Data about you which is transferred to a third country or an international organization, by sending an email to the email address below.

3.1. General

In order to provide our Services and to corporate with our Partners, we may collect or obtain certain types of data from them. Partners may upload, transmit, import, post or process anonymized data about their users, visitors and/or customers ("Data"). During a Partner's use of our Services, it may provide us with its and/or its users', visitors' and/or customers' information via API and/or other electronic and digital means. Partner will not use, and will not assist or knowingly permit any third party to, (i) use the Services to collect or store personally identifiable information (information that may identify an individual); (ii) pass personally identifiable information data to us that could use or recognize as personally identifiable information of its customers. This information is used by us to identify the Partner and/or its users, visitors and/or customers and provide our Services, support, mailings, sales and marketing actions, billing (if required or applicable) and to meet our contractual obligations with the relevant Partner. In addition, we will only have access to information related to the Partner's users, visitors and/or customers after it has been pseudonymized by the Partner, unless otherwise required and authorized by such users', visitors' and/or customers' explicit consent, or by the law and/or legal authority.

Partner acknowledges that: (i) the Service does not operate as an archive or file storage service and we do not obligate to store or backup the Data that Partner upload, import or post to us, or otherwise generate during its use of the Service; (ii) it is solely responsible for the backup of the Data; and (iii) it will lose access to any Data that have been deleted according to our sole discretion or as required by the law and/or any legal authority.

Partner understands and acknowledges that the Internet and communications over it may not be secure, and that connecting to it provides the opportunity for unauthorized access to computer systems, networks, and all data stored therein. The information and data transmitted through the Internet (including, without limitation, the Data) or stored on any equipment through which Internet information is transmitted may not remain confidential and we make no representation or warranty regarding privacy, security, authenticity, non-corruption or destruction of any such information. Use of any information transmitted or obtained over the Internet is at the Partner's own risk and we shall not be responsible for any adverse consequence or loss whatsoever from the use of the Internet.

3.2. Processing of Personal Data

We rely on the Partner's consent to process Personal and/or on Partner's representations and statements that such Partner has obtained the required consent from its users, visitors and/or customers. On other occasions, we may process Personal Data when it needs to do this to fulfill a contractual obligation with you as a Partner or where it is required to do so by law.

We may also process Personal Data when it is in our or our Partners' legitimate interests to do so and when these interests are not overridden by the individual's data protection rights (which may vary based on an individual's jurisdiction).

Partner acknowledges and agrees that the Data which will be provided to us may contain personally identifying information or personal data, as defined by the applicable laws which govern the use of data relating to identified or identifiable natural persons residing in the EU and/or the state of California in the United States, including the laws of the European Union ("EU") Data Protection Act 1998, the EU General Data Protection Regulation ("GDPR"), and the California Consumer Protection Act effective as of January 1, 2020, as each of these laws is amended or replaced from time to time, and any other foreign or domestic laws to the extent that they are applicable to the personally identifiable or personal data you upload, transmit, post or process while using the Service ("Data Protection Laws and Regulations").

Partner hereby grants us a non-exclusive right and license to receive, retrieve, access, use, reproduce, display, copy, transmit, process and store (collectively, "Process") the Data in order to provide the Services. We may redact, anonymize, and/or aggregate the Data with content and data from our other Partners or as collected by us pursuant to this Policy ("Data Aggregations") for purposes including, without limitation, product and service development and commercialization and quality improvement initiatives. We will redact or anonymize Data in such a way as to not divulge any Confidential Information (as defined below) or personally identifying information. All Data Aggregations will be the sole and exclusive property of us.

Partner represents and warrants that: (i) it have lawfully obtained any personally identifying information or Personal data pursuant to any and all applicable and relevant Data Protection Laws and Regulations; (ii) it have appropriately disclosed to users, visitors and/or customers how personally identifiable information or personal data will be used, processed, stored and/or shared pursuant to any and all applicable and relevant Data Protection Laws and Regulations; (iii) it is responsible for honoring any requests from users, visitors and/or customers relating to the collection, use and storage of personally identifiable information or personal data as required by any and all relevant Data Protection Laws and Regulations; (iv) it owns or have acquired the right to all of the intellectual property rights subsisting in the Data, and have the right to provide us the license granted herein to the Data; and (ii) the Data does not infringe or violate any patents, copyrights, trademarks or other intellectual property, proprietary or privacy rights of any third party. Partner shall remain solely responsible and liable for the Data, including without limitation for our use of and reliance upon such Data, and expressly release us from any and all liability arising from any such activities.

3.3. Controller/Processor

We may process Personal Data both as a Processor and/or as a Controller, as defined in the GDPR and/or the Data Protection Laws and Regulation:

• For Visitor's and/or User's data, provided by the Visitor and/or User to us, we will be the Controller in accordance with the GDPR and/or the Data Protection Laws and Regulations.
• For Partner's data and/or Partner's and its users', visitors' and/or customers' data, provided by the Partner to us, we will be the Processor in accordance with the GDPR and/or the Data Protection Laws and Regulations.

All data collected by us will be stored in secure hosting facilities. All hosting is performed in accordance with the highest security regulations. We contract with such hosting providers ensures that all hosting is performed in accordance with the highest security regulations.

We have adopted reasonable physical, technical and organizational safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Partner's data and/or Partner's data and/or the Personal Data in our possession. We will promptly notify Partner in the event of any known unauthorized access to, or use of, the Partner's data and/or Partner's and its users', visitors' and/or customers' data and/or the Personal Data.

3.4. Third-Party Data Protection.

To the extent that the use of the Services (where applicable) requires Partner to process its users', visitors' and/or customers' Personal Data, as part of its use of any third-party's platform, for the purposes of the GDPR and/or the Data Protection Laws and Regulations, such platform will be the Controller and Partner will act as a Processor and will:

8.1. Right of Access

You have the right to receive us confirmation as to whether or not Personal Data about you is being processed, and, where that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the EEA or international organizations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data is not collected from you, any reasonable available information as to its source (subject to our contractual obligation towards such source); (8) the existence of profiling; and (9) where Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.

We shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others, and therefore if the request will harm the rights and freedoms of others or our contractual obligation towards such third parties, we may not fulfill your request or do so in a limited manner.

8.2. Right to Rectification

You have the right to obtain from us the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right to have incomplete Personal Data about you completed, including by means of providing a supplementary statement.

8.3. Right to Erasure

You have the right to obtain from us the erasure of Personal Data about you where one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object, at any time, on grounds relating to your particular situation, to processing of the Personal Data which is based on the legitimate interests pursued by us or by a third party (including our Partners), and there are no overriding legitimate grounds for the processing; (d) you object to the processing of the Personal Data for direct marketing purposes; (e) the Personal Data has been unlawfully processed; (f) the Personal Data has to be erased for compliance with a legal obligation under the law to which we are subject.

This right is not applicable to the extent that the processing is necessary: (a) for compliance with a legal obligation that requires processing under the law to which we are subject; or (b) for the establishment, exercise or defense of legal claims.

8.4. Right of Restriction of Processing

You have the right to obtain by our restriction of processing of Personal Data about you where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; (c) we no longer needs the Personal Data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; (d) where the processing of the Personal Data is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; (e) where the Personal Data is processed for direct marketing purposes, including profiling the extent that it is related to such direct marketing.

8.5. Right to Data Portability

You have the right to receive the Personal Data about you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Data to another controller, where: (a) the processing is based on your consent or on a contract to which you are a party; and (b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the Personal Data about you transmitted directly from us to another entity, where technically feasible. The exercise of your right to data portability is without prejudice to your and our rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

8.6. Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you which is based on the legitimate interests pursued by us or by a third party (including our Partners), including profiling based on such legitimate interests; in such case, we shall no longer process the Personal Data about you unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You have the right to object, at any time, to the processing of Personal Data about you for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

8.7. Right to Withdraw Consent

You may withdraw your consent provided to us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal. Please note that in a case where you will withdraw your consent, we may not be able to provide you with some of our Services.